General deterrence was a relevant sentencing consideration for Commonwealth offences under s 16A of the Crimes Act 1914 (Cth) even before the 2015 amendment expressly including it; the amendment clarified rather than changed the law. The distinction between 'marginal' and 'absolute' general deterrence does not provide a basis for reducing sentences for calculated white collar fraud. For systematic BAS fraud of approximately $5.85 million over four years, a sentence of 8 years with recognisance release after 5 years is at the higher end of the range but not manifestly excessive.
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