Crime script analysis of drug importation into Australia facilitated by the dark net

ABSTRACT

A growing facilitator of drug trafficking are dark net markets, which enable transactions between sellers and buyers of illicit drugs around the world. This study aimed to develop a crime script for drug importation into Australia and identify potential crime prevention points within the crime script. To achieve this, a content analysis of 18 Australian court sentencing transcripts was conducted. The final crime script consisted of five general steps taken by offenders (preparation, access, purchasing, receiving and storage) followed by three script tracks based on the purpose of importation (selling on the dark net domestically, selling offline and personal use). This study will contribute to the current knowledge of the crime commission process of buyers on the dark net by focusing on online and offline steps, and the importation in the Australian context. Through these insights, this study will conclude by looking at potential specific and tailored crime prevention measures.

KEYWORDS:

• Cryptomarket
• dark net
• drug trafficking
• drug importation
• crime script analysis
• crime prevention

Introduction

Illicit drug trafficking is a problem faced by law enforcement agencies worldwide. In Australia, the international mail stream accounts for the largest proportion of drug detections (73–98% depending on the drug type), while by weight the proportion of air, sea and mail streams varies by drug type (Australian Criminal Intelligence Commission (ACIC), 2021). In comparison, in locations such as Europe, drugs are generally trafficked by land, sea and air with a low proportion being sent through the mail (European Monitoring Centre for Drugs and Addiction EMCDDA, 2019). The recognition of this emerging trafficking route by policymakers is evident through the investment of an additional $88 million to fund the increase of screening of international mail from 10 to 50 million items annually (Australian National Audit Office, 2015). Many countries are now witnessing increases in the use of post and parcel services with the drug market moving towards the use of social media platforms, the surface web and the dark net (EMCDDA, 2019). This includes Australia, where forensic intelligence revealed online purchases now comprise up to 75% of packages seized by the Australian Border Force (Horne et al., 2015). Although Australia does have a high policing capacity and reputation of strict border monitoring, Australian buyers continue to engage in dark net markets, some purchasers are buying from international vendors exclusively (38%) and some from both international and domestic vendors (30%). Moreover, overseas vendors continue to sell large quantities of drugs to Australian buyers (Cunliffe et al., 2017). Most importantly, the majority of purchasers (88%) stated their last order from the dark net arrived without interception (Van Buskirk, Roxburgh, et al., 2016). In addition, although online drug trafficking currently accounts for a relatively small proportion of the global drug market, there is arguably potential for a substantial growth (ACIC, 2020).

Several countries are now witnessing increases in the use of dark net platforms to conduct drug trafficking activities (EMCDDA, 2019). In Australia specifically, drugs that were previously unavailable or expensive are now more easily accessible due to the introduction of dark net markets (Cunliffe et al., 2017). Related to this, Australian vendors have been found to be overrepresented within the cryptomarkets in terms of sellers per capita (Van Buskirk, Naicker, et al., 2016). Moreover, Australian drug markets have continued to grow with drug prices among the highest in the world in 2021 (ACIC, 2021). Despite the high use of international mail control and popularity of dark net drug markets in Australia, little is known about Australian buyers and drug importation activities conducted. This provides an interesting context to not only study Australian buyers but also unexplored aspects such as the online and offline dynamics of these transactions and the application of crime prevention to dark net drug trafficking. In this study, how drug trafficking activities on the dark net are conducted is examined using crime script analysis – a framework to identify how offenders operate step-by-step from preparation to crime commission.

Illicit drug importation through the dark net

A niche but growing facilitator of drug trafficking around the world is the dark net (ACIC, 2020; Winstock et al., 2021). The dark net is a section of the deep web (section of the internet unindexed by search engines like Google) commonly associated with illegal activity (i.e. drug markets) (Bergman, 2001). Most of the dark net markets are hosted on the onion network which can be accessed using the browser TOR (The Onion Router). TOR hides the Internet Protocol (IP) address of the computer used to access the dark net by sending information to various servers around the world, thus masking the identity of the user (Christin, 2013; Martin et al., 2020; Martin, 2014a).

On the dark net, various sites host illegal activities including the sale of illicit drugs, illegal firearms, personal information, and distribution and production of child sexual exploitation material. Many transactions of these products occur on dark net markets, otherwise known as cryptomarkets. Cryptomarkets have been ‘defined as an online forum where goods and services are exchanged between parties who use digital encryption to conceal their identities’ (Martin, 2014b, p. 356). Cryptomarkets are generally hosted on the TOR network and, use of cryptocurrencies for payment, affording various layers of anonymity to individuals engaging in transactions (Barratt, 2012; Martin, 2014b). Moreover, they rely on third party hosting and administration, in a similar manner to eBay or Amazon through which transactions between vendors and buyers are facilitated (Aldridge & Décary-Hétu, 2016a; Barratt et al., 2016; Barratt, 2012; Martin, 2014a, 2014b). Cryptomarkets are trading a variety of products but are dominated by illicit drugs (Barratt et al., 2014; Christin, 2013; Dolliver & Kenney, 2016; EMCDDA, 2019; Tzanetakis, 2018; Van Hout & Bingham, 2013b). Thus, unlike traditional drug markets, these new drug markets are both anonymous and accessible to anyone (buyers known and unknown to the vendor) (Aldridge & Décary-Hétu, 2016b; Christin, 2013; Martin, 2014a). In addition to cryptomarkets, buyers also have the option to purchase from single vendor shops (Aldridge & Décary-Hétu, 2016b; Copeland et al., 2020; Laferrière & Décary-Hétu, 2022). Some vendors have moved from cryptomarkets to running independent dark net stores, allowing them to mitigate some limitations to using cryptomarkets such as exit scams and commissions charged by cryptomarkets (Laferrière & Décary-Hétu, 2022; Tsuchiya & Hiramoto, 2021; Van Hout & Bingham, 2014).

Despite some disagreements about the extent of cryptomarkets growth, the expansion of these markets is obvious (Martin, 2014a; Soska & Christin, 2015). The cryptomarkets were worth an estimated $80 million between 2011 and 2017 and increased to $315 million in 2017 to 2020, which constitutes only 0.2% of drug sales in the United States of America and the European Union (UNODC, 2021). Although only accounting for a small proportion of the drug market, a steady growth is evident in the number of cryptomarkets and in the number of listings (UNODC, 2020). In addition, there has been an increase of individuals who have purchased illicit drugs from the dark net. The Global Drug Survey found the number of buyers jumped from 4.7% to 15% between 2014 and 2020 (Winstock et al., 2021).

The purchase of drugs through dark net are preferred over offline purchases for a variety of reasons. A unique aspect of cryptomarkets is the anonymity of transactions and ease of product delivery (Aldridge & Askew, 2017; Van Hout & Bingham, 2013b). The quality of drugs has also been reported as higher and more consistent with what is advertised (Caudevilla, 2016). For instance, Caudevilla (2016) found that 91.3% of drugs purchased on the cryptomarkets were as advertised in quality terms, and the purity relatively high. Moreover, imported drugs are also cheaper than those produced in Australia (ACIC, 2020; Cunliffe et al., 2017). Personal safety is another benefit related to online transactions as threats or violence is unlikely to occur with online transactions (Barratt et al., 2016; Van Hout & Bingham, 2013b, b). The use of an escrow system also protects the users (Aldridge & Askew, 2017; Bakken et al., 2018; Bancroft, 2017; Tzanetakis et al., 2016). In fact, when purchases are made, the buyer transfers the money to the cryptomarkets and the money is only released to the vendor when the drugs have been successfully delivered (Afilipoaie & Shortis, 2015; Bancroft, 2017). Unlike offline drug suppliers, sellers are also rated and reviewed by buyers like any common online business, which could negatively affect sellers’ activities if bad reviews were posted (Aldridge & Askew, 2017; Nurmi et al., 2017; Tzanetakis et al., 2016).

Being a relatively isolated country with a large domestic drug market, dark net markets have provided Australia a new and easy way to access drugs from overseas (Cunliffe et al., 2017). Moreover, the price of products available on the dark net market is significantly higher within Australia compared to those shipped from other countries, a motivator for buyers to purchase from overseas vendors (Cunliffe et al., 2017). However, this price varies according to drug type. For example, MDMA from international vendors is cheaper in comparison to both the Australian domestic dark net vendors and street prices (Cunliffe et al., 2017). This price difference has been termed a ‘risk tariff’ to represent the increase in price due to the risks associated with importing drugs. This also provides opportunities to make money by purchasing cheap drugs and selling them at a higher price domestically (Munksgaard & Martin, 2020). Since the research in this area is based on the markets and vendor listings only, little is known about Australian vendors and buyers’ activities online as well as offline.

How offender proceed with illicit drug activities on the dark net

Several studies have examined specific decisions or actions by buyers on the dark net. Various studies indicated that vendors are chosen based on various factors including trust, speed of transaction, stealth modes and quality of product (Tzanetakis et al., 2016; Van Hout & Bingham, 2013b). Buyers are also able to make more informed decisions in choosing vendors by accessing forums that provide advice to users, user experiences, products and transaction reviews (Childs et al., 2020; Van Hout & Bingham, 2013b). Access to this type of information allows buyers to shop around for the best products, creating competition among vendors to provide the best service to their customers (Paquet-Clouston et al., 2018; Van Hout & Bingham, 2013b). In addition, the internet, and more specifically forums, provide a wealth of information to offenders regarding ways to avoid detection including concealment strategies, delivery locations, use of real or fictious names, avoiding suspicion and suggested actions if packages are seized (Aldridge & Askew, 2017; Van Hout & Bingham, 2013a).

While the markets were originally for those purchasing illicit drugs for personal use, there is a growing wholesale market. In this context, three relationships between vendors and buyers exist: producer/wholesaler to retailer, producer and consumer and wholesaler to consumer (Martin, 2014a). Aldridge and Décary-Hétu (2016b) found that a quarter of buyers on the dark net are reselling and distributing the drugs. In Australia, 7% of drug users had previously used illicit drugs obtained from the dark net, but around 5% had bought the drugs off the dark net themselves (Barratt et al., 2014). Therefore, the drugs sold on the dark net are not only being used by those accessing the dark net but also drug users purchasing these drugs from distributors in the offline market.

One of the major current challenges for crime prevention is the adaptable nature of drug markets on the dark net. Although the focus of agencies has been to shut them down, research has highlighted the relative ineffectiveness of this strategy (Décary-Hétu & Giommoni, 2017; Ladegaard, 2018; Soska & Christin, 2015; Van Buskirk et al., 2017). For example, after Operation Onymous in 2014, which shut down various cryptomarkets, there was a short reduction in drug-related activities on cryptomarkets (Décary-Hétu & Giommoni, 2017). However, the same number of vendors were still operating on other websites within two months. In the following months, the number of sales was twice as high as before the operation. This demonstrates the need for a framework, such as crime script analysis, to help identify potential innovative and tailored strategies to address drug importation through the dark net.

Theoretical framework

The rational choice perspective emerged to provide a theoretical framework for crime prevention by understanding offender decision-making (Clarke & Cornish, 1985; Cornish & Clarke, 2008). The idea is that to prevent crime, the offender decision-making process needs to be examined. This perspective emphasises the importance of the interaction between the offender and the immediate environment (e.g. location, time of data and absence/presence of third party). Behaviour is seen as purposeful, rational and specific to the crime. The offender is seen as rational and their behaviour a result of weighing up the risks and benefits of the crime with the limited information at hand at the time of the offence. Offending is also seen as crime specific where different crimes involve varying situations requiring different decisions by the offender. Thus, higher levels of specificity may result in more detailed analyses. The specificity of the analyses can also allow for more specific crime prevention measures which centre on tipping the cost–benefit analysis in favour of not committing the crime.

Rational choice perspective was initially used to develop a crime event model to demonstrate how offenders make decisions about selecting targets for their crimes (Cornish & Clarke, 2014). Although this approach introduced the concept of decision-making and judgements made during offending, it only addressed the target selection step of offending. The event model was thus expanded to fully examine and understand the crime commission process for prevention purposes through crime script analysis. With this framework, it becomes possible to use each step of the crime commission process (i.e. not only target selection) to examine the potential of intervention measures to disrupt each of those steps.

Cornish (1994) also borrowed the concept of scripts from cognitive psychology to further develop the crime event model first conceptualised under the rational choice approach. The script is based on the ‘event’ schema which guides how individuals understand and act when faced with common situations. Schemas are knowledge structures, or schemata, and organise knowledge of people and events, serving to guide behaviour when elicited. An example by Schank and Abelson (1977) common example of scripts is the restaurant script which involves the following sequence: enter; wait to be seated; get the menu; order; eat; get the check; pay; and exit. As a behaviour is repeated and desired results achieved over time, the schema may be activated without much thinking.

When applied to crime, scripts are step-by-step accounts of the actions and decisions of offenders during crime commission from preparation of the crime to the aftermath of the crime. The two main contributions crime script analysis offers include providing a framework to assist in analysing crime events and assisting to identify potential intervention points (Cornish, 1994). It pinpoints various elements involved including scenes, paths, actions, roles, props and locations that are required for the execution of each stage. A strength of the crime script concept is its flexibility, which allows for script permutations in response to changing circumstances. If frequently used these script permutations can become mini-scripts or ‘tracks’ of the same script (Cornish, 1994). This deeper understanding of the crime commission process generated allows a more accurate prediction of behaviour and provides a template onto which specific crime prevention measures can be mapped to disrupt crime.

Since the development of crime script analysis, its use has grown exponentially (Dehghanniri & Borrion, 2021). Applications of crime script analyses include a range of drug offences such as drug manufacturing (Chiu et al., 2011), offline drug selling (Jacques & Bernasco, 2014), illicit online prescriptions (Leontiadis & Hutchings, 2015), offline open-air drug market selling (Sytsma & Piza, 2018). Crime scripts have also been developed for crimes on the dark net including for child sexual exploitation material online (Leclerc et al., 2021; Van der Bruggen & Blokland, 2020), counterfeit document procurement (Holt & Lee, 2020) and firearms purchasing (Holt & Lee, 2022). Finally, script analysis has also been introduced to identify the intervention process of potential guardians during crime (Leclerc & Reynald, 2017).

Three studies using crime script analysis to examine drug trafficking are particularly relevant to this study. Jacques and Bernasco (2014) developed a crime script of drug dealing Amsterdam’s red light district showing the importance of the interaction between sellers and buyers. Unlike typical crime scripts, the authors identified two necessary steps (agree on trade terms and make an exchange) and three facilitating steps (search for customer, solicit the customer, and agree on and to trade locale) in their study. Based on the crime script, the authors also provided suggestions for prevention, such as increasing surveillance (e.g. in person or CCTV) which may make solicitation and the exchange more difficult.

Turning towards online drug trafficking, Lavorgna (2014) utilised crime script analysis to examine how the internet mediates drug trafficking. Instead of developing a crime script from the data, they mapped the offender’s actions on the internet onto an existing script. Ten major types of criminal opportunities facilitated by the internet were identified including communicative, informational, technological and organisational opportunities. Although this study provided new insights into the impacts of the internet on drug trafficking, it did not contribute any knowledge of offenders’ actions offline specifically. The crime script takes a broad approach with a combination of actions of suppliers, intermediaries and buyers on various levels of the internet (i.e. dark net, surface web). Although crime scripts are beneficial when developed to inform situational crime prevention measures, this study did not include any recommendations based on the script.

Recently, Jardine (2021) developed a crime script of dark net drug markets using existing literature as data. The study presented a generic crime script from learning about the dark net to receiving the illicit drugs in the mail and the range of known police operations and procedures at each stage of the script. The four stages identified were informational accumulation, account formation, market exchange and delivery/receipt stages. Although this study was the first to utilise crime script analysis to examine the actions of buyers and sellers on the dark net, a large focus was placed on the online actions of these offenders. This is unquestionably necessary for this type of offending, however given the complexity of illicit drug supply chains more attention is required for to the offline actions related to the same drug trafficking activities. The generic script developed by Jardine (2021) has provided new insights into actors on the dark net, but empirical-based crime scripts are arguably more suitable as a framework for thinking about the development of specific crime prevention techniques or interventions.

These three studies provided new and unique perspectives onto drug trafficking, making them a useful starting point for crime analysis research on drug trafficking facilitated by the internet. This study builds on these previous works by studying drug importation facilitated by the dark net. It will provide new insights into the whole crime commission process (online and offline) and specific crime prevention measures based on the script.

The current study

The current study addresses an important gap in the literature on understanding the crime commission process of drug importation facilitated by the dark net by applying crime script analysis. The first aim is to develop a crime script of drug importation into Australia facilitated by the dark net. Previous studies have examined the characteristics of markets and some aspects of the crime commission process and decision-making in purchasing drugs from the dark net. However, there is a lack of empirical evidence on the entire sequence of steps related to drug importation facilitated by these markets. Similarly, Jardine (2021) introduces the use of crime scripts to map the actions of offenders on the dark net but had a different methodology, aims and results. Along with these differences, this study will contribute to the current knowledge on both online and offline steps of the crime commission process. The second aim of this study is to stimulate thinking of crime prevention measures based on the crime script. Although Cornish (1994) suggests the use of crime scripts to create situational prevention strategies to address criminal activities, very few studies have been completed with this goal in mind (e.g. Chiu et al., 2011). In addition, general strategies for crime prevention have been broadly suggested in the literature on dark net drug markets, but there is a lack of specific recommendations to reduce drug importation in both the online and offline environment. Through a content analysis of sentencing remarks of Australian court cases, this paper will bring a complementary perspective to the understanding of the crime commission process for this type of crime and discuss potential measures to reduce drug importation into Australia through the dark net.

Procedure

The current study used court transcripts to develop a crime script for drug importation into Australia through the dark net. A major advantage of using court data is the basis on multiple sources of evidence, reducing the need for triangulation of data recommended in qualitative research (Porter, 2008). Moreover, the information in this type of archival data is also based on evidence accepted under legal scrutiny (Porter, 2008). It is also easily accessible as it is online and available to the public allowing for more efficient data collection (Lune & Berg, 2017). This also minimises ethical issues, although care needs to be taken in ensuring anonymity and confidentiality (Lune & Berg, 2017; Porter, 2008). The narrative nature of sentencing remarks of court cases is also beneficial for the development of crime scripts (Porter, 2008). However, a major limitation of using court cases is that they only contain the actions and decisions of those who have been convicted. Although this limits the representativeness of offenders’ behaviours informing the crime script (Porter, 2008) the presence of interrupted crime events can be useful in the development of crime scripts as it allows identification of weak spots in the script presenting potential points for crime prevention (Cornish, 1994). The information in the court cases may also be incomplete and recorded incorrectly as the main purpose of this type of data is not for research (Lune & Berg, 2017; Porter, 2008). Though this limitation is minimised in this research by compiling the information of each case into one script, where minor inaccuracies and gaps are filled by the information of other cases in the sample. Although limitations for using court transcripts exist, these can be managed and are outweighed by the advantages indicated above. In addition, it has been used in various crime script studies (Chiu & Leclerc, 2016; Chiu et al., 2011).

This study followed the data collection methodology used in earlier studies using court transcripts (e.g. Chiu & Leclerc, 2016; Chiu et al., 2011). Data collection was conducted between March and June 2021. The court cases were found through the case law databases in the Australian Legal Information Institute (Austlii). Through a Boolean search operator, combinations of the terms ‘dark web’, ‘dark net’ and ‘darknet’ with ‘border controlled drug’, ‘drug import’ and ‘traffick*’ were used (see Figure 1). The search words were matched to free texts which resulted in 87 Australian court cases. These were collated, and duplicates were identified and then removed. The full text of 41 cases were examined and manually eliminated. Reasons for exclusion were being irrelevant to the study, lacking information to determine inclusion in the sample and lack of information on the offenders’ actions which is essential for developing a crime script. This process resulted in 20 cases which included two transcripts on the same crime event. Due to the high number of duplicates and no conflicting information in the data, it was determined that saturation was reached. Therefore, the final sample used in this study consisted of 18 court cases in which offenders imported illicit drugs into Australia purchased through the dark net (see Appendix). These cases were from various levels of courts around Australia, ranging from years 2016 to 2021. No further parameters to the dates of court cases were used due to the limited number of court cases for this type of crime. Ethics approval was also obtained through the university ethics office prior data collection and analysis.

Figure 1. Data collection flow diagram.

Data analytic strategy

Following data collection, the sentencing transcripts were analysed through a qualitative content analysis using the similar methodology as Chiu and her colleagues (Chiu et al., 2011; Chiu & Leclerc, 2017). The crime script was developed through a series of steps discussed below and illustrated in Figure 2.

Figure 2. Crime script development process.

Firstly, areas of interest (variables/elements of offending) in the development of crime script were identified using existing literature, prior crime scripts and scanning the cases. Areas of interest used were drug type, drug country of origin, dark net market, packaging, receiving location, storage, reason for importation, online and offline tools, and other facilitators. These areas of interest were identified to assist in the following stages of the development of crime script.

Secondly, each case was summarised through four sub-steps. The first sub-step involved familiarisation with the cases. The second sub-step was summarisation of each case according to the areas of interest. Each case was summarised according to the areas of interest identified in the first step of analysis, which included information such as drug type, location of delivery, packaging, and other facilitators to completing the offence. This was followed the third sub-step, listing the sequence of events in dot points. In sub-step four, a ‘mini script’ was developed for each case. To do this, information about actors, resources and decisions at each step of the crime commission was compiled for each case. These four sub-steps were completed to consolidating the data to make the development of the script easier.

Thirdly, using Microsoft Excel, a matrix of the various elements of the offending was summarised across all cases. The matrix consisted of the categories identified earlier alongside each of the cases (i.e. single matrix for all 18 cases). For example, the category of packaging of drugs consisted of two levels (letters and packages) which were tabulated for each case. Based on the matrix, the number and percentages of cases which contained each category and level were calculated to gain an understanding of patterns within the data.

Fourthly, all information from previous steps were combined qualitatively and quantitatively to develop the final crime script. The ‘mini scripts’ were used to develop the script steps, and the information from the matrix was used for supporting information and smaller details of the script.

Finally, the crime script was refined through numerous revisions. This involved the development, removal and modification of various steps to best represent the actions of offenders. The final crime script consisted of five main script steps and three script tracks.

Results

The following section presents the crime script for drug importation facilitated by the dark net, which covers the step-by-step process for this crime in detail (see Figure 3). The script consists of five steps leading to three script tracks (or script variations), specified based on the purpose of importation.

Figure 3. Crime script of drug importation facilitated by the dark net.

Preparation

The first necessary steps taken by offenders to access the markets on the dark net included downloading the TOR web browser and obtaining a cryptocurrency. Many offenders downloaded the TOR web browser (n = 6) onto a laptop (n = 8), however some used a mobile phone to access the dark net (n = 6). Bitcoins were the only cryptocurrency (n = 11) identified to be used to pay for the products. Bitcoins were generally obtained by offender themselves or in one case were given to an offender by an associate of the organised crime group. The money was first entered into a regular bank account (online or in one case through an ATM) then exchanged into Bitcoins and kept in cryptocurrency wallets.

The additional actions adopted by some offenders involved the use of two types of extra security measures. The first involved obtaining false identification documents for use during later steps of the script (n = 2). Although the specific methods of procurement of false identification were unclear, in one case offenders produced their own fake driver licences, as evidenced by paraphernalia to make these and books advising how to do so. The second extra security measure utilised by some offenders (n = 4) was opening post office boxes for receiving drugs later in the script. These boxes were used in four cases with all offenders opening more than one (one case with two boxes, two cases with three boxes and one case with 25 boxes). Whether these were opened under real or fictious names was not reported.

Access

The most common device used to access the dark net was a laptop, although some used a phone, as evidenced by the downloaded browsers on these devices. Once on the dark net, offenders purchased the drugs from various cryptomarkets. Some (n = 3) used one market only (one case used Alphabay and two cases used Dream Market), while others (n = 3) used more than one cryptomarket (one case used Black Market Rebooted and Sheep, one case used Alphabay and Dream Market, and one case used unspecified markets).

Purchasing

Offenders purchased a variety of illicit drugs, but MDMA was most common (n = 13), followed by cocaine (n = 9) and methamphetamine (n = 6). MDMA was the drug contained in the greatest number of parcels (n = 27). Moreover, most offenders (n = 14) bought more than one drug type. The average number was around two drug types.

Locations of vendors from whom offenders purchased from varied depending on the drug type, but the most common country of origin was the Netherlands (n = 6) followed by other European countries, such as Germany (n = 2) and Belgium (n = 2). There may also be a preference for purchasing from known vendors, as evidenced by the lists of vendors found in the possession of some offenders (n = 2).

The two main forms of packaging of the illicit drugs used were envelopes and parcels. Multiple layers of packaging, such as cardboard sleeves and heat-sealed packaging, were often used to conceal the drugs to avoid detection. Further concealments such as the use of protein sachets and DVD cases for extra security precaution reasons were also identified in some cases.

Receiving the drugs

Various locations were used by offenders to receive the drugs. The most common was residential properties (n = 11), which mainly consisted of the offenders’ residence (some also utilised their parents’ residence). Offenders used both real (n = 6) and fictitious names (n = 4) for deliveries. While most preferred to use one or the other, in one case they were used interchangeably. Previously acquired post office boxes were the second most used delivery location. As discussed above, offenders tended to utilise more than one post office box to receive drugs. A minority of offenders (n = 2) also used vacant addresses, one of which was across the road from the offender’s workplace. Those who did not order their illicit drugs from the intended storage place were further required to organise the transport for the drugs and collect the packages from various locations. Packages were collected and taken to the storage location by motor vehicles.

Storage

The offenders’ residence was the primary storage location used (n = 8), regardless of the place where it was received initially. The drugs were often found with other supporting materials, such as records of purchases and items required for organising transactions (i.e. measuring scale, small plastic bags and postage materials). Security measures were taken by some offenders (n = 2) including CCTV to monitor any activity occurring outside of the storage location as well as a safe to store the illicit drugs. Two cases showing a high level of planning and social networks utilised several locations, including a safe house and office space, presumably due to the risks associated with the use of a personal residence.

Script tracks

Once in possession of the drugs, offenders adopted one of the following three script tracks: selling on the dark net, selling offline or personal use. In most cases (n = 16), the illicit drugs were sold by offenders (either online or offline), with many also using the drugs for personal use. Few offenders imported the illicit drugs solely for their own personal use.

Some offenders (n = 4) were found to distribute their imported illicit drugs on the dark net domestically. For this track, offenders firstly set up an online account, chose a name and listed items for sale. At this point of the track, the customers would purchase the drugs through the dark net. Once drugs were purchased, the offender packaged the product as evidenced by postage materials and postage tracking numbers. In addition, some offenders used concealments, such as toys, as a security measure to avoid detection. The packages were then sent through postal services. The benefit was monetary gain in the form of Bitcoins. Profits could then be used to purchase more drugs on the dark net or exchanged back to the original currency.

Most (n = 8) of the drugs, however, were distributed offline in a more traditional manner to acquaintances of offenders. Contact was initiated by both the offender who imported the illicit drugs and the customer through mobile text messaging or secure encrypted phone applications. It is assumed that individuals were known to each other since there was no indication of making acquaintance. Offenders then met with the buyer in person to proceed with the transaction. Unlike those selling on the dark net, offenders who sold the drugs offline were able to use the money instantly, without the need to exchange it. Additionally, some offenders also sold the drugs to clear debts with members of organised crime groups.

The last purpose for drug importation was personal use (n = 13). Few offenders (n = 2) purchased drugs purely for their own personal use. MDMA was purchased the most by those who did not sell the drugs, although most cases (n = 11) involved offenders who ordered the drugs for both personal use and to resell it either online or offline.

Other important elements of the crime script

Additional elements that impacted the execution of the crime script but were not considered a step of the script were also identified. The first is the activity of repurchasing of drugs (illustrated by the arrows going upwards in Figure 3). Except for one, all offenders made more than one purchase. Excluding a case with 137 purchases, the average number of purchases was about four. These repurchases were not necessarily started only once the crime script was executed for the first time but also when the items were seized by the Australian Border Force and not delivered. This further suggests the seizure of items on one occasion did not deter offenders from further criminal activities and was often followed by a repurchase. In addition, those repurchasing drugs did not necessarily start at the beginning of the crime script again since many of the preparation steps had previously been completed (e.g. obtaining the TOR Browser and Bitcoins).

Most offenders (n = 12) imported the drugs without any assistance from other offenders. However, one-third of cases had more than one person involved in the execution of the crime script. Most of these cases (n = 5) involved two offenders. Many working together had close relationships, such as a romantic relationship or friendship as opposed to a purely business relationship. Although these networks were small, they arguably had an impact on the execution of the crime script in three ways: scale of operation, greater security measures and division of the execution of crime script steps amongst members. In cases involving more than one offender the number of purchases was higher and the types of drugs more varied and purchased a wider variety of drug types. Groups were more likely to take security measures, such as using post office boxes and storage locations other than their own residence. One case also used a third-party remailing centre (who received the packages from the dark net vendors and divided the product into multiple smaller packages to be sent to the buyer from less suspicious locations) to decrease the likelihood of detection at the border. The involvement of several offenders was most common during distribution, which was often the only step where other offenders were involved in the script. This was most evident in groups with a hierarchical structure where those who distributed the drugs (offline) were subordinates to those purchasing them. The delegation of tasks also frequently occurred based on the expertise of offenders (i.e. ability to use the dark net).

Discussion

The two aims of this study were to: 1) identify and understand the process of drug importation through the dark net using crime script analysis and 2) use the crime script to stimulate thinking of potential crime prevention measures. This discussion will first review some key points of the results in relation to the current literature. This will be followed by looking at potential crime prevention measures relevant to each step of the crime script to demonstrate how crime scripts might inform prevention.

To our knowledge, the most relevant study, for comparison purposes with the crime script developed in this study, was conducted by Jardine (2021). Overall, the two scripts are non-contradictory and each contributes to the literature in different ways. One of the notable differences is that the crime script developed in this study had a considerable proportion dedicated to the offline steps. The offline aspects of the script revealed the greatest variation in decisions made by offenders at different steps of the script. While some steps of the crime script are shaped by outside influences (i.e. market administrators), it is these offline steps where offenders have more agency over their actions, which demonstrate individual differences in managing the risks and benefits of engaging in these activities. Indeed, cryptomarkets are structurally alike with similar processes of purchasing which allows little room for individual decision-making, as illustrated by the crime script (Martin, 2014a). The different options taken by offenders highlight the necessity of studying all components of the purchasing process and not simply the online environment the transactions are occurring within. This is particularly relevant for drug markets which always continue to occur partly in the offline environment. These offline elements are also important to understand as prevention measures may be applied more easily by individual countries in comparison to online.

A well-established section of the crime script was the anonymising tools used by offenders during the crime script, the TOR browser and Bitcoins. No other browser or cryptocurrency was used, demonstrating the strength of this component of the crime script. However, these technologies are required to engage in transactions on cryptomarkets (Martin, 2014a). While these two innovations have arguably contributed to the growth of these markets and remain popular, developments of new, and possibly improved, dark net networks and cryptocurrencies may change the use of these in the future (Afilipoaie & Shortis, 2015; Soska & Christin, 2015). This provides an interesting example of how the market has influence on offender behaviour. For example, although other cryptocurrencies exist which may provide greater anonymity (and are thus a more rational choice), it is not up to the offender to make the decision but the market administrators.

How to access and purchase drugs are frequently researched as studies often centre around the markets. Purchasing from multiple cryptomarkets may indicate the buyers’ decision to ‘shop around’ for the best deal or demonstrate the flexibility of buyers, a trait required for engaging with these volatile markets (Décary-Hétu & Giommoni, 2017; Van Hout & Bingham, 2013). This is one of the key points of improved decision-making provided to buyers in the purchasing process on dark net markets in comparison to offline (Childs et al., 2020). Although these options are available, some preferred to continue purchasing from known vendors, possibly to mitigate risks. This is supported by research suggesting offenders are more likely to repurchase from the same vendors as opposed to seeking new ones due to the challenges of building trust online (Décary-Hétu & Giommoni, 2017).

The receiving and storage steps had some differences which can be attributed to individual decision-making. Offenders making smaller purchases received deliveries and stored products using residential addresses. Those in larger, more complex networks were more likely to use post office boxes (or other locations) to receive items and use locations such as a safe house or office space to store their products. In addition, those with a higher chance of being detected (i.e. those with a greater number of purchases) implemented various security measures for preventing detection in comparison to those with less purchases opting for deliveries to be made to their residence. In the dark net community, it is generally assumed that small amounts can be delivered to residences, while organised crime groups utilise greater actions (Afilipoaie & Shortis, 2015; Desroches, 2007). This difference supports the idea that offenders are rational decision makers and those who are taking greater risks are also taking further steps to mitigate these risks. Though it should be noted that this difference in risk management could also be explained by the idea that offenders who are being more rational about the benefits and risks of these activities are taking other additional security measures and have not been detected or convicted.

The script tracks, developed based on the benefits of importation, provided new knowledge about how drugs are sourced for personal use, and for resale on the dark net and offline. The tracks indicate the end goal of using the drugs and monetary gain, as well as how these motivations impact the crime script. A proportion of drugs was imported solely for personal use, indicating that despite the perceived risks of importing, the benefits provided are significant for offenders to accept these risks. While it is known that purchases are made on the dark net, Australian dark net participants are known to majorly engage in the domestic market (Cunliffe et al., 2017; Van Buskirk, Naicker, et al., 2016). Indeed, the risks of importing the drugs for personal use may not outweigh the benefits of afforded with purchasing from overseas vendors. This is somewhat reflected in the results as small portion of products imported solely for personal use, while many were imported for reselling either online or offline. However, this difference may be due to the use of court transcripts and the focus of law enforcement on larger or more frequent transactions. This crime script demonstrates one of the possible ways drugs are sources for the Australian drug market. Although greater risks exist with importing drugs, the benefits such as the low cost of the drugs and possibility of making money are likely a motivator (Cunliffe et al., 2017; Munksgaard & Martin, 2020). Most selling activities occurred through traditional methods offline as opposed to the dark net. This, importantly, demonstrates the impact of the dark net on those who engage with these anonymous markets but also other drug users who may have never accessed the dark net. This can have significant impacts on the drug markets overall. A small proportion of offenders resold the drugs on the dark net. It is well known in the literature that Australian vendors are overrepresented in cryptomarkets and generally only ship domestically, though little is known about how these vendors operate (Cunliffe et al., 2017; Martin et al., 2018; Van Buskirk, Naicker, et al., 2016). This provides an insight into the possible ways Australian dark net vendors source their drugs. This sourcing method may have benefits such as easy sourcing strategy and large profits (Cunliffe et al., 2017).

The crime script also provided new insights on two aspects specifically: repurchasing and social network. Repurchasing was a reoccurring theme element in the crime script. This occurred, in cases when the deliveries arrived and, more concerningly, when deliveries were seized and did not arrive. Those who received their deliveries were then able to complete the script and subsequently purchase more products. This assumes that offenders in this circumstance were satisfied with the items they received to re-engage with the dark net markets. Offenders who did not receive their deliveries but continued to make purchases demonstrate the ineffectiveness of seizures on buyers’ behaviour. This is supported by previous research suggesting that overseas vendors shipping to Australia despite the risks associated with this (Cunliffe et al., 2017). This provides an interesting insight into the risk and benefit calculation of offenders, as it may be presumed that those having items seized do not believe the risks are significant enough to stop them from purchasing again. This demonstrates the importance of considering other ways in which this type of offending can be reduced.

Regarding social networks, the script suggests there is some involvement of co-offenders, particularly of smaller groups. The crime script indicates some involvement of social networks in the execution of the crime script. By distributing tasks according to the strengths and expertise of individuals (e.g. technical skills), the success of the crime script may be improved. As a result, the likelihood of successfully completing the script is improved and the difficulty of detection of offenders and prevention increased. In addition, the emergence of smaller groups could indicate that the dark net arguably can provide new avenues for sourcing products for smaller groups of offenders. These smaller groups may require cryptomarkets to establish connections with producers and sellers, which established organised groups already have. Thus, the dark net arguably could create opportunities for more offenders to undertake drug trafficking activities.

Implications for prevention

An important objective of crime scripts is to assist with the development of crime prevention measures (Cornish, 1994). Although police have shutdown cryptomarkets and convicted offenders previously, this generally only has short-term impacts on illicit activities and in some instances has the opposite effect, where popularity of these markets grow (Décary-Hétu et al., 2016; Ladegaard, 2018; Soska & Christin, 2015; Van Buskirk et al., 2017). This demonstrates the need for more effective and efficient crime prevention measures. By utilising a crime script framework, it is possible to identify areas of the crime commission process where crime prevention measures may be created and implemented.

The purpose of this section is to demonstrate the ways in which various strategies could be suggested and is not a comprehensive discussion of the crime prevention measures. Indeed, one of the limitations of using court data may be the limited discovery of new prevention interventions. Thus, most of the prevention measures may not be unique to this crime script or have been studied or developed by other researchers in this area. Nonetheless, by examining the potential of measures studied by other researchers, this study can add empirical evidence to the relevance of these measures and supports the current body of literature to implement these strategies. An overview of the suggested prevention measures is presented in Table 1.

Table 1. Crime script and potential prevention points for drug importation on the dark net.

Script Steps	Crime Prevention Measures
Preparation	Regulation of cryptocurrency transactions Improve detection capability through education Removing information about obtaining and using Bitcoins Tightening regulation of opening post office box (to prevent multiple post office boxes and use of false identification)
Access	Warning signs when accessing the dark net Removing information about dark net sites on clear web
Purchasing	Disrupt markets
Receiving	Strengthen border control through use of intelligence obtained from dark net forums Encourage post office and couriers of suspicious parcels and locations such as abandoned addresses
Storage	Greater background checks for rental properties
Dark net distribution	Disruption of markets ‘Knock and talk’ operations Use of identification when sending packages Restrictions on use of post boxes Requirements of return sender
Face to face distribution	Guardianship of locations where illicit drugs are sold
Personal Use	Education on risks of illicit drugs purchased from cryptomarkets Promote safe use Provide resources to treat addictions

The preparation step allows for points of intervention which may prevent offenders from obtaining the cryptocurrency or opening post office boxes. First, once the money is exchanged into cryptocurrencies (i.e. Bitcoin), it is more difficult to track the transaction. Therefore, the crime script could be used for informing financial institutions of how offenders operate and improve detection of illicit activities such as depositing large amounts of money into a bank account over a short period of time across multiple ATMs. Moreover, the crime script could be used as an educational tool to demonstrate the importance of this type of work to those working in this area in financial institutions. Greater regulations and verification of identity for setting up a cryptocurrency trading account, which currently depends on the exchange market, could assist law enforcement investigations (Afilipoaie & Shortis, 2015). Another strategy may be to limit the access to information available about Bitcoin, and cryptocurrencies more generally, on the clear and dark net. As knowledge about this is often learned in online environments, the removal of information about how to obtain and use Bitcoin to make purchases on the dark net may be an effective strategy (Jardine, 2021). This would require the collaboration of various government agencies and organisations such as law enforcement and international policing organisations globally. Second, stricter regulations to prevent offenders from opening post office boxes by increasing their risk of being exposed and identified could be implemented. Identities could perhaps be verified through authentication with other government departments responsible for personal identification, such as passports and driver licences, to prevent the use of illegitimate identification documents. All offenders who utilised post office boxes opened more than one, which also provides an important avenue for prevention. A limit to the use of only one post office box per individual, unless legitimate reasons can be provided, could be implemented.

Taking down an infrastructure such as the TOR networks to prevent offending (such as drug importation) is not realistic as it may also affect those who are accessing the dark net for legal activities, such as participating in forums anonymously (Hutchings & Holt, 2017). In addition, removal of such infrastructure in practice may consequentially result in new and additional dark net networks, similarly to the dispersal of cryptomarkets experienced following the shutdown of Silk Road (Martin, 2014a; Soska & Christin, 2015). A potential avenue for prevention, like the prevention for obtaining Bitcoin, is controlling the information on accessing dark net sites. To access the dark net sites, the individual must know the exact site address, unlike on the surface web where search engines can be used (Jardine, 2021). Therefore, by removing this type of information on the clear web could help reduce the offenders’ ability to access illegal sites. Another prevention measure could involve automated warning signs alerting the individuals of potentially illegal activities they may encounter on the dark net when downloading the browser and the risks of engaging in these activities. This strategy has previously been found effective for deterring access to child sexual exploitation material (Prichard et al., 2022).

For the prevention measures regarding the purchasing step of the crime script, some researchers suggest the infiltration by law enforcement to disrupt the operations of cryptomarkets instead of law enforcement simply closing cryptomarkets. One specific method is ‘lemonising the market’ or creating distrust among vendors and buyers through Sybil and slander attacks (Hutchings & Holt, 2017). Applied to drug importation, this could increase the efforts required by vendors to sell products thus indirectly decreasing the profits made from sales. For buyers, this measure could create difficulties identifying authentic vendors, increasing the effort to make a purchase (Hutchings & Holt, 2017). Distrust may also be created through participating in forums as fictious actors and posting fictious claims, questioning reputation of vendors and providing false information (Hutchings & Holt, 2017). False information may include posting tutorials about packaging for importing illicit drugs, which in fact makes detection at the border easier and more likely due to their distinctive appearance (Hutchings & Holt, 2017). Another potential measure is increasing the perceived risk of making purchases by providing true information on forum platforms about law enforcement arrests including publicity of arrests and prosecutions of offenders (Hutchings & Holt, 2017).

The Australian Border Force arguably remains the first line of defence for the prevention of illicit drugs coming into Australia (Martin, 2014a). Examination of packages could be improved through education on the latest stealth techniques disclosed by offenders on dark net forums especially since relying on border control has arguably been ineffective in reducing offending to date. The detection of illicit drugs could also be enhanced by including the postal delivery personnel. Personnel, arguably have more contextual information around the location of the parcel (e.g. parcel addressed to an abandoned property), which could be beneficial for the detection of offenders. Thus, the crime script could be utilised to educate delivery personnel on the growing use of postal services to traffic drugs, how they are packaged, how to identify suspicious delivery locations and report suspicious items.

The location used for the storage of the imported drugs mainly centre around those offending in groups as those were more risk averse and conducted activities outside of their residential address. Prevention may involve greater guardianship through education of the public and storage companies around the use of storage spaces and safe houses. Offenders who utilised storage places and safe houses also used false identification to rent the spaces. Therefore, conducting greater renter background checks may help prevent offenders from being able to obtain storage spaces without valid reasons.

Many previously discussed potential prevention points could also apply to offenders selling drugs on the dark net (disrupting markets), but there are some additional vendor-specific intervention points. An intervention, relevant for sellers are ‘knock and talk’ operations whereby sellers are contacted in relation to their activities in these markets (Jardine, 2021). Similarly, Howell et al. (2022) found credible sources sending warning messages about potential scams to be effective in reducing market participation. However, the point where prevention may be most effective offline, by increasing the risk of vendors being identified while sending drugs through postal services. This could involve increasing the requirements of providing personal identification and a legitimate return address when sending items. In addition, restrictions on the use of post boxes to letters only to ensure parcels are sent through the post office could be effective. Increasing the use of CCTV around post boxes could also deter some offenders by increasing their risk of identification when sending items. There is also potential for greater monitoring of letters and parcels sent domestically, in a similar fashion to international parcels. Though this type of inspection would require the allocation of a considerable number of resources to ensure the delivery times of all parcels were not impacted (Afilipoaie & Shortis, 2015). However, the increasing role of postal services, in the domestic dark net market and drug trafficking more generally, may make the investment worthwhile (Cunliffe et al., 2017).

With the current data, little can be suggested for the prevention of face-to-face transactions due to the limited information found in this study about specific locations in which these were occurring. Prevention measures may best be implemented when the transactions of the illicit drugs are taking place, that is, when the drugs are exchanged for money. Jacques and Bernasco (2014) recommended, in relation to drug selling in public places, increased surveillance (either in person or CCTV) in public spaces to ensure greater visibility of transactions to increase risk for the offenders. This may also involve educating those working in and around public spaces (e.g. place managers) about offender behaviours and how to report them.

The prevention measures proposed to address personal use related to a harm reduction approach. Some argue that the dark net already facilitates this approach through its forums promoting the safe use of drugs (Bancroft, 2017). As offenders are likely to receive information about drug use through these forums, it could be beneficial to provide access to these resources in these forums as well. An example of this is a thread by Caudevilla (2016) on various cryptomarkets forums named ‘Ask a drug expert physician about drugs and health’, which has been well received by these communities. This ‘virtual outreach’ technique may not be as effective as a face-to-face approach, but it could provide information to those uncomfortable accessing traditional healthcare services or who do not have easy access to such services (Caudevilla, 2016). Moreover, greater education around the use of the dark net to purchase illicit drugs could be implemented. Again, these could be achieved through online methods and involve campaigns providing information about potential health and legal consequences.

It is important to consider possible innovations of the market and unintended consequences of these potential prevention measures (Aldridge et al., 2018). A prime example being the law enforcements’ shutdown of Silk Road, which resulted in the emergence of multiple smaller markets, making future law enforcement investigations more difficult (Martin, 2014a). Prior to use of these measures, it is critical to understand the potential displacement effects as well. Another consideration in the implementation is the need for more effective collaboration between stakeholders. Many of the crime prevention measures suggested in this section require the cooperation of multiple agencies and organisations. This should include law enforcement agencies globally, key industries, such as information technology, and financial institutions, as well as the research community.

Limitations

While utilising court documents to produce a crime script has provided unique insights into the crime commission process, there are some limitations originating from this data. First, the crime script may not be representative of the strategies and actions of offenders who have evaded law enforcement. Given these documents focus on the actions of convicted offenders, it is not possible to be certain that this crime script is illustrative of all offenders. Furthermore, it is important to note how individuals are detected and subsequently investigated by law enforcement. To illustrate, individual packages, particularly of small quantities, may not be of concern to law enforcement and consequently only the significant drug importation offenders will be deemed worth investigating which may explain the high number of repetitive purchases found in this study (Horne et al., 2015).

Second, sentencing transcripts are not produced for crime scripting purposes which is evident in the lack of detail in some steps. This was particularly apparent in the actions of offenders online even though this may not have had a large effect as comparisons with the crime script by Jardine (2021) supported the findings. This limitation could be addressed in future research through using primary data such as interviews, collected with the purpose of developing a crime script and allowing the researcher flexibility to further inquire into specific aspects of the crime script.

Third, the limited sample size also may have implications for the quality of the crime script. Some aspects of the crime script were brief, evidentially in the script tracks which had fewer cases informing their development. Though it should be noted, steps in the reselling on the dark net track were also similar to those identified previously (Jardine, 2021). The lack of information has further implications for the crime prevention measures developed since they are mapped onto this crime script. Therefore, the suggested measures are preliminary and require further empirical research.

Conclusion

In this study, a crime script of drug importation facilitated by the dark net was developed. It deepens the current knowledge on how buyers operate on the dark net and was the first to examine this type of offending in the Australian context. Moreover, the investigation of the entire crime commission of buyers on the dark net had not been investigated in-depth previously, with much of the research in this area concerning only certain aspects of offending, such as decision-making about purchases. Importantly, this study provided details into the actions of offenders both online and offline which has not been discussed in length in previous research. This study contributes new and complementary information about this crime commission process.

Australia sets a unique context for the investigation of dark net purchases due to the strict border controls and large number of domestic dark net transactions. Though this study focused solely on buyers, it has provided an overview into the actions of offenders. As well as contributing to the current literature, this crime script is informative for law enforcement agencies as well as other relevant organisations affected by this phenomenon (such as the banking and technology industries) for future investigations of this type of offending. Furthermore, this study demonstrates how crime scripts can be used to create more specific and informed crime prevention strategies at different points of the offending to counter these resilient and adaptable cryptomarkets, which should become a focal point in future research.

There are a few possible avenues for future research. The first, and possibly most obvious, is the use of other sources of data for the script development which may be more suited to the development of this type of tool. Though the ideal data for future research would occur through interviews (e.g. Leclerc, 2017), a more realistic data source may be dark net forums which have been used for crime script development of dark net actors previously (e.g. Holt & Lee, 2020). The second potential area of research is an expansion to the use of crime scripts to map offending of other dark net market actors such as administrators for generating insights into operations. Third, further studies could examine different geographical contexts in which this type of offending occurs. Importation into Australia is a unique example due to the country’s heavy investment in border control and strong domestic market in comparison to other countries throughout the world. Thus, other countries with differing border controls and drug markets may find different crime scripts which may also have different implications for law enforcement. Finally, the prevention measures discussed are currently hypothetical and require future research to support their use or efficiency. As the use of the dark net for trafficking of illicit drugs around the world continues to grow, there is an urgent need for developing effective prevention measures. To conclude, it is hoped the findings of this study will contribute to and encourage further research into understanding trafficking of illicit drugs through the dark net and innovative crime prevention measures to address the challenges faced by law enforcement agencies globally.

Disclosure statement

No potential conflict of interest was reported by the authors.

Appendix

List of case numbers used in analysis

R v Collopy; R v Cooley [2017] SASCFC 64

R v Ye [2016] SASCFC 82

R v Woods [2019] NSWDC 401; Woods v R [2020] NSWCCA 219 (28 August 2020)

R v Grey [2020] QCA 77

R v Sagnelli [2020] ACTSC 348

DPP v Ragauskas [2016] VCC 1232

Allami v DPP (Cth) [2021] VSCA 42; DPP v Allami [2020] VCC 1114

DPP v Evers [2017] VCC 1226

DPP v Kerovec [2018] VCC 382

R v Smith [2019] ACTSC 196

DPP (Cth) v Frendo [2019] VCC 1548

DPP v Watkins & Anor [2020] VCC 25

R v Azabal [2019] NSWDC 523

R v AA [2021] NSWDC 112

Baker v The Queen [2020] ACTCA 55

Gallagher v The State of Western Australia [2019] WASCA

Edmonds v The Queen [2019] NTCCA 1

DPP v Hough [2020] VCC 1534