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Goldman Sachs 1MDB FCPA resolution (2020)

Last checked: 22 October 2026 · Case records

Yes, in part. On 22 October 2020 The Goldman Sachs Group Inc. entered a deferred prosecution agreement with DOJ, and Goldman Sachs (Malaysia) Sdn. Bhd. pleaded guilty to conspiracy to violate the FCPA anti-bribery provisions 1. DOJ said Goldman would pay more than US$2.9 billion in a coordinated resolution 1. DOJ said "Goldman admitted" facts of the scheme 1. The SEC imposed a US$400 million penalty and the Federal Reserve a US$154 million fine 2,3.
Resolution type
DPA for the parent, guilty plea for the Malaysian subsidiary, SEC cease-and-desist order, Federal Reserve fine 1,2 3
Date
22 October 2020 1,2 3
Agencies
U.S. Department of Justice, SEC and Federal Reserve Board 1,2 3
Court
Eastern District of New York, assigned to Judge Margo K. Brodie 1
Total amount
More than US$2.9 billion, with over US$1.6 billion in payments to other authorities credited by DOJ 1
SEC
US$400 million civil penalty and US$606.3 million disgorgement, partly satisfied by payments to Malaysia and 1MDB 2
Federal Reserve
US$154 million fine 3
Statute
FCPA anti-bribery provisions (DOJ), plus FCPA books and records and internal accounting controls provisions (SEC) 1,2
Admission
DOJ states "Goldman admitted" facts of the scheme. The Malaysian unit pleaded guilty 1

What DOJ charged

DOJ announced the resolution on 22 October 2020 1. The Goldman Sachs Group Inc. entered a DPA in connection with a criminal information filed in the Eastern District of New York 1. Goldman Sachs (Malaysia) Sdn. Bhd. pleaded guilty in the same court to a one-count criminal information 1. The charge was conspiracy to violate the anti-bribery provisions of the FCPA 1.

DOJ said Goldman acted as underwriter on three bond deals for 1Malaysia Development Bhd. (1MDB) with a total value of about US$6.5 billion 1. DOJ said the co-conspirators allegedly paid bribes using more than US$2.7 billion in funds diverted from the bond offerings 1. It said more than US$1.6 billion in bribes went to Malaysian, 1MDB, IPIC and Aabar officials 1. DOJ said Goldman received about US$606 million in fees and revenue 1.

What Goldman admitted

The DOJ release introduces the admitted facts with the words "Goldman admitted today that, in order to effectuate the scheme" 1. It says Goldman admitted that its control functions "did not take reasonable steps" to keep a person the release names as Low out of the deals 1. A DOJ official is quoted saying the resolution "requires Goldman Sachs to admit wrongdoing" 1.

The guilty plea by the Malaysian subsidiary is a criminal conviction of that entity 1. The parent's DPA defers prosecution of the parent on the filed information 1.

Amounts and credit

DOJ said: "Goldman will pay a criminal penalty and disgorgement of over $2.9 billion" 1. DOJ said it would "credit over $1.6 billion in payments" made under parallel resolutions 1. Goldman reached separate resolutions with authorities in the United Kingdom, Singapore and Malaysia, according to DOJ 1. The DOJ release does not give the amount paid to each foreign authority 1.

DOJ gave Goldman partial cooperation credit 1. DOJ said Goldman did not receive full credit, as it "significantly delayed producing relevant evidence" 1. DOJ said the penalty reflected a 10 percent reduction off the bottom of the applicable US Sentencing Guidelines fine range 1.

The SEC and Federal Reserve actions

The SEC found violations of the anti-bribery, internal accounting controls and books and records provisions of the federal securities laws 2. Goldman agreed to a cease-and-desist order, a US$400 million civil penalty and US$606.3 million in disgorgement 2. The SEC said the disgorgement was satisfied in part by amounts Goldman paid to the Government of Malaysia and 1MDB 2. The SEC release does not state whether Goldman admitted or denied the SEC findings 2.

The Federal Reserve Board fined Goldman US$154 million on 22 October 2020 3. It found that "Goldman's transaction approval processes and internal controls failed to detect or prevent the scheme" 3. The Board required Goldman to improve oversight and due diligence of complex transactions and its anti-bribery compliance program 3.

Individuals and status

DOJ said Tim Leissner, former Southeast Asia Chairman, pleaded guilty to conspiring to launder money and violate the FCPA 1. Former managing director Ng Chong Hwa, known as Roger Ng, was charged with the same conspiracies 1. DOJ said the charges against him were allegations and he was presumed innocent, with trial then set for March 2021 1.

The DOJ release does not state the DPA term 1. This page does not report how the DPA ended, as no primary court or DOJ record of that step was reached.

Common questions

Did Goldman Sachs plead guilty over 1MDB?

Its Malaysian subsidiary pleaded guilty 1. The parent company entered a deferred prosecution agreement and, per DOJ, admitted facts of the scheme 1.

How much did Goldman pay?

DOJ said more than US$2.9 billion in a coordinated resolution, crediting over US$1.6 billion paid to other authorities 1.

What did the SEC order?

A US$400 million penalty and US$606.3 million in disgorgement 2.

How much money was diverted from 1MDB?

DOJ said more than US$2.7 billion in funds from the bond offerings was used to pay bribes or otherwise diverted 1.

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Sources

  1. U.S. Department of Justice: Goldman Sachs Charged in Foreign Bribery Case and Agrees to Pay Over $2.9 Billion (22 October 2020)
  2. U.S. Securities and Exchange Commission: SEC Charges Goldman Sachs With FCPA Violations, 2020-265 (22 October 2020)
  3. Board of Governors of the Federal Reserve System: Federal Reserve Board fines Goldman Sachs $154 million over 1MDB (22 October 2020)

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