For absolute liability money laundering offences under s 400.9 of the Criminal Code (Cth), the accused's subjective knowledge or belief as to the source of funds is of very limited relevance to sentencing, because knowledge would elevate the offence to a more serious category under ss 400.3-400.8, and treating it as an aggravating feature would breach the De Simoni principle. The value of the proceeds is the paramount consideration in assessing objective seriousness. A sentencing judge's failure to specifically identify comparable cases in reasons does not establish specific error; such a complaint is properly characterised as a particular of manifest excess.
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