Goldman Sachs Asset Management Co., Ltd.

Event Detail: A CRIMINAL INFORMATION WAS FILED ON OCTOBER 22, 2020, IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NEW YORK CHARGING THE GOLDMAN SACHS GROUP, INC. ("GS GROUP") WITH (1) ONE FELONY COUNT OF CONSPIRACY TO VIOLATE THE FOREIGN CORRUPT PRACTICES ACT OF 1977 (THE "FCPA"), TITLE 18, UNITED STATES CODE, SECTION 371 (THE "INFORMATION"), RELATED TO CORPORATE DEBT TRANSACTIONS. GS GROUP WAIVED INDICTMENT AND ANY OBJECTION TO VENUE, AND ACCEPTED AND ACKNOWLEDGED RESPONSIBILITY FOR THE ACTS OF ITS OFFICERS AND EMPLOYEES AS SET FORTH IN THE ACCOMPANYING STATEMENT OF FACTS. A PLEA WAS NOT ENTERED IN RESPECT OF ANY OF THE CHARGES. Status: Pending Disposition: ON OCTOBER 22, 2020, GS GROUP ENTERED INTO A DEFERRED PROSECUTION AGREEMENT ("DPA") WITH THE DEPARTMENT OF JUSTICE AND THE UNITED STATES ATTORNEY'S OFFICE FOR THE EASTERN DISTRICT OF NEW YORK (COLLECTIVELY, THE "OFFICES"). PROSECUTION WAS DEFERRED FOR THREE YEARS FROM THE DATE OF THE DPA. AS PART OF THE DPA, GS GROUP HAS AGREED TO PAY A CRIMINAL MONETARY PENALTY OF $2,315,088,000, $500,000 OF WHICH WILL BE PAID AS A CRIMINAL FINE BY GOLDMAN SACHS (MALAYSIA) SDN. BHD. ("GS MALAYSIA"). Summary: AS DESCRIBED IN THE INFORMATION, FROM 2009 TO 2014, GS GROUP AND ITS AFFILIATES, THROUGH CERTAIN OF ITS EMPLOYEES AND AGENTS, KNOWINGLY AND WILLFULLY CONSPIRED AND AGREED WITH OTHERS TO CORRUPTLY PROVIDE PAYMENTS AND THINGS OF VALUE IN EXCHANGE FOR OBTAINING AND RETAINING BUSINESS. PURSUANT TO THE DPA, GS GROUP HAS AGREED TO, AMONG OTHER THINGS (I) COOPERATE FULLY WITH THE OFFICES AND OTHER DOMESTIC OR FOREIGN LAW ENFORCEMENT AND REGULATORY AUTHORITIES AND AGENCIES, AS WELL AS THE MULTILATERAL DEVELOPMENT BANKS; (II) CONTINUE TO IMPLEMENT A COMPLIANCE AND ETHICS PROGRAM DESIGNED TO PREVENT AND DETECT VIOLATIONS OF THE FCPA AND OTHER APPLICABLE ANTI-CORRUPTION LAWS; (III) REVIEW AND, WHERE NECESSARY AND APPROPRIATE, MODIFY OR MAINTAIN ITS EXISTING INTERNAL ACCOUNTING CONTROLS, POLICIES, AND PROCEDURES REGARDING COMPLIANCE WITH THE FCPA AND OTHER APPLICABLE ANTICORRUPTION LAWS; (IV) REPORT ANNUALLY TO THE OFFICES DURING THE TERM OF THE DPA REGARDING REMEDIATION AND IMPLEMENTATION OF THE COMPLIANCE MEASURES DESCRIBED IN THE DPA; AND (V) PAY A CRIMINAL MONETARY PENALTY OF $2,315,088,000, $500,000 OF WHICH WILL BE PAID AS A CRIMINAL FINE BY GS MALAYSIA.

Allegations: ON SEPTEMBER 25, 2024, THE GOLDMAN SACHS GROUPS, INC. ("GS GROUP") ENTERED INTO AN ORDER INSTITUTING CEASE AND DESIST PROCEEDINGS WITH THE SECURITIES AND EXCHANGE COMMISSION (THE "SEC" AND THE ORDER, THE "SEC ORDER"), WHICH ALLEGED THAT GS GROUP AND CERTAIN OF ITS AFFILIATES FAILED TO TIMELY FILE REPORTS ON FORMS 3 AND 4 IN ACCORDANCE WITH SECTION 16(A) OF THE SECURITIES EXCHANGE ACT 1934, AS AMENDED, AND RULE 16A-3 THEREUNDER. Status: Final Sanction Detail: PURSUANT TO THE SEC ORDER, THE SEC REQUIRED GS GROUP TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $300,000. GS GROUP PAID THE PENALTY ON 10/15/2024. Summary: GS GROUP PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $300,000 TO THE SEC ON 10/15/2024.