(2) Standard of review
 This court has held that the standard of review of a decision concerning a fine in lieu of forfeiture is the usual one applicable to all sentence appeals. In R. v. Angelis (2016), 133 O.R.
(3d) 575,  O.J. No. 4735, 2016 ONCA 675, 340 C.C.C. (3d)
477, at para. 22, leave to appeal to S.C.C. refused 
S.C.C.A. No. 484, it stated:
An order made under s. 462.37, including an order refusing to direct pay-
ment of a fine in lieu of forfeiture under s. 462.37(3), is a “sentence” within
s. 673 of the Criminal Code. As an appeal from sentence, and as a discre-
tionary order, the trial judge’s conclusion is subject to deference in the
absence of an error in principle, a failure to consider a relevant factor, con-
sideration of an irrelevant factor, overemphasis of appropriate factors or a
decision that is plainly unreasonable. Appellate intervention is justified only
where it appears from the trial judge’s decision that an error had an impact
on the result.
(3) Purpose of forfeiture of proceeds of crime
 The purpose of the forfeiture provisions of the Criminal
Code is to deprive the offender of the proceeds of his or her crime
and to deter him or her from committing crimes in the future.
This is different from the general sentencing provisions which
aim to punish an offender for committing a particular offence.
In R. v. Lavigne,  1 S.C.R. 392,  S.C.J. No. 10, 2006
SCC 10, at para. 16, Deschamps J. stated:
Parliament’s intention in enacting the forfeiture provisions was to give
teeth to the general sentencing provisions. While the purpose of the latter
provisions is to punish an offender for committing a particular offence, the
objective of forfeiture is rather to deprive the offender and the criminal
organization of the proceeds of their crime and to deter them from commit-
ting crimes in the future. The severity and broad scope of the provisions
suggest that Parliament is seeking to avert crime by showing that the
proceeds of crime themselves, or the equivalent thereof, may be forfeited.
 Where the property itself is no longer available for forfeiture, the court has a limited discretion to refuse to order a fine
in lieu of forfeiture under s. 462.37(3) of the Code. Deschamps J.
stated, at paras. 27 and 32 of Lavigne:
The effect of the word “may” cannot therefore be to grant a broad discre-
tion. The exercise of the discretion is necessarily limited by the objective of
the provision, the nature of the order and the circumstances in which the
order is made.
. . . . .
The mere fact that the property has been used cannot therefore justify
exercising the discretion to reduce the amount of the fine, especially where