Where money laundering offences involve a sophisticated plan with separate activities to disguise proceeds (such as funnelling cash through business accounts and vehicle purchases), this constitutes additional criminality over and above the underlying conspiracy offence, justifying partial accumulation of sentences. The cases of Thorn, Nahlous and Dela Cruz are confined to situations where the proceeds offence was merely incidental to the primary offence. The CCA will not lightly entertain arguments on appeal that were not advanced at the sentencing hearing, and where an offender seeks to establish for the first time on appeal that his role was more junior than a co-offender, he bears the onus of establishing that on the balance of probabilities.
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