When sentencing for rolled-up counts under s.193C(1) Crimes Act 1900 (NSW), the number of individual transfers, total amount involved, and average amount per transaction in each count must be individually assessed in determining objective seriousness; identical indicative sentences for counts with very substantial differences in these features constitutes error. The use of rolled-up counts may mean that indicative sentences approaching the maximum penalty are appropriate for counts with heightened objective gravity. Exceptional and ongoing assistance to law enforcement authorities, combined with an imminent release date, may justify the exercise of the residual discretion not to resentence even where manifest inadequacy is established.
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