Offences under s 91 of the Estate Agents Act 1980 (Vic) involving fraudulent conversion of client trust funds are serious offences of dishonesty reflecting a high degree of criminality, not merely regulatory offences. General deterrence, punishment and denunciation carry particular weight in sentencing for such offences, even where the offender has no prior criminal history, good prospects of rehabilitation, and has made efforts at restitution. A total effective sentence of 3 years and 4 months' imprisonment for 62 charges involving close to $2 million was within range.
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