Goldman Sachs Asset Management (Singapore) Pte. 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 MAY 19, 2023, MS. SHANDLING WAS MADE AWARE OF AN ORDER BY THE SUPREME COURT OF THE STATE OF NEW YORK APPELLATE DIVISION, FIRST JUDICIAL DEPARTMENT (THE "COURT"), DATED NOVEMBER 14, 2022, SUSPENDING MS. SHANDLING FOR FAILURE TO FILE A BIENNIAL REGISTRATION AS A RETIRED ATTORNEY PER JUDICIARY LAW §468-A. Status: Final Sanction Detail: ON MAY 19, 2023, MS. SHANDLING WAS MADE AWARE OF AN ORDER BY THE SUPREME COURT OF THE STATE OF NEW YORK APPELLATE DIVISION, FIRST JUDICIAL DEPARTMENT (THE "COURT"), DATED NOVEMBER 14, 2022, SUSPENDING MS. SHANDLING FOR FAILURE TO FILE A BIENNIAL REGISTRATION AS A RETIRED ATTORNEY PER JUDICIARY LAW §468-A, WHICH REQUIRES THAT EVERY ATTORNEY ADMITTED TO PRACTICE IN THE STATE OF NEW YORK REGISTER BIENNIALLY AS AN ACTIVE ATTORNEY OR A RETIRED ATTORNEY WITH THE CHIEF ADMINISTRATOR OF THE COURTS. THE SUSPENSION WAS ADMINISTRATIVE IN NATURE. MS. SHANDLING HAS NOT PRACTICED LAW SINCE BEFORE 2015, INCLUDING SINCE THE EXPIRATION OF HER PRIOR BIENNIAL REGISTRATION. ON MAY 22, 2023, MS. SHANDLING FILED A CORRECTIVE REGISTRATION STATEMENT WITH THE COURT INDICATING THAT SHE HAS RETIRED FROM THE PRACTICE OF LAW, AND ON MAY 30, 2023, SHE FILED A MOTION FOR REINSTATEMENT OF HER REGISTRATION WITH THE COURT. ON JULY 6, 2023, THE COURT GRANTED MS. SHANDLING'S MOTION AND REINSTATED HER AS A RETIRED ATTORNEY AND COUNSELOR-AT-LAW IN THE STATE OF NEW YORK. Summary: ON MAY 19, 2023, MS. SHANDLING WAS MADE AWARE OF AN ORDER BY THE SUPREME COURT OF THE STATE OF NEW YORK APPELLATE DIVISION, FIRST JUDICIAL DEPARTMENT (THE "COURT"), DATED NOVEMBER 14, 2022, SUSPENDING MS. SHANDLING FOR FAILURE TO FILE A BIENNIAL REGISTRATION AS A RETIRED ATTORNEY PER JUDICIARY LAW §468-A, WHICH REQUIRES THAT EVERY ATTORNEY ADMITTED TO PRACTICE IN THE STATE OF NEW YORK REGISTER BIENNIALLY AS AN ACTIVE ATTORNEY OR A RETIRED ATTORNEY WITH THE CHIEF ADMINISTRATOR OF THE COURTS. THE SUSPENSION WAS ADMINISTRATIVE IN NATURE. MS. SHANDLING HAS NOT PRACTICED LAW SINCE BEFORE 2015, INCLUDING SINCE THE EXPIRATION OF HER PRIOR BIENNIAL REGISTRATION. ON MAY 22, 2023, MS. SHANDLING FILED A CORRECTIVE REGISTRATION STATEMENT WITH THE COURT INDICATING THAT SHE HAS RETIRED FROM THE PRACTICE OF LAW, AND ON MAY 30, 2023, SHE FILED A MOTION FOR REINSTATEMENT OF HER REGISTRATION WITH THE COURT. ON JULY 6, 2023, THE COURT GRANTED MS. SHANDLING'S MOTION AND REINSTATED HER AS A RETIRED ATTORNEY AND COUNSELOR-AT-LAW IN THE STATE OF NEW YORK.

Allegations: THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM (THE ""FEDERAL RESERVE"") HAS ALLEGED THAT: WHEREAS THE GOLDMAN SACHS GROUP, INC. (""GS GROUP"") SERVES AS A FOREIGN EXCHANGE (""FX"") DEALER THROUGH CERTAIN OF ITS INDIRECT SUBSIDIARIES (""FX SUBSIDIARIES""), BY BUYING AND SELLING U.S. DOLLARS AND FOREIGN CURRENCY FOR THEIR OWN ACCOUNT AND BY SOLICITING AND RECEIVING ORDERS THROUGH COMMUNICATIONS BETWEEN CUSTOMERS AND SALES PERSONNEL THAT ARE EXECUTED ON THE SPOT MARKET (""COVERED FX ACTIVITIES""), FROM OCTOBER 2008 THROUGH OCTOBER 2012, GS GROUP AND CERTAIN SUBSIDIARIES (TOGETHER, THE ""FIRM""): (A) LACKED ADEQUATE GOVERNANCE, COMPLIANCE RISK MANAGEMENT, COMPLIANCE AND/OR AUDIT POLICIES TO ENSURE THAT THE FX SUBSIDIARIES' COVERED FX ACTIVITIES COMPLIED WITH SAFE AND SOUND BANKING PRACTICES AND APPLICABLE INTERNAL POLICIES; AND (B) HAD DEFICIENT POLICIES AND PROCEDURES THAT PREVENTED IT FROM DETECTING AND ADDRESSING POTENTIALLY UNSOUND CONDUCT BY CERTAIN OF THE FX SUBSIDIARIES' FX TRADERS, AND AS A RESULT OF THE DEFICIENT POLICIES AND PROCEDURES, ENGAGED IN UNSAFE AND UNSOUND BANKING PRACTICES. Status: Final Sanction Detail: ON MAY 1, 2018, GS GROUP AND THE FEDERAL RESERVE ENTERED INTO AN ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF A CIVIL MONEY PENALTY ISSUED UPON CONSENT PURSUANT TO THE FEDERAL DEPOSIT INSURANCE ACT, AS AMENDED, WHICH ASSESSES THE FIRM A CIVIL MONETARY PENALTY IN THE AMOUNT OF $54,750,000, WHICH THE FIRM PAID TO THE FEDERAL RESERVE ON MAY 2, 2018. Summary: ON MAY 1, 2018, PRIOR TO THE FILING OF ANY NOTICES OF CHARGES, OR TAKING OF ANY TESTIMONY, OR ADJUDICATION OF OR FINDING ON ANY ISSUES OF FACT OR LAW HEREIN, AND SOLELY FOR THE PURPOSE OF SETTLEMENT OF THIS MATTER WITHOUT A FORMAL PROCEEDING BEING FILED AND WITHOUT THE NECESSITY FOR PROTRACTED OR EXTENDED HEARINGS OR TESTIMONY, GS GROUP AND THE FEDERAL RESERVE ENTERED INTO AN ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF A CIVIL MONEY PENALTY ISSUED UPON CONSENT PURSUANT TO THE FEDERAL DEPOSIT INSURANCE ACT, AS AMENDED (THE ""CONSENT ORDER""), PURSUANT TO WHICH: (A) GS GROUP, AS APPLICABLE, SHALL SUBMIT TO THE FEDERAL RESERVE WITHIN THE APPLICABLE TIME PERIODS SET FORTH IN THE CONSENT ORDER, AN ENHANCED WRITTEN INTERNAL CONTROLS AND COMPLIANCE PROGRAM, COMPLIANCE RISK MANAGEMENT PROGRAM, CONTROLS REVIEW, AND INTERNAL AUDIT PROGRAM, EACH AS ACCEPTABLE TO THE FEDERAL RESERVE; (B) THE FIRM SHALL ADOPT AND IMPLEMENT THESE PROGRAMS AND SUBMIT PROGRESS REPORTS TO THE FEDERAL RESERVE; (C) THE FIRM SHALL NOT IN THE FUTURE DIRECTLY OR INDIRECTLY RETAIN ANY INDIVIDUAL AS AN OFFICER, EMPLOYEE, AGENT, CONSULTANT, OR CONTRACTOR OF THE FIRM OR ANY SUBSIDIARY OR ANY AFFILIATE THEREOF WHO HAS PARTICIPATED IN THE CONDUCT UNDERLYING THE CONSENT ORDER, BEEN SUBJECT TO A FORMAL DISCIPLINARY ACTION AS A RESULT OF THE FIRM'S INTERNAL DISCIPLINARY REVIEW OR PERFORMANCE REVIEW IN CONNECTION WITH THE CONDUCT DESCRIBED IN THE CONSENT ORDER AND SEPARATED FROM THE FIRM OR ANY SUBSIDIARY THEREOF OR HAD HIS OR HER EMPLOYMENT TERMINATED IN CONNECTION WITH THE CONDUCT DESCRIBED IN THE CONSENT ORDER; AND (D) THE FIRM PAID A CIVIL MONETARY PENALTY IN THE AMOUNT OF $54,750,000 ON MAY 2, 2018.

Allegations: THE GOLDMAN SACHS GROUP, INC. ("GS GROUP") AND GOLDMAN SACHS BANK USA ("GS BANK") ENTERED INTO AN ORDER OF ASSESSMENT OF A CIVIL MONEY PENALTY ISSUED UPON CONSENT PURSUANT TO THE FEDERAL DEPOSIT INSURANCE ACT, AS AMENDED, WITH THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM (THE "FEDERAL RESERVE") ON JANUARY 12, 2018 (THE "CONSENT ASSESSMENT"). THE CONSENT ASSESSMENT RELATED TO ALLEGATIONS BY THE FEDERAL RESERVE THAT, PRIOR TO SEPTEMBER 1, 2011, GS GROUP AND GS BANK HAD ENGAGED IN DEFICIENT PRACTICES IN RESIDENTIAL MORTGAGE LOAN SERVICING AND FORECLOSURE PROCESSING INVOLVING LITTON LOAN SERVICING LP ("LITTON"), A FORMER SUBSIDIARY. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS GROUP AND GS BANK HAD PREVIOUSLY ENTERED INTO A CONSENT ORDER WITH THE FEDERAL RESERVE RELATING TO THE SAME ALLEGED CONDUCT ON SEPTEMBER 1, 2011, AS AMENDED ON FEBRUARY 28, 2013 (THE "AMENDED CONSENT", WHICH IS REPORTED ON A SEPARATE DRP). Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS IN THE AMENDED CONSENT, GS GROUP, GS BANK AND THE FEDERAL RESERVE ENTERED INTO THE CONSENT ASSESSMENT, WHICH RELEASES AND DISCHARGES GS GROUP, GS BANK, AND THEIR AFFILIATES, SUCCESSORS, AND ASSIGNS FROM ALL POTENTIAL LIABILITY THAT HAS BEEN OR MIGHT HAVE BEEN ASSERTED BY THE FEDERAL RESERVE BASED ON THE CONDUCT THAT IS THE SUBJECT OF CONSENT ASSESSMENT OR THE AMENDED CONSENT, AND ASSESSES GS GROUP AND GS BANK A CIVIL MONEY PENALTY IN THE AMOUNT OF $14,000,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON JANUARY 12, 2018. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS IN THE AMENDED CONSENT, GS GROUP, GS BANK AND THE FEDERAL RESERVE ENTERED INTO THE CONSENT ASSESSMENT, WHICH RELEASES AND DISCHARGES GS GROUP, GS BANK, AND THEIR AFFILIATES, SUCCESSORS, AND ASSIGNS FROM ALL POTENTIAL LIABILITY THAT HAS BEEN OR MIGHT HAVE BEEN ASSERTED BY THE FEDERAL RESERVE BASED ON THE CONDUCT THAT IS THE SUBJECT OF CONSENT ASSESSMENT OR THE AMENDED CONSENT, AND ASSESSES GS GROUP AND GS BANK A CIVIL MONEY PENALTY IN THE AMOUNT OF $14,000,000, WHICH WAS PAID TO THE FEDERAL RESERVE BY SUBMISSION OF A WIRE ON JANUARY 12, 2018.

Allegations: THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM (THE "BOARD OF GOVERNORS") HAS ALLEGED THAT: (A) GOLDMAN, SACHS & CO. ("GSCO") AND THE GOLDMAN SACHS GROUP, INC., (TOGETHER WITH GSCO, (THE "FIRM") FAILED TO MONITOR ELECTRONIC MAIL FOR DOCUMENTS CONTAINING CONFIDENTIAL SUPERVISORY INFORMATION; (B) FIRM EMPLOYEES, INCLUDING SENIOR MANAGERS, HAD CONFIDENTIAL SUPERVISORY INFORMATION OF THE BOARD OF GOVERNORS AND OTHER BANKING REGULATORS IN THEIR POSSESSION WITHOUT THE AUTHORIZATION REQUIRED BY LAW; (C) A FIRM EMPLOYEE ENGAGED IN CRIMINAL THEFT OF CONFIDENTIAL SUPERVISORY INFORMATION OF THE BOARD OF GOVERNORS AND OTHER BANKING REGULATORS, AND DISSEMINATED SUCH INFORMATION TO MULTIPLE EMPLOYEES WITHIN THE FIRM; (D) THE FIRM'S PERSONNEL IMPROPERLY USED CONFIDENTIAL SUPERVISORY INFORMATION, INCLUDING CONFIDENTIAL SUPERVISORY INFORMATION RELATING TO INSTITUTIONS OTHER THAN THE FIRM, OF THE BOARD OF GOVERNORS AND OTHER BANKING REGULATORS IN PRESENTATIONS TO ITS CLIENTS AND PROSPECTIVE CLIENTS IN AN EFFORT TO SOLICIT BUSINESS FOR THE FIRM; AND (E) THE FIRM LACKED ADEQUATE POLICIES AND PROCEDURES DESIGNED TO DETECT OR PREVENT THE UNAUTHORIZED DISSEMINATION AND USE OF CONFIDENTIAL SUPERVISORY INFORMATION BELONGING TO THE BOARD OF GOVERNORS AND OTHER BANKING REGULATORS. Status: Final Sanction Detail: THE CONSENT ORDER REQUIRED THE FIRM TO PAY A CIVIL MONETARY PENALTY TO THE BOARD OF GOVERNORS IN THE AMOUNT OF $36,300,000, WHICH THE FIRM PAID ON AUGUST 3, 2016. Summary: THE FIRM AND THE BOARD OF GOVERNORS ENTERED INTO A CONSENT ORDER TO CEASE AND DESIST AND ASSESSMENT OF CIVIL MONEY PENALTY ON AUGUST 2, 2016 (THE "CONSENT ORDER"), PURSUANT TO WHICH: (A) WITHIN 30 DAYS OF THE CONSENT ORDER, THE BOARD OF DIRECTORS OF THE FIRM SHALL APPOINT A COMMITTEE COMPRISED OF MEMBERS OF SENIOR MANAGEMENT TO MONITOR AND COORDINATE COMPLIANCE WITH THE PROVISIONS OF THE CONSENT ORDER, WHICH COMMITTEE SHALL MEET QUARTERLY, KEEP DETAILED MINUTES OF EACH MEETING, AND ANNUALLY SUBMIT TO THE BOARD OF GOVERNORS AND THE BOARD OF DIRECTORS OF THE FIRM WRITTEN PROGRESS REPORTS DETAILING THE FORM AND MANNER OF ALL ACTIONS TAKEN TO SECURE COMPLIANCE WITH THE CONSENT ORDER AND THE RESULTS THEREOF; (B) WITHIN 90 DAYS OF THE CONSENT ORDER, THE FIRM SHALL: (I) SUBMIT TO THE BOARD OF GOVERNORS A WRITTEN PLAN, AND TIMELINE FOR IMPLEMENTATION, TO ENHANCE THE EFFECTIVENESS OF THE INTERNAL CONTROLS AND COMPLIANCE FUNCTIONS REGARDING THE IDENTIFICATION, MONITORING, AND CONTROL OF CONFIDENTIAL SUPERVISORY INFORMATION, WHICH PLAN SHALL BE REVIEWED FOR EFFECTIVENESS BY THE FIRM'S INTERNAL AUDIT FUNCTION; (II) SUBMIT TO THE BOARD OF GOVERNORS A WRITTEN PLAN, AND TIMELINE FOR IMPLEMENTATION, FOR THE TRAINING OF ALL APPROPRIATE [GSCO] PERSONNEL REGARDING THE RESTRICTIONS, CONTROLS AND LEGAL REQUIREMENTS GOVERNING THE USE OF CONFIDENTIAL SUPERVISORY INFORMATION; AND (III) CERTIFY TO THE BOARD OF GOVERNORS THAT ALL DOCUMENTS CONTAINING CONFIDENTIAL SUPERVISORY INFORMATION OF WHICH THE FIRM IS AWARE OR BECOMES AWARE THAT THE FIRM OBTAINED WITHOUT APPROPRIATE REGULATORY AUTHORIZATION HAVE BEEN DE-REFERENCED FROM THE FIRM'S INTERNAL SYSTEMS AND RENDERED INACCESSIBLE BY FIRM PERSONNEL, AND TO THE EXTENT SUCH CONFIDENTIAL SUPERVISORY INFORMATION MAY BE SUBSEQUENTLY BE RESTORED OR RENDERED ACCESSIBLE FOR ANY PURPOSE, THE FIRM SHALL NOTIFY THE BOARD OF GOVERNORS PRIOR TO SUCH INFORMATION BEING RESTORED OR ACCESSIBLE BY FIRM PERSONNEL; (C) THE FIRM SHALL NOT IN THE FUTURE DIRECTLY OR INDIRECTLY RETAIN ANY INDIVIDUAL AS AN OFFICER, EMPLOYEE, AGENT, CONSULTANT, OR CONTRACTOR OF THE FIRM OR OF ANY AFFILIATE OF THE FIRM WHO, BASED ON THE INVESTIGATIVE RECORD COMPILED BY U.S. AUTHORITIES, HAS DONE ALL OF THE FOLLOWING: (I) PARTICIPATED IN THE ILLEGAL CONDUCT DESCRIBED IN THE CONSENT ORDER; (II) BEEN SUBJECT TO FORMAL DISCIPLINARY ACTION AS A RESULT OF GSCO'S INTERNAL DISCIPLINARY REVIEW OR PERFORMANCE REVIEW IN CONNECTION WITH THE CONDUCT DESCRIBED IN THE CONSENT ORDER; AND (III) HAS BEEN SEPARATED FROM OR HAS HAD HIS OR HER EMPLOYMENT TERMINATED BY THE FIRM; AND (D) THE FIRM PAID A CIVIL MONETARY PENALTY IN THE AMOUNT OF $36,300,000 MILLION ON AUGUST 3, 2016.

Allegations: THE FEDERAL DEPARTMENT OF FINANCE ("FDF") OF THE SWISS CONFEDERATION ALLEGED THAT THE GOLDMAN SACHS GROUP, INC. ("GS GROUP") PUBLISHED TWICE AN INCOMPLETE NOTIFICATION REGARDING THE FIRM'S HOLDINGS IN CERTAIN SECURITIES IN THE PERIOD BETWEEN DECEMBER 12, 2013 AND FEBRUARY 12, 2014, AND PUBLISHED DELAYED NOTIFICATION OF THE FIRM'S QUALIFIED SHAREHOLDING IN CERTAIN SECURITIES EXCEEDING THE NOTIFICATION THRESHOLD IN THE PERIOD BETWEEN AUGUST 19, 2014 AND AUGUST 8, 2015, EACH IN ALLEGED INFRINGEMENT OF ARTICLE 41 OF THE SWISS FEDERAL ACT ON STOCK EXCHANGES AND SECURITIES TRADING ("SESTA"). Status: Final Sanction Detail: WITHOUT ADMITTING ANY INTENTIONAL INFRINGEMENT OF SESTA ARTICLES OR WRONGDOING, GS GROUP CONSENTED TO A PAYMENT TO THE SWISS CONFEDERATION IN THE AMOUNT OF CHF20,000, WHICH AMOUNT WAS PAID ON DECEMBER 18, 2015. WHILE THE ACTUAL PAYMENT WAS MADE IN SWISS FRANCS, USING THE MOST RECENTLY PUBLISHED FEDERAL RESERVE FOREIGN EXCHANGE RATE OF CHF0.9828:USD1 AS OF DECEMBER 11, 2015, THE EQUIVALENT U.S. DOLLAR VALUE ON DECEMBER 11, 2015 WAS $20,350.02, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE. Summary: WITHOUT ADMITTING ANY INTENTIONAL INFRINGEMENT OF SESTA ARTICLES OR WRONGDOING, GS GROUP ENTERED INTO A SETTLEMENT AGREEMENT WITH FDF ON DECEMBER 8, 2015, AND CONSENTED TO A PAYMENT TO THE SWISS CONFEDERATION IN THE AMOUNT OF CHF20,000, WHICH AMOUNT WAS PAID ON DECEMBER 18, 2015.

Allegations: ON FEBRUARY 24, 2021, FINANSTILSYNET, THE FINANCIAL SUPERVISORY AUTHORITY OF NORWAY CONCLUDED THAT GOLDMAN SACHS GROUP, INC., GOLDMAN SACHS INTERNATIONAL, AND GOLDMAN SACHS & CO. LLC VIOLATED THE NOTIFICATION REQUIREMENT UNDER SECTION 3-14 OF THE NORWEGIAN SECURITIES TRADING ACT, CF. REGULATION (EU) NO 236/2012 ("SSR") ARTICLE 5, CF. ARTICLE 9, BY NOT NOTIFYING FINANSTILSYNET OF NET SHORT POSITIONS WITHIN THE TIME LIMIT LAID IN ACCORDANCE WITH SSR. Status: Final Sanction Detail: ON FEBRUARY 24, 2021, FINANSTILSYNET IMPOSED A VIOLATION PENALTY OF NOK 350,000(APPROXIMATELY USD 41,939.27). THE FINE WAS PAID IN FULL BY WIRE SUBMISSION ON JUNE 16, 2021. Summary: ON FEBRUARY 24, 2021, FINANSTILSYNET IMPOSED A VIOLATION PENALTY OF NOK 350,000 (APPROXIMATELY USD 41,939.27). THE FINE WAS PAID IN FULL BY WIRE SUBMISSION ON JUNE 16, 2021.

Allegations: ON SEPTEMBER 20, 2019 THE SWEDISH FINANCIAL SUPERVISORY AUTHORITY (FINANSINSPEKTIONEN - "SFSA") IMPOSED AN ADMINISTRATIVE FINE ON THE GOLDMAN SACHS GROUP, INC. ("GS GROUP") IN THE AMOUNT OF 70,000 SWEDISH KRONA (SEK) (APPROXIMATELY USD 7,200). SFSA ALLEGES A VIOLATION BY GS GROUP OF CHAPTER 6, SECTION 3 A, SUBSECTION 1 OF THE FINANCIAL INSTRUMENTS TRADING ACT DUE TO A DELAY IN NOTIFYING A RELEVANT CHANGE IN GS GROUP'S HOLDING OF SHARES AND OTHER FINANCIAL INSTRUMENTS IN FINGERPRINT CARDS AB. Status: Final Sanction Detail: "GOLDMAN SACHS GROUP, INC. PAID THE FINE OF 70,000 SEK ON DECEMBER 19, 2019 TO THE SFSA BY WIRE. WHILE THE ACTUAL PAYMENT OF THE FINE WAS MADE IN SEK, BASED ON THE FOREIGN EXCHANGE RATE OF 1 USD: 9.4211 SEK AS OF DECEMBER 19, 2019, THE EQUIVALENT U.S. DOLLAR VALUE WAS APPROXIMATELY 7,430.13 USD, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE." Summary: "GOLDMAN SACHS GROUP, INC. PAID THE FINE OF 70,000 SEK ON DECEMBER 19, 2019 TO THE SFSA BY WIRE. WHILE THE ACTUAL PAYMENT OF THE FINE WAS MADE IN SEK, BASED ON THE FOREIGN EXCHANGE RATE OF 1 USD: 9.4211 SEK AS OF DECEMBER 19, 2019, THE EQUIVALENT U.S. DOLLAR VALUE WAS APPROXIMATELY 7,430.13 USD, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE."

Allegations: THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES (THE "DFS") HAS ALLEGED THAT: (A) CERTAIN FOREIGN EXCHANGE ("FX") TRADERS AT CERTAIN AFFILIATES OF THE GOLDMAN SACHS GROUP, INC. AND GOLDMAN SACHS BANK USA (TOGETHER, "GOLDMAN SACHS") ENGAGED IN IMPROPER CONDUCT OVER THE PERIOD 2008 THROUGH EARLY 2013; (B) ESCALATION OF CERTAIN COMPLIANCE CONCERNS DID NOT ALWAYS OCCUR AS REQUIRED, ALLOWING POTENTIALLY IMPROPER ACTIVITY TO CONTINUE UNNECESSARILY; AND (C) GOLDMAN SACHS CONDUCTED BANKING BUSINESS IN AN UNSAFE AND UNSOUND MANNER, IN VIOLATION OF NEW YORK BANKING LAW § 44. Status: Final Sanction Detail: ON MAY 1, 2018, GOLDMAN SACHS AND THE DFS ENTERED INTO A CONSENT ORDER UNDER NEW YORK STATE BANKING LAW §§ 39 AND 44, WHICH ASSESSES GOLDMAN SACHS A CIVIL MONETARY PENALTY IN THE AMOUNT OF $54,750,000, WHICH GOLDMAN SACHS PAID TO THE DFS ON MAY 8, 2018. Summary: ON MAY 1, 2018, GOLDMAN SACHS AND THE DFS ENTERED INTO A CONSENT ORDER UNDER NEW YORK STATE BANKING LAW §§ 39 AND 44 (THE "CONSENT ORDER"), PURSUANT TO WHICH GOLDMAN SACHS: (A) SHALL NOT IN THE FUTURE REHIRE OR RETAIN A CERTAIN TRADER AS EITHER AN OFFICER, EMPLOYEE, AGENT, CONSULTANT, OR CONTRACTOR OF GOLDMAN SACHS OR ANY AFFILIATE OF GOLDMAN SACHS, OR IN ANY OTHER CAPACITY; (B) SHALL SUBMIT TO THE DFS WITHIN THE APPLICABLE TIME PERIODS SET FORTH IN THE CONSENT ORDER, AN ENHANCED WRITTEN INTERNAL CONTROLS AND COMPLIANCE PROGRAM, COMPLIANCE RISK MANAGEMENT PROGRAM, AND INTERNAL AUDIT PROGRAM, EACH ACCEPTABLE TO THE DFS, ADOPT AND IMPLEMENT THOSE PROGRAMS, AND PROVIDE WRITTEN PROGRESS REPORTS CONCERNING: (I) COMPLIANCE WITH APPLICABLE NEW YORK STATE AND FEDERAL LAWS AND REGULATIONS AS REGARDS ITS FX BUSINESS, AND RECOGNIZED FX INDUSTRY BEST PRACTICES, AS AFFECT OR PERTAIN TO GOLDMAN SACHS OR NEW YORK CUSTOMERS; (II) CREATION OF ENHANCED POLICIES AND PROCEDURES GOVERNING THE FX BUSINESS, AND GOLDMAN SACHS' COMPLIANCE WITH THOSE POLICIES AND PROCEDURES, AS AFFECT OR PERTAIN TO GOLDMAN SACHS OR NEW YORK CUSTOMERS, AND (III) GOLDMAN SACHS' MAINTENANCE OF AN HONEST, ETHICAL AND FAIR FX BUSINESS AS IT AFFECTS OR PERTAINS TO THE NEW YORK BRANCH OR NEW YORK CUSTOMERS; AND (C) PAID A CIVIL MONETARY PENALTY IN THE AMOUNT OF $54,750,000 ON MAY 8, 2018.

Allegations: THE CZECH NATIONAL BANK ("CNB") ISSUED AN ORDER ALLEGING THAT THE GOLDMAN SACHS GROUP, INC. (THE "FIRM") FAILED TO NOTIFY THE CNB WITHIN THE STATUTORY TIME LIMIT THAT ITS SHARES IN THE VOTING RIGHTS OF A CERTAIN ISSUER COMPANY HAD EXCEEDED 1%, IN DEEMED VIOLATION OF ARTICLE 122(1), AND IN CONJUNCTION WITH ARTICLE 122(2), OF THE CAPITAL MARKET UNDERTAKINGS ACT. Status: Final Sanction Detail: THE CNB IMPOSED A FINE ON THE FIRM IN THE AMOUNT OF 750,000 CZECH KORUNA (CZK), TOGETHER WITH COSTS OF 1,000 CZK, WHICH WAS PAID BY WIRE ON SEPTEMBER 7, 2018. WHILE THE ACTUAL PAYMENT OF THE FINE AND COSTS WAS MADE IN CZECH KORUNA, USING THE CNB FOREIGN EXCHANGE RATE OF CZK22.124:USD1 AS OF SEPTEMBER 7, 2018, THE EQUIVALENT U.S. DOLLAR VALUE ON SEPTEMBER 7, 2018 WAS APPROXIMATELY $33,945.00, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE. Summary: THE CNB IMPOSED A FINE ON THE FIRM IN THE AMOUNT OF 750,000 CZECH KORUNA (CZK), TOGETHER WITH COSTS OF 1,000 CZK, WHICH WAS PAID BY WIRE ON SEPTEMBER 7, 2018.

Allegations: ON OCTOBER 22, 2020, THE GOLDMAN SACHS GROUP, INC. ("GS GROUP") ENTERED INTO AN ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF A CIVIL MONEY PENALTY WITH THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM (THE "FEDERAL RESERVE", AND THE ORDER, THE "FEDERAL RESERVE ORDER"), WHICH ALLEGED GS GROUP ENGAGED IN UNSAFE AND UNSOUND BANKING PRACTICES RELATING TO THE 1MALAYSIA DEVELOPMENT BERHAD ("1MDB") BOND TRANSACTIONS THAT RESULTED FROM DEFICIENT POLICIES, PROCEDURES AND CONTROLS. SUCH DEFICIENCIES INCLUDED (I) THE LACK OF, OR FAILURE TO IMPLEMENT, ADEQUATE COMPLIANCE POLICIES AND PROCEDURES TO ENSURE THE 1MDB OFFERINGS COMPLIED WITH SAFE AND SOUND PRACTICES; (II) THE FAILURE OF THE REVIEW AND APPROVAL PROCESS TO APPRECIATE THE SIGNIFICANT RISKS ASSOCIATED WITH THE 1MDB OFFERINGS; (III) THE FAILURE OF GS GROUP CONTROL FUNCTIONS AND SENIOR PERSONNEL TO ADDRESS RED FLAGS, INSIST ON ADEQUATE INFORMATION AND DOCUMENTATION REGARDING KEY ASPECTS OF THE OFFERINGS PRIOR TO EXECUTION, AND EFFECTIVELY SUPERVISE A SENIOR BUSINESS EMPLOYEE ABOUT WHOM CERTAIN GS GROUP PERSONNEL HAD EXPRESSED INTEGRITY CONCERNS IN THE PAST; AND (IV) THE FAILURE TO ESCALATE OR ADDRESS ALLEGATIONS OF BRIBERY COMMUNICATED TO CERTAIN SENIOR BUSINESS PERSONNEL. Status: Final Sanction Detail: PURSUANT TO THE FEDERAL RESERVE ORDER, THE FEDERAL RESERVE ORDERED GS GROUP TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $154,000,000. Summary: IN ADDITION TO PAYMENT OF THE CIVIL MONEY PENALTY, THE FEDERAL RESERVE ORDER REQUIRES THAT GS GROUP TAKE CERTAIN AFFIRMATIVE ACTIONS, INCLUDING SUBMITTING TO THE FEDERAL RESERVE (I) A WRITTEN PLAN TO ENHANCE, AND MAINTAIN IMPROVEMENTS TO, OVERSIGHT OF THE REVIEW AND APPROVAL OF CERTAIN SIGNIFICANT AND COMPLEX TRANSACTIONS; (II) A WRITTEN PLAN TO ENHANCE ITS EXISTING ANTI-BRIBERY COMPLIANCE PROGRAM FOR SUCH TRANSACTIONS; AND (III) A WRITTEN ENHANCED DUE DILIGENCE PROGRAM FOR SUCH TRANSACTIONS, IN EACH CASE EACH ACCEPTABLE TO THE FEDERAL RESERVE.

Allegations: ON OCTOBER 22, 2020, THE GOLDMAN SACHS GROUP, INC. ("GS GROUP") ENTERED INTO A CONSENT ORDER FOR A CIVIL MONEY PENALTY WITH THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES (THE "DFS", AND THE CONSENT ORDER, THE "DFS ORDER"), WHICH ALLEGED VIOLATIONS OF THE NEW YORK BANKING LAW ("BANKING LAW") ARISING OUT OF INVESTMENTS BY A GS GROUP WHOLLY-OWNED SUBSIDIARY, GOLDMAN SACHS BANK USA ("GS BANK"), IN INSTRUMENTS RELATED TO 1MALAYSIA DEVELOPMENT BERHAD ("1MDB"). THE CONDUCT DESCRIBED IN THE DFS ORDER INCLUDES (I) THE FAILURE OF GS GROUP TO ADEQUATELY DETECT OR ADDRESS CERTAIN RED FLAGS IN CONNECTION WITH THE 1MDB BOND TRANSACTIONS; (II) GS GROUP'S FAILURE TO ESCALATE OR ADDRESS ALLEGATIONS OF BRIBERY COMMUNICATED TO CERTAIN SENIOR BUSINESS PERSONNEL FOLLOWING THE COMPLETION OF THE 1MDB OFFERINGS; (III) GS GROUP'S FAILURE TO ADDRESS ALLEGATIONS OF ITS EMPLOYEES SUSPECTED INVOLVEMENT IN THE 1MDB MISCONDUCT; AND (IV) GS GROUP'S FAILURE TO CONVEY TO GS BANK RED FLAGS OR INFORMATION KNOWN ABOUT THE 1MDB OFFERINGS OR THE MISCONDUCT OF ITS EMPLOYEES SO THAT GS BANK COULD AFFIRMATIVELY REPORT THE INCIDENT TO THE DFS. THE DFS ORDER ALSO FINDS THAT GS GROUP VIOLATED SECTION 44 OF THE BANKING LAW BY CONDUCTING BUSINESS IN AN UNSAFE AND UNSOUND MANNER AND 3 N.Y.C.R.R. SECTION 300.4 BY FAILING TO SUBMIT A REPORT TO THE UPERINTENDENT OF THE DFS OF ONE OR MORE INCIDENTS THAT APPEAR TO RELATE TO A PLAN OR SCHEME THAT WOULD BE OF INTEREST TO SIMILAR ORGANIZATIONS LOCATED IN THE SAME AREA OR THROUGH THE STATE. Status: Final Sanction Detail: PURSUANT TO THE DFS ORDER, THE DFS REQUIRED GS GROUP TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $150,000,000. Summary: GS GROUP PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $150,000,000 TO THE DFS.

Allegations: THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES (THE "DFS") HAS ALLEGED THAT: (A) A FORMER ASSOCIATE OF GOLDMAN, SACHS & CO. (TOGETHER WITH THE GOLDMAN SACHS GROUP, INC., ("GOLDMAN SACHS") ENGAGED IN THE THEFT OF DFS CONFIDENTIAL SUPERVISORY INFORMATION, AND THAT A FORMER GOLDMAN SACHS MANAGING DIRECTOR IMPROPERLY RECEIVED THIS INFORMATION WITHOUT REPORTING IT; AND (B) GOLDMAN SACHS FAILED: (I) TO EFFECTIVELY SUPERVISE THE ASSOCIATE TO PREVENT THIS THEFT FROM OCCURRING; (II) TO IMPLEMENT AND MAINTAIN ADEQUATE POLICIES AND PROCEDURES RELATING TO POST-EMPLOYMENT RESTRICTIONS FOR FORMER GOVERNMENT EMPLOYEES; AND (III) TO IMPLEMENT AND MAINTAIN SUFFICIENT POLICIES AND PROCEDURES TO ENSURE COMPLIANCE WITH NEW YORK STATE BANKING LAW SECTION 36(10) ("SECTION 36(10)"), SPECIFICALLY WITH RESPECT TO GOLDMAN SACHS' UNAUTHORIZED POSSESSION AND DISTRIBUTION OF DFS CONFIDENTIAL SUPERVISORY INFORMATION. Status: Final Sanction Detail: THE CONSENT ORDER REQUIRED GOLDMAN SACHS TO PAY A CIVIL MONETARY PENALTY TO THE DFS IN THE AMOUNT OF $50 MILLION, WHICH GOLDMAN SACHS PAID ON NOVEMBER 9, 2015. Summary: GOLDMAN SACHS AND THE DFS ENTERED INTO A CONSENT ORDER UNDER NEW YORK STATE BANKING LAW SECTIONS 39 AND 44 ON OCTOBER 28, 2015 (THE "CONSENT ORDER"), PURSUANT TO WHICH GOLDMAN SACHS: (A) VOLUNTARILY WILL NOT ACCEPT ANY NEW ENGAGEMENTS THAT WOULD REQUIRE THE DFS TO AUTHORIZE THE DISCLOSURE OF CONFIDENTIAL SUPERVISORY INFORMATION UNDER SECTION 36(10) TO GOLDMAN SACHS DURING THE THREE-YEAR PERIOD FOLLOWING THE DATE OF THE CONSENT ORDER; (B) AGREED TO IMPLEMENT REFORMS TO ITS POLICIES AND PROCEDURES THAT ARE REASONABLY DESIGNED TO PREVENT THE IMPROPER USE OF CONFIDENTIAL SUPERVISORY INFORMATION UNDER SECTION 36(10), INCLUDING: (I) POLICIES AND PROCEDURES REASONABLY DESIGNED TO ENSURE THE PROTECTION AND PROPER HANDLING OF CONFIDENTIAL SUPERVISORY INFORMATION UNDER SECTION 36(10); (II) CONFIRMING THAT, TO THE BEST OF GOLDMAN SACHS' KNOWLEDGE, AS OF THE DATE OF THE CONSENT ORDER, GOLDMAN SACHS HAD NOT ACCEPTED ANY ENGAGEMENTS THAT WOULD REQUIRE THE DFS TO AUTHORIZE THE DISCLOSURE OF CONFIDENTIAL SUPERVISORY INFORMATION UNDER SECTION 36(10); (III) POLICIES AND PROCEDURES REASONABLY DESIGNED TO ENSURE THAT GOLDMAN SACHS IS AWARE OF APPLICABLE POST-EMPLOYMENT RESTRICTIONS FOR FORMER GOVERNMENT EMPLOYEES HIRED AFTER THE DATE OF THE CONSENT ORDER WHO HAVE LEFT THE GOVERNMENT WITHIN THE PAST FIVE YEARS AND THAT GOLDMAN SACHS HAS TAKEN STEPS NECESSARY TO ADDRESS COMPLIANCE WITH THOSE RESTRICTIONS; (IV) PROCESSES TO MONITOR THE ASSIGNMENT OF SUCH FORMER GOVERNMENT EMPLOYEES TO PREVENT VIOLATIONS OF POST-EMPLOYMENT RESTRICTIONS AND PROTECT CONFIDENTIAL SUPERVISORY INFORMATION UNDER SECTION 36(10); AND (V) PROCESSES TO MONITOR THE USE OF EMAIL TO ADDRESS THE MISUSE OF CONFIDENTIAL MATERIAL UNDER SECTION 36(10); AND (C) PAID A CIVIL MONETARY PENALTY IN THE AMOUNT OF $50 MILLION ON NOVEMBER 9, 2015.

Allegations: ON DECEMBER 21, 2016, THE COMMODITY FUTURES TRADING COMMISSION ("CFTC") ENTERED AN ORDER INSTITUTING PROCEEDINGS PURSUANT TO SECTIONS 6(C) AND 6(D) OF THE COMMODITY EXCHANGE ACT, MAKING FINDINGS AND IMPOSING REMEDIAL SANCTIONS (THE "ORDER") AGAINST THE GOLDMAN SACHS GROUP, INC. ("GS GROUP") AND THE GOLDMAN, SACHS & CO. ("GS&CO.", AND TOGETHER WITH GS GROUP, "GOLDMAN") RELATING TO ATTEMPTED MANIPULATION OF THE U.S. DOLLAR INTERNATIONAL SWAPS AND DERIVATIVES ASSOCIATION FIX ("USD ISDAFIX"), AN INTEREST RATE BENCHMARK. SPECIFICALLY, THE CFTC FOUND THAT, FROM JANUARY 2007 THROUGH MARCH 2012, CERTAIN TRADERS ON GS&CO.'S INTEREST RATE PRODUCTS TRADING DESKS SUBMITTED BIDS AND OFFERS, AND EXECUTED TRADES, THAT WERE DESIGNED TO ATTEMPT TO MANIPULATE THE USD ISDAFIX. IN ADDITION, THE CFTC FOUND THAT THESE TRADERS ATTEMPTED TO AFFECT THE RATE AT WHICH USD ISDAFIX WAS SET BY MAKING FALSE, MISLEADING, OR KNOWINGLY INACCURATE SUBMISSIONS TO CERTAIN SWAPS BROKERS FOR INCLUSION IN THE CALCULATION OF THE DAILY RATES. THE ORDER ALSO STATES THAT THE TRADERS SUBMITTED ORAL AND WRITTEN REQUESTS FOR CERTAIN RATES TO BE SUBMITTED, WHICH WOULD BENEFIT GS&CO.'S TRADING POSITIONS. THE CFTC FOUND THAT GOLDMAN VIOLATED COMMODITY EXCHANGE ACT SECTIONS 6(C), 6(D), AND 9(A)(2), 7 U.S.C. §§ 9, 13B, 13(A)(2) (2006), AND FOR CONDUCT OCCURRING ON OR AFTER AUGUST 15, 2011, SECTIONS 6(C)(1), 6(C)(1)(A), 6(C)(3), 6(D), AND 9(A)(2), 7 U.S.C. §§ 9(1), 9(1)(A), 9(3), 13B, 13(A)(2) (2012), AND CFTC REGULATIONS 180.1(A) AND 180.2, 17 C.F.R. §§ 180.1(A), 180.2 (2015). Status: Final Sanction Detail: THE ORDER REQUIRED GOLDMAN TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $120 MILLION, WHICH GS&CO. PAID DECEMBER 28, 2016. Summary: WITHOUT ADMITTING OR DENYING THE VIOLATIONS, GOLDMAN CONSENTED TO THE ENTRY OF THE ORDER ON DECEMBER 21, 2016 BY THE CFTC, PURSUANT TO WHICH GOLDMAN: (A) SHALL CEASE AND DESIST FROM VIOLATING COMMODITY EXCHANGE ACT SECTIONS 6(C)(1), 6(C)(1)(A), 6(C)(3), 6(D), AND 9(A)(2), 7 U.S.C. §§ 9(1), 9(1)(A), 9(3), 13B, 13(A)(2) (2012), AND CFTC REGULATIONS 180.1(A) AND 180.2, 17 C.F.R. §§ 180.1(A), 180.2 (2015); (B) PAY A CIVIL MONETARY PENALTY OF $120 MILLION, WHICH GS&CO. PAID ON DECEMBER 28, 2016; AND (C) COMPLY WITH THE UNDERTAKINGS SET FORTH IN THE ORDER, INCLUDING PROVIDING A REPORT TO THE CFTC WITHIN 120 DAYS OF THE ORDER, ADDRESSING REMEDIATION EFFORTS BOTH PRIOR TO AND SINCE THE ENTRY OF THE ORDER, AND PROVIDING AN ADDITIONAL REPORT TO THE CFTC, NO LATER THAN 365 DAYS OF THE ENTRY OF THE ORDER, EXPLAINING HOW IT HAS COMPLIED WITH THE UNDERTAKINGS SET FORTH IN THE ORDER.

Allegations: ON OCTOBER 22, 2020, THE GOLDMAN SACHS GROUP, 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 GS GROUP FAILED TO REASONABLY MAINTAIN A SUFFICIENT SYSTEM OF INTERNAL ACCOUNTING CONTROLS BETWEEN 2012 AND 2015 WITH RESPECT TO THE PROCESS BY WHICH IT REVIEWED AND APPROVED THE COMMITMENT OF FIRM CAPITAL IN LARGE, SIGNIFICANT AND COMPLEX TRANSITIONS, SUCH AS THE 1MALAYSIA DEVELOPMENT BERHAD ("1MDB") OFFERINGS, AND THAT DOCUMENTATION PREPARED IN CONNECTION WITH THE 1MDB TRANSACTIONS DID NOT ACCURATELY REFLECT CERTAIN ASPECTS OF THE BOND OFFERINGS, INCLUDING THE INVOLVEMENT OF A THIRD PARTY INTERMEDIARY IN THE OFFERINGS. Status: Final Sanction Detail: PURSUANT TO THE SEC ORDER, THE SEC REQUIRED GS GROUP. (I) TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $400,000,000 AND (II) TO PAY DISGORGEMENT OF $606,300,000, WITH DOLLAR-FOR-DOLLAR DISGORGEMENT CREDIT UP TO THAT AMOUNT BASED ON THE U.S. DOLLAR VALUE OF SIMILAR PAYMENTS MADE TO THE GOVERNMENT OF MALAYSIA AND 1MDB PURSUANT TO THE PARALLEL SETTLEMENT AGREEMENT ENTERED INTO BY GS GROUP ON AUGUST 18, 2020 (THE "SETTLEMENT AGREEMENT). Summary: GS GROUP PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $400,000,000 TO THE SEC AND DISGORGEMENT OF $606,300,000, WITH DOLLAR-FOR-DOLLAR DISGORGEMENT CREDIT UP TO THAT AMOUNT BASED ON THE U.S. DOLLAR VALUE OF SIMILAR PAYMENTS MADE PURSUANT TO THE SETTLEMENT AGREEMENT.

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.