Reposted: A key excerpt from Special Counsel Robert Mueller's recommended sentencing memo for former Trump campaign chairman/convicted felon Paul Manafort Jr.:

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(One background article link: Who is Paul Manafort Jr.?
https://en.wikipedia.org/wiki/Paul_Manafort)
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2/15/19 sentencing memo excerpt. (Footnotes omitted. Emphasis has been added:)

"THE GOVERNMENT’S SENTENCING MEMORANDUM

The United States of America, by and through Special Counsel Robert S. Mueller, III,
files this submission to address the sentencing of defendant Paul J. Manafort, Jr.

As an initial matter, the government agrees with the guidelines analysis in the
Presentence Investigation Report (PSR) and its calculation of the defendant’s Total Offense
Level as 38 with a corresponding range of imprisonment of 235 to 293 months, a fine range of
$50,000 to $24,371,497.74, a term of supervised release of up to five years, restitution in the
amount of $24,815,108.74, and forfeiture in the amount of $4,412,500.

Second, while the government does not take a position as to the specific sentence to be
imposed here, the government sets forth below its assessment of the nature of the offenses and
the characteristics of the defendant under Title 18, United States Code, Section 3553(a).

The defendant stands convicted of the serious crimes of tax fraud, bank fraud, and failing to file a foreign bank account report. Manafort was the lead perpetrator and a direct beneficiary of each offense. And while some of these offenses are commonly prosecuted, there was nothing
ordinary about the millions of dollars involved in the defendant’s crimes, the duration of his criminal conduct, or the sophistication of his schemes. Together with the relevant criminal
conduct, Manafort’s misconduct involved more than $16 million in unreported income resulting
in more than $6 million in federal taxes owed, more than $55 million hidden in foreign bank
accounts, and more than $25 million secured from financial institutions through lies resulting in
a fraud loss of more than $6 million. Manafort committed these crimes over an extended period
of time, from at least 2010 to 2016. His criminal decisions were not momentary or limited in
time; they were routine. And Manafort’s repeated misrepresentations to financial institutions
were brazen, at least some of which were made at a time when he was the subject of significant
national attention.

Neither the Probation Department nor the government is aware of any mitigating factors.
Manafort did not commit these crimes out of necessity or hardship. He was well educated,
professionally successful, and financially well off. He nonetheless cheated the United States
Treasury and the public out of more than $6 million in taxes at a time when he had substantial
resources. Manafort committed bank fraud to supplement his liquidity because his lavish
spending exhausted his substantial cash resources when his overseas income dwindled.
Finally, Manafort pled guilty in September 2018 in the United States District Court for
the District of Columbia to others crimes committed over an even longer period.

The government references those crimes below principally as they pertain to the Section 3553(a)
factors and, in particular, because they demonstrate the defendant’s concerted criminality,
including the conduct to which he pled guilty, from as early as 2005 and continuing up until the defendant’s involvement in an obstruction of justice conspiracy between February 23, 2018 and
April 2018—a crime Manafort committed while under indictment in two jurisdictions and
subject to court-ordered bail conditions in each. The District of Columbia offenses are also
relevant to the application of § 2S1.3(b) of the Sentencing Guidelines to the FBAR offenses
and to the issue of acceptance of responsibility, as discussed below.

In the end, Manafort acted for more than a decade as if he were above the law, and
deprived the federal government and various financial institutions of millions of dollars. The
sentence here should reflect the seriousness of these crimes, and serve to both deter Manafort and others from engaging in such conduct..."

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