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100% agree with your interpretation, the winds of change are a dry scorching heat from the bowels of hell for anyone ignorant enough to think the old methods are fine and ASIC knock on your door.

Perversely ironic not to mention hypocritical that ASIC staff are paid and rewarded for 'volume based' performance i.e. the more heads and scalps they collect, the higher their bonuses.

I recently read an account of how the public 'witch hunters' in the thirteenth century pay structure was changed from a retainer out of the kings purse to a fee per village of 9 pence per witch they found. No surprise the number of discovered 'evil hags' increased a hundredfold, and artifacts have shown that pins with retractable heads were part of their tools (if you didn't bleed when poked you were obviously a witch as proof to the village).

The tricky word play and 'interpretations' are those false pins in ASICs toolkit. If they need your head to make a quota or even if they personally don't like you, it does matter what the facts or regulations are or were, all that matters is what angle they wish to take to remove that odd shaped melon off your shoulders.

And don't forget, they are not there to ascertain facts; they are actively being told and coached not to trust you, to treat you entirely as a criminal and their job is to interrogate you, your staff and your records until they find the crimes that they 'know' are there.