EASTERN DISTRICT OF NEW YORK

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UNITED STATES OF AMERICA

 - against -

THE GOLDMAN SACHS GROUP, INC.,

 Defendant.

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Payment of Monetary Penalty

7. The Offices and the Company agree that application of the Sentencing Guidelines

to determine the applicable fine range yields the following analysis:

a. The 2018 USSG are applicable to this matter.

b. Offense Level. Based upon USSG § 2C1.1, the total offense level is 48, calculated

as follows:

(a)(2) Base Offense Level 12

(b)(l) Multiple Bribes +2

(b)(2) Value of benefit received more than $550,000,000 +30

(b)(3) High-Level Official Involved +4

TOTAL 48

c. Base Fine. Based upon USSG § 8C2.4(a)(3), the base fine is $1,607,700,000 (value

of the unlawful payments, pursuant to § 2C1.1(d)(1)).

d. Culpability Score. Based upon USSG § 8C2.5, the culpability score is 8, calculated

as follows:

(a) Base Culpability Score 5

(b)(1) the organization had 5,000 or more employees and

an individual within high-level personnel of the

organization participated in, condoned, or was

willfully ignorant of the offense +5

(g)(2) Cooperation, Acceptance -2

TOTAL 8

e. Calculation of Fine Range:

Base Fine $1,607,700,000

Multipliers 1.6 (min)/3.2 (max)

 Fine Range $2,572,320,000 to $5,144,640,000