34 Highlights to: UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK - - - - - - - - - - - - - - - - - - - - - - - - - - - - - X UNITED STATES OF AMERICA - against - THE GOLDMAN SACHS GROUP, INC., Defendant. - - - - - - - - - - - - - - - - - - - - - - - - - - - - - X
34 Highlights to: UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK - - - - - - - - - - - - - - - - - - - - - - - - - - - - - X UNITED STATES OF AMERICA - against - THE GOLDMAN SACHS GROUP, INC., Defendant. - - - - - - - - - - - - - - - - - - - - - - - - - - - - - X https://drive.google.com/file/d/1Yx88RMoeLyyfbNK0RtPl4r-m8N21_1Sp/view?usp=d... 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
participants (1)
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Gunnar Larson