X0405 TA-1/A 0000734700 XXXXXXXX 084-01100 true LIVE SEC GOLDMAN SACHS & CO. LLC /TA GOLDMAN SACHS & CO /TA 900050 71 S Wacker Drive Suite 1200 Chicago IL 60606 N 312-655-4400 N N Y DST Asset Manager Solutions, Inc./TA 084-00896 2000 Crown Colony Drive Quincy MA 02169 SS&C GIDS, Inc 084-00448 1055 Broadway St Kansas Ctiy MO 64105 N Corporation David Michael Solomon 04/15/2017 Managing Director, Manager NA true John Edward Waldron 12/15/2018 Managing Director, CEO, Manager NA true Denis Patrick Coleman III 01/15/2022 Managing Director, Manager NA true Ericka T Horan 02/15/2022 Managing Director, Manager NA true 12/01/2023 The Goldman Sachs Group, Inc. 04/15/2017 Class A Member E true Kathryn Helen Ruemmler 12/01/2023 Managing Director, CLO, Manager NA true N N Y Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org 02/27/2023 Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org GS GROUP UNITED STATES DISTRICT COURT - EASTERN DISTRICT OF NEW YORK - CR. NO. 20-438 MKB) 10/22/2020 U.S. Justice Department ON OCTOBER 22, 2020, GOLDMAN SACHS (MALAYSIA) SDN. BHD. ("GS MALAYSIA") PLED GUILTY TO ONE FELONY COUNT OF CONSPIRACY TO VIOLATE THE FOREIGN CORRUPT PRACTICES ACT OF 1977 (THE "FCPA"), TITLE 18, UNITED STATES CODE, SECTION 371, RELATED TO CORPORATE DEBT TRANSACTIONS. ON OCTOBER 22, 2020, GS MALAYSIA PLED GUILTY TO ONE COUNT OF CONSPIRACY TO COMMIT OFFENSES AGAINST THE UNITED STATES, IN VIOLATION OF THE FCPA, TITLE 18, UNITED STATES CODE, SECTION 371. PURSUANT TO THE PLEA AGREEMENT PRESENTED TO THE EASTERN DISTRICT OF NEW YORK ON OCTOBER 22, 2020 (THE "PLEA AGREEMENT"), GS MALAYSIA HAS AGREED TO (I) COOPERATE FULLY WITH THE DEPARTMENT OF JUSTICE AND THE UNITED STATES ATTORNEY'S OFFICE FOR THE EASTERN DISTRICT OF NEW YORK (COLLECTIVELY, THE "OFFICES"), OTHER DOMESTIC OR FOREIGN LAW ENFORCEMENT AND REGULATORY AUTHORITIES AND AGENCIES; (II) PROMPTLY REPORT ANY NEWLY LEARNED EVIDENCE OR ALLEGATIONS OF CONDUCT THAT MIGHT CONSTITUTE A VIOLATION OF THE MONEY LAUNDERING LAWS THAT INVOLVE ITS EMPLOYEES OR AGENTS; (III) PAY A $500,000 CRIMINAL FINE AS PART OF THE TOTAL CRIMINAL MONETARY PENALTY REQUIRED BY THE DEFERRED PROSECUTION AGREEMENT THE GOLDMAN SACHS GROUP, INC. ("GS GROUP") ENTERED INTO WITH THE OFFICES ON OCTOBER 22, 2020 ("DPA"); (IV) COMMIT NO FURTHER CRIMES; AND (V) TO WORK WITH GS GROUP IN FULFILLING ITS OBLIGATIONS UNDER THE DPA. ON OCTOBER 22, 2020, GS MALAYSIA PLED GUILTY TO ONE COUNT OF CONSPIRACY TO COMMIT OFFENSES AGAINST THE UNITED STATES, IN VIOLATION OF THE FCPA, TITLE 18, UNITED STATES CODE, SECTION 371. GS PAID A $500,000 CRIMINAL FINE AS PART OF THE TOTAL CRIMINAL MONETARY PENALTY REQUIRED BY THE DEFERRED PROSECUTION AGREEMENT THE GOLDMAN SACHS GROUP, INC. ("GS GROUP") ENTERED INTO WITH THE OFFICES ON OCTOBER 22, 2020 ("DPA"). Y Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org 02/27/2023 Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org GS GROUP UNITED STATES DISTRICT COURT - EASTERN DISTRICT OF NEW YORK - CR. NO. 20-438 10/22/2020 U.S. Justice Department ON OCTOBER 22, 2020, GOLDMAN SACHS (MALAYSIA) SDN. BHD. ("GS MALAYSIA") PLED GUILTY TO ONE FELONY COUNT OF CONSPIRACY TO VIOLATE THE FOREIGN CORRUPT PRACTICES ACT OF 1977 (THE "FCPA"), TITLE 18, UNITED STATES CODE, SECTION 371, RELATED TO CORPORATE DEBT TRANSACTIONS. ON OCTOBER 22, 2020, GS MALAYSIA PLED GUILTY TO ONE COUNT OF CONSPIRACY TO COMMIT OFFENSES AGAINST THE UNITED STATES, IN VIOLATION OF THE FCPA, TITLE 18, UNITED STATES CODE, SECTION 371. PURSUANT TO THE PLEA AGREEMENT PRESENTED TO THE EASTERN DISTRICT OF NEW YORK ON OCTOBER 22, 2020 (THE "PLEA AGREEMENT"), GS MALAYSIA HAS AGREED TO (I) COOPERATE FULLY WITH THE DEPARTMENT OF JUSTICE AND THE UNITED STATES ATTORNEY'S OFFICE FOR THE EASTERN DISTRICT OF NEW YORK (COLLECTIVELY, THE "OFFICES"), OTHER DOMESTIC OR FOREIGN LAW ENFORCEMENT AND REGULATORY AUTHORITIES AND AGENCIES; (II) PROMPTLY REPORT ANY NEWLY LEARNED EVIDENCE OR ALLEGATIONS OF CONDUCT THAT MIGHT CONSTITUTE A VIOLATION OF THE MONEY LAUNDERING LAWS THAT INVOLVE ITS EMPLOYEES OR AGENTS; (III) PAY A $500,000 CRIMINAL FINE AS PART OF THE TOTAL CRIMINAL MONETARY PENALTY REQUIRED BY THE DEFERRED PROSECUTION AGREEMENT THE GOLDMAN SACHS GROUP, INC. ("GS GROUP") ENTERED INTO WITH THE OFFICES ON OCTOBER 22, 2020 ("DPA"); (IV) COMMIT NO FURTHER CRIMES; AND (V) TO WORK WITH GS GROUP IN FULFILLING ITS OBLIGATIONS UNDER THE DPA. ON OCTOBER 22, 2020, GS MALAYSIA PLED GUILTY TO ONE COUNT OF CONSPIRACY TO COMMIT OFFENSES AGAINST THE UNITED STATES, IN VIOLATION OF THE FCPA, TITLE 18, UNITED STATES CODE, SECTION 371. GS PAID A $500,000 CRIMINAL FINE AS PART OF THE TOTAL CRIMINAL MONETARY PENALTY REQUIRED BY THE DEFERRED PROSECUTION AGREEMENT THE GOLDMAN SACHS GROUP, INC. ("GS GROUP") ENTERED INTO WITH THE OFFICES ON OCTOBER 22, 2020 ("DPA"). GSI Action imposed following inquiry/investigation related to 1MDB 12/17/2018 THE MALAYSIAN ATTORNEY GENERAL THE MALAYSIAN ATTORNEY GENERAL ("ATTORNEY GENERAL") HAS CHARGED GOLDMAN SACHS INTERNATIONAL ("GSI"), AS BOOKRUNNER AND ARRANGER OF THREE OFFERINGS OF DEBT SECURITIES OF 1MALAYSIA DEVELOPMENT BERHAD, CONDUCTED IN 2012 AND 2013, FOR ALLEGED DISCLOSURE DEFICIENCIES IN THE OFFERING DOCUMENTS, A FELONY. THE ATTORNEY GENERAL HAS CHARGED GOLDMAN SACHS (ASIA) L.L.C. AND GOLDMAN SACHS (SINGAPORE) PTE. FOR HAVING ABETTED GSI IN ITS ALLEGED ACTIVITIES. THE ATTORNEY GENERAL HAS STATED THAT IT WILL SEEK CRIMINAL FINES IN EXCESS OF $2.7 BILLION AND THE $600 MILLION IN FEES GSI RECEIVED IN THE DEBT OFFERINGS. THE CRIMINAL OFFENSES ARE THE EQUIVALENT OF FELONY CHARGES. ON SEPTEMBER 4, 2020, GOLDMAN SACHS INTERNATIONAL, GOLDMAN SACHS (ASIA) LLP, AND GOLDMAN SACHS (SINGAPORE) PTE. WERE ACQUITTED AND THE CHARGES AGAINST THEM WERE DISCHARGED, AND THE PROCEEDINGS AGAINST THE CURRENT AND FORMER DIRECTORS WERE DISCONTINUED. ON SEPTEMBER 4, 2020, GOLDMAN SACHS INTERNATIONAL, GOLDMAN SACHS (ASIA) LLP, AND GOLDMAN SACHS (SINGAPORE) PTE. WERE ACQUITTED AND THE CHARGES AGAINST THEM WERE DISCHARGED, AND THE PROCEEDINGS AGAINST THE CURRENT AND FORMER DIRECTORS WERE DISCONTINUED. GS (Asia) L.L.C. Action imposed following inquiry/investigation related to 1MDB 12/17/2018 THE MALAYSIAN ATTORNEY GENERAL THE MALAYSIAN ATTORNEY GENERAL ("ATTORNEY GENERAL") HAS CHARGED GOLDMAN SACHS INTERNATIONAL ("GSI"), AS BOOKRUNNER AND ARRANGER OF THREE OFFERINGS OF DEBT SECURITIES OF 1MALAYSIA DEVELOPMENT BERHAD, CONDUCTED IN 2012 AND 2013, FOR ALLEGED DISCLOSURE DEFICIENCIES IN THE OFFERING DOCUMENTS, A FELONY. THE ATTORNEY GENERAL HAS CHARGED GOLDMAN SACHS (ASIA) L.L.C. AND GOLDMAN SACHS (SINGAPORE) PTE. FOR HAVING ABETTED GSI IN ITS ALLEGED ACTIVITIES. THE ATTORNEY GENERAL HAS STATED THAT IT WILL SEEK CRIMINAL FINES IN EXCESS OF $2.7 BILLION AND THE $600 MILLION IN FEES GSI RECEIVED IN THE DEBT OFFERINGS. THE CRIMINAL OFFENSES ARE THE EQUIVALENT OF FELONY CHARGES. ON SEPTEMBER 4, 2020, GOLDMAN SACHS INTERNATIONAL, GOLDMAN SACHS (ASIA) LLP, AND GOLDMAN SACHS (SINGAPORE) PTE. WERE ACQUITTED AND THE CHARGES AGAINST THEM WERE DISCHARGED, AND THE PROCEEDINGS AGAINST THE CURRENT AND FORMER DIRECTORS WERE DISCONTINUED. ON SEPTEMBER 4, 2020, GOLDMAN SACHS INTERNATIONAL, GOLDMAN SACHS (ASIA) LLP, AND GOLDMAN SACHS (SINGAPORE) PTE. WERE ACQUITTED AND THE CHARGES AGAINST THEM WERE DISCHARGED, AND THE PROCEEDINGS AGAINST THE CURRENT AND FORMER DIRECTORS WERE DISCONTINUED. GS (Singapore) PTE Action imposed following inquiry/investigation related to 1MDB 12/17/2018 THE MALAYSIAN ATTORNEY GENERAL THE MALAYSIAN ATTORNEY GENERAL ("ATTORNEY GENERAL") HAS CHARGED GOLDMAN SACHS INTERNATIONAL ("GSI"), AS BOOKRUNNER AND ARRANGER OF THREE OFFERINGS OF DEBT SECURITIES OF 1MALAYSIA DEVELOPMENT BERHAD, CONDUCTED IN 2012 AND 2013, FOR ALLEGED DISCLOSURE DEFICIENCIES IN THE OFFERING DOCUMENTS, A FELONY. THE ATTORNEY GENERAL HAS CHARGED GOLDMAN SACHS (ASIA) L.L.C. AND GOLDMAN SACHS (SINGAPORE) PTE. FOR HAVING ABETTED GSI IN ITS ALLEGED ACTIVITIES. THE ATTORNEY GENERAL HAS STATED THAT IT WILL SEEK CRIMINAL FINES IN EXCESS OF $2.7 BILLION AND THE $600 MILLION IN FEES GSI RECEIVED IN THE DEBT OFFERINGS. THE CRIMINAL OFFENSES ARE THE EQUIVALENT OF FELONY CHARGES. ON SEPTEMBER 4, 2020, GOLDMAN SACHS INTERNATIONAL, GOLDMAN SACHS (ASIA) LLP, AND GOLDMAN SACHS (SINGAPORE) PTE. WERE ACQUITTED AND THE CHARGES AGAINST THEM WERE DISCHARGED, AND THE PROCEEDINGS AGAINST THE CURRENT AND FORMER DIRECTORS WERE DISCONTINUED. ON SEPTEMBER 4, 2020, GOLDMAN SACHS INTERNATIONAL, GOLDMAN SACHS (ASIA) LLP, AND GOLDMAN SACHS (SINGAPORE) PTE. WERE ACQUITTED AND THE CHARGES AGAINST THEM WERE DISCHARGED, AND THE PROCEEDINGS AGAINST THE CURRENT AND FORMER DIRECTORS WERE DISCONTINUED. Y Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org 02/27/2023 Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Y Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org 02/27/2023 Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Y Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org 02/27/2023 Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Y GOLDMAN SACHS & CO. LLC IN THE MATTER OF: GOLDMAN SACHS & CO. LLC CFTC DOCKET NO. 23-09 04/10/2023 THE COMMODITY FUTURES TRADING COMMISSION 1155 21ST STREET N.W., WASHINGTON, DC 20581 ON APRIL 10, 2023, THE COMMODITY FUTURES TRADING COMMISSION ("COMMISSION" OR "CFTC") ISSUED AN ORDER AGAINST GOLDMAN SACHS & CO. LLC ("GSCO"), ACCEPTING AN OFFER OF SETTLEMENT SUBMITTED BY GSCO. THE CFTC FOUND THAT FROM IN OR ABOUT APRIL 2015 TO AT LEAST SEPTEMBER 2016 ("RELEVANT PERIOD"), GSCO VIOLATED SECTION 4S(H)(1) OF THE COMMODITY EXCHANGE ACT ("ACT"), 7 U.S.C. SECTION 6S(H)(1), AND SECTIONS 23.431 AND 23.433, 17 C.F.R. SECTIONS 23.431, 23.433, OF THE COMMISSION REGULATIONS ("REGULATIONS") IN CONNECTION WITH CERTAIN SWAP TRANSACTIONS BY FAILING TO PROVIDE OR POVIDING INACCURATE PRE-TRADE-MID-MARKET-MARKS ("PTMMM") TO US-BASED COUNTERPARTIES AND BY FAILING TO COMMUNICATE IN A FAIR AND BALANCED MANNER BASED ON PRINCIPLES OF FAIR DEALING AND GOOD FAITH. THE SWAPS IN QUESTION WERE EQUITY-INDEX SWAPS IN WHICH THE EQUITY LEG OF THE SWAP WAS STRUCK ON THE SAME DAY AS THE OTHER MATERIAL TERMS OF THE SWAP WERE AGREED UPON ("SAME-DAY SWAPS"), RATHER THAN THE DAY AFTER THE DATE OF AGREEMENT. GSCO ADMITTED THAT FOR NEARLY ALL SAME-DAY SWAPS EXECUTED IN 2015 AND 2016 IT EITHER FAILED TO DISCLOSE A PTMMM OR FAILED TO DISCLOSE AND ACCURATE PTMMM. GSCO NEITHER ADMITTED NOR DENIED THE REST OF THE CFTC'S FINDINGS. THE CFTC ORDERED THAT GSCO CEASE AND DESIST AND PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $15,000,000. THE FINE WAS PAID ON APRIL 20, 2023. GOLDMAN SACHS ASSET MANAGEMENT, L.P. 3-21245 11/22/2022 SECURITIES AND EXCHANGE COMMISSION ("SEC") ON NOVEMBER 22, 2022, GOLDMAN SACHS ASSET MANAGEMENT, L.P. ("GSAMLP") ENTERED INTO A SETTLEMENT WITH THE SECURITIES AND EXCHANGE COMMISSION ("SEC") REGARDING GSAMLP'S POLICIES AND PROCEDURES WITH RESPECT TO ENVIRONMENTAL, SOCIAL AND GOVERNANCE INVESTMENTS. THE SEC FOUND THAT GSAMLP DID NOT ADOPT WRITTEN POLICIES AND PROCEDURES GOVERNING THE EVALUATION OF ESG FACTORS UNTIL SOMETIME AFTER TWO ESG MUTUAL FUNDS WERE INTRODUCED AND A SOCIALLY-RESPONSIBLE SEPARATE ACCOUNT STRATEGY WAS REBRANDED AS ESG, AND THAT, ONCE SUCH POLICIES AND PROCEDURES WERE ADOPTED, THEY WERE NOT CONSISTENTLY FOLLOWED PRIOR TO FEBRUARY 2020. GSAMLP WAS CENSURED AND ORDERED TO CEASE AND DESIST FROM VIOLATING SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 PROMULGATED THEREUNDER. GSAMLP AGREED TO PAY A PENALTY OF $4 MILLION. GOLDMAN SACHS & CO. LLC 3-21167 09/27/2022 SECURITIES AND EXCHANGE COMMISSION ("SEC") ON SEPTEMBER 27, 2022, THE SEC INSTITUTED PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS AGAINST GOLDMAN SACHS & CO. ("GSCO") PURSUANT TO SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT"), BASED ON THEIR DETERMINATION THAT FEDERAL SECURITIES LAWS WERE VIOLATED. GSCO ADMITTED AND ACCEPTED THE SEC'S JURISDICTION AND THE SUBJECT MATTER OF THESE PROCEEDINGS AND SUBMITTED AN OFFER OF SETTLEMENT ("OFFER") WHICH THE SEC ACCEPTED. THE SEC FOUND THAT FROM JANUARY 2018 TO SEPTEMBER 2021, GSCO EMPLOYEES USED THEIR PERSONAL DEVICES TO COMMUNICATE BOTH INTERNALLY AND EXTERNALLY BY PERSONAL TEXT MESSAGES OR OTHER TEXT MESSAGING PLATFORMS SUCH AS WHATSAPP ("OFF-CHANNEL COMMUNICATIONS"), IN RELATION TO THE BUSINESS OF THE BROKER-DEALER OPERATED BY GSCO. GSCO'S FAILURE TO MAINTAIN OR PRESERVE THE SUBSTANTIAL MAJORITY OF THESE WRITTEN COMMUNICATIONS WAS FIRM-WIDE, AND INVOLVED EMPLOYEES AT ALL LEVELS OF AUTHORITY. AS A RESULT, GSCO VIOLATED SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4(B)(4). THE SEC FOUND GSCO'S FAILURE TO IMPLEMENT ITS POLICIES AND PROCEDURES THAT PROHIBIT SUCH OFF-CHANNEL COMMUNICATIONS LED TO ITS FAILURE TO SUPERVISE ITS EMPLOYEES WITHIN THE MEANING OF SECTION 15(B)(4)(E) OF THE EXCHANGE ACT. THE SEC UNCOVERED GSCO'S MISCONDUCT AFTER COMMENCING A RISK-BASED INITIATIVE TO INVESTIGATE THE USE OF OFF-CHANNEL AND UNPRESERVED COMMUNICATIONS AT BROKER-DEALERS. AS A RESULT, GSCO HAS INITIATED A REVIEW OF ITS RECORDKEEPING FAILURES AND BEGUN A PROGRAM OF REMEDIATION. THE SEC ORDERED THAT GSCO CEASE AND DESIST; IS CENSURED; COMPLIES WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER; AND PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $125,000,000. THE FINE WAS PAID ON OCTOBER 14, 2022. GOLDMAN SACHS GROUP, INC. (GS GROUP) 3-20132 10/22/2020 THE SECURITIES AND EXCHANGE COMMISSION, United States 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. 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. GOLDMANS SACHS & CO. LLC (GSCO) 3-17053 01/14/2016 SEC, United States THE U.S. SECURITIES AND EXCHANGE COMMISSION (THE "SEC") ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") VIOLATED REGULATION SHO UNDER THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") BY IMPROPERLY RELYING ON THE FIRM'S AUTOMATED LOCATE FUNCTION IN THE ORDER MANAGEMENT SYSTEM WITHOUT HAVING CONFIRMED THE AVAILABILITY OF THE SECURITIES TO BE LOCATED. IN ADDITION, THE SEC ALLEGED THAT FIRM EMPLOYEES DID NOT PROVIDE SUFFICIENT AND ACCURATE INFORMATION WITH RESPECT TO THESE LOCATES IN THE FIRM'S LOCATE LOG, WHICH MUST REFLECT THE BASIS UPON WHICH THE FIRM PROVIDED THE LOCATES. THE SEC ALLEGED THAT THE FIRM WILLFULLY VIOLATED RULE 203(B)(1) OF REGULATION SHO AND SECTION 17(A) OF THE EXCHANGE ACT. WITHOUT ADMITTING OR DENYING THE VIOLATIONS, THE FIRM CONSENTED TO THE ENTRY BY THE SEC OF AN ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS, PURSUANT TO SECTIONS 15(B) AND 21C OF THE EXCHANGE ACT, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER (RELEASE NO. 34-76899, JAN. 14, 2016). ALSO PURSUANT TO THE ORDER, THE FIRM WAS CENSURED AND PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $15,000,000 ON JANUARY 20, 2016. GOLDMANS SACHS & CO. LLC (GSCO) 3-16665 06/30/2015 SEC, United States THE U.S. SECURITIES AND EXCHANGE COMMISSION (THE "SEC") HAS ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") DID NOT HAVE A SYSTEM OF RISK MANAGEMENT CONTROLS AND SUPERVISORY PROCEDURES REASONABLY DESIGNED TO MANAGE THE FINANCIAL, REGULATORY, AND OTHER RISKS OF MARKET ACCESS IN RELATION TO ITS LISTED EQUITY OPTIONS BUSINESS, WHICH CONTRIBUTED TO THE ENTRY OF ERRONEOUS ELECTRONIC OPTIONS ORDERS ON MULTIPLE OPTIONS EXCHANGES ON AUGUST 20, 2013. THE SEC ALLEGED THAT THE FIRM WILLFULLY VIOLATED SECTION 15(C)(3) OF THE EXCHANGE ACT AND RULE 15C3-5 THEREUNDER IN RELATION TO ITS CONTROLS AND SUPERVISORY PROCEDURES ADDRESSING (I) THE ENTRY OF ORDERS THAT EXCEED APPROPRIATE PRE-SET CREDIT OR CAPITAL THRESHOLDS; (II) THE ENTRY OF ERRONEOUS ORDERS THAT EXCEED APPROPRIATE PRICE OR SIZE PARAMETERS OR THAT INDICATE DUPLICATIVE ORDERS; AND (III) THE MANAGEMENT OF SOFTWARE CHANGES THAT IMPACT ORDER FLOW. WITHOUT ADMITTING OR DENYING THE VIOLATIONS, THE FIRM CONSENTED TO THE ENTRY OF AN ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS, PURSUANT TO SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER ON JUNE 30, 2015 BY THE SEC PURSUANT TO WHICH THE FIRM: (I) SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 15(C)(3) OF THE EXCHANGE ACT AND RULE 15C3-5 THEREUNDER; (II) IS CENSURED; AND (III) PAID A TOTAL CIVIL MONEY PENALTY OF $7 MILLION ON JUNE 30, 2015. GOLDMANS SACHS & CO. LLC (GSCO) 3-16619 06/18/2015 SEC, United States THE U.S. SECURITIES AND EXCHANGE COMMISSION (THE "SEC") HAS ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") CONDUCTED INADEQUATE DUE DILIGENCE IN CERTAIN OFFERINGS AND, AS A RESULT, FAILED TO FORM A REASONABLE BASIS FOR BELIEVING THE TRUTHFULNESS OF CERTAIN MATERIAL REPRESENTATIONS IN OFFICIAL STATEMENTS ISSUED IN CONNECTION WITH THOSE OFFERINGS. THIS RESULTED IN THE FIRM OFFERING AND SELLING MUNICIPAL SECURITIES ON THE BASIS OF MATERIALLY MISLEADING DISCLOSURE DOCUMENTS. THE SEC ALLEGED THAT THE FIRM WILLFULLY VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT OF 1933. THE VIOLATIONS DISCUSSED IN THE ORDER WERE SELF-REPORTED BY THE FIRM TO THE SEC PURSUANT TO THE DIVISION OF ENFORCEMENT'S MUNICIPALITIES CONTINUING DISCLOSURE COOPERATION INITIATIVE. WITHOUT ADMITTING OR DENYING THE VIOLATIONS, THE FIRM CONSENTED TO THE ENTRY OF AN ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS, PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933 AND SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER ON JUNE 18, 2015 BY THE SEC PURSUANT TO WHICH THE FIRM: (I) SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A)(2) OF THE SECURITIES ACT OF 1933; (II) PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $500,000 ON JUNE 25, 2015; AND (III) SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE ORDER. GOLDMANS SACHS & CO. LLC (GSCO) 20-10 11/26/2019 THE COMMODITY FUTURES TRADING COMMISSION, United States ON NOVEMBER 26, 2019, THE COMMODITY FUTURES TRADING COMMISSION ("CFTC") ISSUED AN ORDER REQUIRING GOLDMAN SACHS & CO. LLC ("GOLDMAN") TO PAY A $1,000,000 CIVIL MONETARY PENALTY AND TO CEASE AND DESIST FROM FURTHER VIOLATIONS OF CERTAIN CFTC REGULATIONS. DURING AN INVESTIGATION BY THE CFTC'S DIVISION OF ENFORCEMENT ("DIVISION"), THE DIVISION REQUESTED THAT GOLDMAN PRODUCE CERTAIN AUDIO RECORDINGS FROM JANUARY 2014. GOLDMAN WAS UNABLE TO PRODUCE MANY OF THE RECORDINGS REQUESTED DUE TO A MALFUNCTION WHICH OCCURRED DURING THE COURSE OF A SYSTEM UPGRADE WHICH AFFECTED RECORDINGS OF THE PHONE LINES OF A TRADING AND SALES DESK IN ONE OF GOLDMAN'S OFFICES FOR TWENTY CALENDAR DAYS IN JANUARY AND FEBRUARY 2014. GOLDMAN'S INABILITY TO PRODUCE THESE RECORDINGS IMPEDED THE DIVISION'S ONGOING INVESTIGATION, BECAUSE THE DIVISION WAS UNABLE TO OBTAIN THE INFORMATION THAT SHOULD HAVE BEEN CAPTURED IN MANY OF THE RECORDINGS THROUGH ANY OTHER MEANS. BASED ON THE FOREGOING, THE CFTC FOUND THAT GOLDMAN VIOLATED REGULATIONS 23.202(A)(1), (B)(1), AND 23.203(B)(2), 17 C.F.R. 23.202(A)(1), (B)(1) (2018), 23.203(B)(2) (2017). GOLDMAN SUBMITTED AN OFFER OF SETTLEMENT, WHICH THE CFTC ACCEPTED. WITHOUT ADMITTING OR DENYING THE VIOLATIONS, GOLDMAN CONSENTED TO THE ENTRY OF THE ORDER BY THE CFTC, PURSUANT TO WHICH GOLDMAN: (A) SHALL CEASE AND DESIST FROM VIOLATING REGULATIONS 23.202(A)(1), (B)(1), AND 1.31(B)(2), 17 C.F.R. 23.202(A)(1), (B)(1), 1.31(B)(2) (2018); AND (B) PAY A CIVIL MONETARY PENALTY IN THE AMOUNT $1,000,000. IN ADDITION, AS PART OF THE SETTLEMENT, GOLDMAN REPRESENTED TO THE CFTC THAT IT HAD MADE CERTAIN CHANGES IN ITS SURVEILLANCE PROGRAMS. THE FINE WAS PAID BY GOLDMAN BY WIRE ON DECEMBER 20, 2019. GOLDMAN SACHS & CO. LLC (GSCO) 23-09 04/10/2023 COMMODITY FUTURES TRADING COMMISSION, United States ON APRIL 10, 2023, THE COMMODITY FUTURES TRADING COMMISSION ("COMMISSION" OR "CFTC") ISSUED AN ORDER AGAINST GOLDMAN SACHS & CO. LLC ("GSCO"), ACCEPTING AN OFFER OF SETTLEMENT SUBMITTED BY GSCO. THE CFTC FOUND THAT FROM IN OR ABOUT APRIL 2015 TO AT LEAST SEPTEMBER 2016 ("RELEVANT PERIOD"), GSCO VIOLATED SECTION 4S(H)(1) OF THE COMMODITY EXCHANGE ACT ("ACT"), 7 U.S.C. 6S(H)(1), AND SECTIONS 23.431 AND 23.433, 17 C.F.R. 23.431, 23.433, OF THE COMMISSION REGULATIONS ("REGULATIONS") IN CONNECTION WITH CERTAIN SWAP TRANSACTIONS BY FAILING TO PROVIDE OR PROVIDING INACCURATE PRE-TRADE-MID-MARKET-MARKS ("PTMMM") TO US-BASED COUNTERPARTIES AND BY FAILING TO COMMUNICATE IN A FAIR AND BALANCED MANNER BASED ON PRINCIPLES OF FAIR DEALING AND GOOD FAITH. THE SWAPS IN QUESTION WERE EQUITY-INDEX SWAPS IN WHICH THE EQUITY LEG OF THE SWAP WAS STRUCK ON THE SAME DAY AS THE OTHER MATERIAL TERMS OF THE SWAP WERE AGREED UPON ("SAME-DAY SWAPS"), RATHER THAN THE DAY AFTER THE DATE OF AGREEMENT. GSCO ADMITTED THAT FOR NEARLY ALL SAME-DAY SWAPS EXECUTED IN 2015 AND 2016 IT EITHER FAILED TO DISCLOSE A PTMMM OR FAILED TO DISCLOSE AN ACCURATE PTMMM. GSCO NETIHER ADMITTED NOR DENIED THE REST OF THE CFTC'S FINDINGS. THE CFTC ORDERED THAT GSCO CEASE AND DESIST AND PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $15,000,000. THE FINE WAS PAID ON APRIL 20, 2023. GOLDMAN SACHS GROUP, INC. (GS GROUP) 17-03 12/21/2016 COMMODITY FUTURES TRADING COMMISSION 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 GOLDMAN, SACHS & CO. (THE "FIRM", 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 THE FIRM'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 THE FIRM'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). WITHOUT ADMITTING OR DENYING THE VIOLATIONS, GOLDMAN CONSENTED TO THE ENTRY OF THE ORDER ON DECEMBER 21, 2016 BY THE CFTC. GOLDMAN SACHS PAID A CIVIL MONETARY PENALTY OF $120 MILLION, WHICH THE FIRM PAID ON DECEMBER 28, 2016. GOLDMAN SACHS & CO. LLC (GSCO) 22-40 09/27/2022 COMMODITY FUTURES TRADING COMMISSION (CFTC) ON SEPTEMBER 27, 2022, THE COMMODITY FUTURES TRADING COMMISSION ("CFTC") ALLEGED THEY HAD REASON TO BELIEVE THAT FROM AT LEAST JANUARY 2016 TO THE PRESENT ("RELEVANT PERIOD"), GOLDMAN SACHS & CO. LLC ("GSCO" ) VIOLATED SECTIONS 4G, 4S(F)(1)(C), 4S(G)(1) AND (3), AND 4S(H)(1)(B) OF THE COMMODITY EXCHANGE ACT ("ACT"), 7 U.S.C. 6G, 6S(F)(1)(C), 6S(G)(1), (3), 6S(H)(1)(B), AND CFTC REGULATIONS ("REGULATIONS") 1.31, 1.35, 23.201(A), 23.202(A)(1) AND (B)(1), 23.602(A), AND 166.3, 17 C.F.R. 1.31, 1.35, 23.201(A), 23.202(A)(1), (B)(1), 23.602(A), 166.3 (2021). AS A RESULT, THE CFTC DEEMED IT APPROPRIATE TO INSTITUTE PUBLIC ADMINISTRATIVE PROCEEDINGS TO DETERMINE WHETHER GSCO ENGAGED IN THE LISTED VIOLATIONS AND DETERMINE WHETHER ANY ORDER SHOULD BE ISSUED IMPOSING REMEDIAL SANCTIONS. GSCO ADMITTED AND ACKNOWLEDGED THEIR CONDUCT VIOLATED THE ACT AND SUBMITTED AN OFFER OF SETTLEMENT ("OFFER") WHICH THE CFTC ACCEPTED. THE CFTC BECAME AWARE OF GSCO EMPLOYEE USE OF UNAPPROVED COMMUNICATION METHODS FOR BUSINESS CONVERSATIONS DURING THE COURSE OF AN INVESTIGATION INTO CERTAIN OF GSCO'S TRADING. AS A RESULT, THE CFTC SUBPOENAED THE RECORDS OF FOUR GSCO TRADERS. THE COMMUNICATIONS PRODUCED BY THE TRADERS IN RESPONSE TO THOSE SUBPOENAS INDICATED THAT THE TRADERS FREQUENTLY USED NON-GSCO-APPROVED METHODS OF COMMUNICATION, INCLUDING TEXT AND WHATSAPP ("OFF-CHANNEL COMMUNICATIONS"), TO COMMUNICATE WITH OTHER GSCO TRADERS AND WITH BROKERS. THE COMMUNICATIONS ALSO REVEALED THAT EMPLOYEES AT ALL LEVELS OF AUTHORITY WERE INVOLVED IN THE USE OF THESE OFF-CHANNEL COMMUNICATIONS, WHICH WERE SENT AND RECEIVED BY GSCO EMPLOYEES RELATING TO GSCO'S BUSINESS AS A CFTC REGISTRANT, WHICH WERE REQUIRED TO BE MAINTAINED UNDER CFTC-MANDATED RECORDKEEPING REQUIREMENTS. THESE RECORDS WERE GENERALLY NOT MAINTAINED AND PRESERVED BY GSCO, AND GSCO WOULD NOT HAVE BEEN ABLE TO FURNISH SUCH COMMUNICATIONS PROMPTLY TO A CFTC REPRESENTATIVE IF AND WHEN REQUESTED, WHICH VIOLATES THE ACT. IN ADDITION, THE WIDESPREAD USE OF UNAUTHORIZED OFF-CHANNEL COMMUNICATIONS BY GSCO'S EMPLOYEES TO CONDUCT FIRM BUSINESS VIOLATED GSCO'S OWN POLICIES AND PROCEDURES, WHICH PROHIBITED SUCH COMMUNICATIONS. THEREFORE, THE CFTC FOUND GSCO ALSO FAILED TO IMPLEMENT A DILIGENT SUPERVISORY SYSTEM TO ENSURE COMPLIANCE WITH THE CFTC'S RECORDKEEPING REQUIREMENTS AND THE FIRM'S OWN POLICIES AND PROCEDURES, AND BECAUSE THE FIRM FAILED TO MAINTAIN CFTC-REQUIRED RECORDS, GSCO FAILED TO DILIGENTLY SUPERVISE MATTERS RELATED TO ITS BUSINESS AS A CFTC REGISTRANT, IN VIOLATION OF THE ACT. THE CFTC ORDERED THAT GSCO CEASE AND DESIST; IS CENSURED; COMPLIES WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER; AND PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $75,000,000. THE FINE WAS PAID ON OCTOBER 14, 2022. GOLDMAN SACHS & CO. LLC 3-21700 09/22/2023 SECURITIES AND EXCHANGE COMMISSION, United States ON SEPTEMBER 22, 2023, THE SECURITIES AND EXCHANGE COMMISSION ("SEC" OR "COMMISSION") INSTITUTED PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS AGAINST GOLDMAN SACHS & CO. ("GSCO" OR "THE FIRM") PURSUANT TO SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 AND SECTION 203(E) OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT"), BASED ON THEIR DETERMINATION THAT FEDERAL SECURITIES LAWS WERE VIOLATED. GSCO ADMITTED THE SEC'S JURISDICTION AND THE FACTS SET FORTH IN THE ORDER AND SUBMITTED AN OFFER OF SETTLEMENT ("OFFER"), WHICH THE SEC ACCEPTED. THE SEC FOUND THAT FROM AT LEAST NOVEMBER 2012 THROUGH OCTOBER 2022, AT LEAST 22,192 OUT OF 52,147 OF THE ELECTRONIC BLUE SHEETS ("EBS") SUBMITTED BY GSCO INCLUDED INACCURATE OR INCOMPLETE INFORMATION, RESULTING IN THE MISREPORTING OF TRADE DATA. AS A RESULT, THE FIRM VIOLATED THE RECORDKEEPING AND REPORTING REQUIREMENTS OF SECTION 17(A)(1) OF THE EXCHANGE ACT AND RULES 17A-4(J) AND 17A-25. GSCO INITIATED A VOLUNTARY REMEDIATION PROGRAM AND IS RESUBMITTING CORRECTED EBS TO THE COMMISSION. THE SEC ORDERED THAT GSCO CEASE AND DESIST; IS CENSURED; AND PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $6,000,000. THE FINE WAS PAID ON OCTOBER 3, 2023. GOLDMAN SACHS & CO. LLC 23-59 09/29/2023 COMMODITY FUTURES TRADING COMMISSION, United States ON SEPTEMBER 29, 2023, THE COMMODITY FUTURES TRADING COMMISSION ("COMMISSION" OR "CFTC") ISSUED AN ORDER AGAINST GOLDMAN SACHS & CO. LLC ("GSCO"), ACCEPTING AN OFFER OF SETTLEMENT SUBMITTED BY GSCO, IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE COMMISSION'S FINDINGS. THE CFTC FOUND THAT FROM DECEMBER 31, 2012 TO THE PRESENT, GSCO VIOLATED SECTIONS 2(A)(13)(F) AND (G) AND 4S(H)(1) OF THE COMMODITY EXCHANGE ACT ("CEA"), 7 U.S.C. 2(A)(13)(F), (G), 6S(H)(1), AND COMMISSION REGULATIONS 23.431(A)(3)(I), 23.602(A), 43.3(A)(1), 45.3(B)(1), 45.4(C), 45.6, 17 C.F.R. 23.431(A)(3)(I), 23.602(A), 43.3(A)(1), 45.3(B)(1), 45.4(C), AND 45.6 (2022) IN CONNECTION WITH GSCO'S ALLEGED FAILURE TO REPORT ACCURATELY AND TIMELY SWAP DATA, DISCLOSE CERTAIN PTMMMS IN ACCORDANCE WITH THE CFTC'S REQUIREMENTS, AND SUPERVISE CERTAIN AREAS OF ITS SWAP DEALER BUSINESS, INCLUDING SWAP DATA REPORTING, PRE-TRADE MID-MARKET MARKS ("PTMMM") DISCLOSURES, A PERSONNEL REPORTING LINE, CLEARING MEMBER RISK MANAGEMENT POLICY, NOTICES REGARDING ITS INITIAL MARGIN MODEL AND TO UNSEGREGATED CLIENTS, AND DISCLOSURE OF STATIC MATERIAL ECONOMIC TERMS. GSCO HAS AND CONTINUES TO TAKE REMEDIAL STEPS TO ADDRESS THE DEFICIENCIES. THE CFTC ORDERED THAT GSCO CEASE AND DESIST FROM VIOLATING THESE PROVISIONS OF THE CEA AND COMMISSION REGULATIONS; COMPLY WITH THE CONDITIONS AND UNDERTAKINGS ENUMERATED IN THE OFFER; AND PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $30,000,000. THE FINE WAS PAID ON OCTOBER 5, 2023. GOLDMAN SACHS & CO. LLC 23-60 09/29/2023 COMMODITY FUTURES TRADING COMMISSION, United States ON SEPTEMBER 29, 2023, THE COMMODITY FUTURES TRADING COMMISSION ("COMMISSION" OR "CFTC") ISSUED AN ORDER AGAINST GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), ACCEPTING AN OFFER OF SETTLEMENT SUBMITTED BY GSCO, IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE COMMISSION'S FINDINGS. THE CFTC FOUND THAT GSCO FAILED TO MAINTAIN AN ADEQUATE SUPERVISORY SYSTEM WITH RESPECT TO DISRUPTIVE TRADING, IN VIOLATION OF COMMISSION REGULATION 166.3, IN CONNECTION WITH A SINGLE EIGHT-MINUTE TRADING EPISODE FROM DECEMBER 29, 2017. ADDITIONALLY, THE CFTC FOUND THAT GSCO REASONABLY SHOULD HAVE KNOWN THAT THE OMISSION OF INFORMATION REGARDING THE FIRM'S CONTROL SYSTEMS AND THEIR MALFUNCTION IN CONNECTION WITH DECEMBER 29, 2017 TRADING EPISODE FROM A STATEMENT TO THE CFTC'S DIVISION OF ENFORCEMENT WAS MATERIALLY MISLEADING, IN VIOLATION OF SECTION 6(C)(2) OF THE COMMODITY EXCHANGE ACT. THE CFTC ORDERED THAT GSCO CEASE AND DESIST; COMPLY WITH THE CONDITIONS AND UNDERTAKINGS ENUMERATED IN THE OFFER; AND PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $3,000,000. THE FINE WAS PAID ON OCTOBER 5, 2023. GOLDMAN SACHS & CO. LLC 23-39 08/29/2023 COMMODITY FUTURES TRADING COMMISSION, United States ON AUGUST 29, 2023, THE COMMODITY FUTURES TRADING COMMISSION ("COMMISSION" OR "CFTC") ISSUED AN ORDER AGAINST GOLDMAN SACHS & CO. LLC ("GSCO"), ACCEPTING AN OFFER OF SETTLEMENT SUBMITTED BY GSCO. THE CFTC FOUND THAT FROM AT LEAST MARCH 2020 TO NOVEMBER 2020 ("RELEVANT PERIOD"), GSCO VIOLATED SECTION 4S(F)(1)(C) OF THE COMMODITY EXCHANGE ACT ("ACT"), 7 U.S.C. 6S(F)(1)(C), AND COMMISSION REGULATIONS ("REGULATIONS") 1.31(B)(2) AND 23.202(A)(1) AND (B)(1), 17 C.F.R. 1.31(B)(2), 23.202(A)(1), (B)(1) (2022), AND VIOLATED THE CEASE-AND-DESIST PROVISION OF A PRIOR COMMISSION ORDER. THE COMMISSION FOUND THAT GSCO USED RECORDING SYSTEM COMPONENTS FROM TWO VENDORS TO RECORD CERTAIN PHONE CALLS, AND DUE TO FAILURES IN THOSE SYSTEMS, GSCO FAILED TO MAKE AND RETAIN A NUMBER OF RECORDINGS OF TRADERS AND SALES PERSONNEL THAT CONTAINED THE ORAL COMMUNICATIONS THAT LED TO THE EXECUTION OF SWAPS AND RELATED CASH AND FORWARD TRANSACTIONS DURING THE RELEVANT PERIOD. CONSEQUENTLY, GSCO ALSO VIOLATED AN ORDER THAT THE COMMISSION HAD PREVIOUSLY ISSUED ON NOVEMBER 26, 2019, RELATED TO OTHER SWAP DEALER RECORDKEEPING VIOLATIONS UNDER THE SAME PROVISIONS. GSCO NEITHER ADMITTED NOR DENIED ANY OF CFTC'S FINDINGS. THE CFTC ORDERED THAT GSCO CEASE AND DESIST, AND PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $5,500,000. THE FINE WAS PAID ON SEPTEMBER 8, 2023. Goldman Sachs Group, Inc. 3-22185 09/25/2024 United States Securities and Exchange Commission ON SEPTEMBER 25, 2024, THE GOLDMAN SACHS GROUP, INC. ("GS GROUP") ENTERED INTO AN ORDER INSTITUTING CEASE-AND-DESIST PROCEEDINGS WITH THE U.S. SECURITIES AND EXCHANGE COMMISSION ("SEC"), WHICH ALLEGED GS GROUP AND RELEVANT GS GROUP AFFILIATES FAILED TO TIMELY FILE SECTION 16(A) REPORTS WITH RESPECT TO CERTAIN ISSUERS, INCLUDING LATE-REPORTED TRANSACTIONS EXECUTED FROM MARCH 2018 TO NOVEMBER 2021. WITHOUT ADMITTING OR DENYING THE FINDINGS, GS GROUP CONSENTED TO THE ENTRY OF THE SEC'S ORDER TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 16(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 16A-3 AND AGREED TO PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $300,000, WHICH GS GROUP PAID ON OCTOBER 15, 2024. N Y Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org 02/27/2023 Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Y Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org 02/27/2023 Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org GREENSKY LLC GREENSKY 2021-CFPB-0004 07/12/2021 CONSUMER FINANCIAL PROTECTION BUREAU ("CFPB") ON JULY 12, 2021, THE CONSUMER FINANCIAL PROTECTION BUREAU ("CFPB") ENTERED A CONSENT ORDER AGAINST GREENSKY LLC ("GREENSKY") AFTER DETERMINING GREENSKY VIOLATED SECTIONS 1031(A) AND 1036(A)(1)(B) OF THE CONSUMER FINANCIAL PROTECTION ACT. FROM MARCH 2014 THROUGH JULY 2021, THE CFPB IDENTIFIED MULTIPLE INSTANCES OF GREENSKY ENGAGING IN UNFAIR ACTS AND PRACTICES WITH REGARD TO LOANS TO CONSUMERS WHO DID NOT AUTHORIZE THEM AND BY STRUCTURING ITS LOAN ORIGINATION AND SERVICING ACTIVITIES IN A MANNER THAT ENABLED UNAUTHORIZED LOANS. ON JULY 12, 2021, THE CONSUMER FINANCIAL PROTECTION BUREAU ("CFPB") ENTERED A CONSENT ORDER AGAINST GREENSKY LLC ("GREENSKY") AFTER DETERMINING GREENSKY VIOLATED SECTIONS 1031(A) AND 1036(A)(1)(B) OF THE CONSUMER FINANCIAL PROTECTION ACT. IN ADDITION, A CIVIL PENALTY OF $2,5000,000 WAS ORDERED TO BE PAID TO THE CFPB. GOLDMANS SACHS & CO. LLC GSCO SEU-2008-048 06/20/2016 DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS, HAWAII, United States VARIOUS STATE REGULATORS, INCLUDING THE COMMISSIONER OF SECURITIES, DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS, HAWAII, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. IN THE CONSENT ORDER, THE COMMISSIONER OF SECURITIES, DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS, HAWAII, ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") ENGAGED IN UNETHICAL PRACTICES IN THE OFFER AND SALE OF ARS AND FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE COMMISSIONER OF SECURITIES, DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS, HAWAII, ON JUNE 20, 2016, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $47,703.26 TO THE COMMISSIONER OF SECURITIES, DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS, HAWAII, WHICH AMOUNT WAS PAID ON JUNE 28, 2016. GOLDMANS SACHS & CO. LLC (GSCO) 09SEC049 06/18/2014 NORTH CAROLINA DEPARTMENT OF THE SECRETARY OF STATE, SECURITIES DIVISION, United States VARIOUS STATE REGULATORS, INCLUDING THE NORTH CAROLINA DEPARTMENT OF THE SECRETARY OF STATE, SECURITIES DIVISION, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. IN THE ADMINISTRATIVE CONSENT ORDER, THE NORTH CAROLINA DEPARTMENT OF THE SECRETARY OF STATE, SECURITIES DIVISION, ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") ENGAGED IN UNETHICAL PRACTICES IN THE OFFER AND SALE OF ARS AND FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE NORTH CAROLINA DEPARTMENT OF THE SECRETARY OF STATE, SECURITIES DIVISION, ON JUNE 18, 2014, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $125,175.05 TO THE NORTH CAROLINA DEPARTMENT OF THE SECRETARY OF STATE, SECURITIES DIVISION, WHICH AMOUNT WAS PAID ON JUNE 26, 2014. Y Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org 02/27/2023 Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Goldman Sachs Mexico 211-2A/14596036-SVM/2022 09/02/2022 THE NATIONAL BANKING AND SECURITIES COMMISSION, Mexico ON SEPTEMBER 2, 2022, GOLDMAN SACHS MEXICO, S.A. DE C.V. CASA DE BOLSA ("MCBO") RECEIVED A FINE IMPOSED BY THE NATIONAL BANKING AND SECURITIES COMMISSION (COMISION NACIONAL BANCARIA Y DE VALORES - "CNBV") OF $1,737,600.00 PESOS (APPROXIMATELY USD $87,899.00), FOR AN ALLEGED VIOLATION OF ARTICLE 350, PARAGRAPH THREE, OF THE SECURITIES MARKET LAW ("SML"). CNBV ALLEGES MCBO FAILED TO COMPLY WITH ITS OBLIGATION TO RESPOND TO 724 OFFICIAL LETTERS BETWEEN SEPTEMBER 2020 AND OCTOBER 2020 WITHIN THE DEADLINE. MCBO PAID THE ADMINISTRATIVE FINE OF $1,737,600.00 PESOS (APPROXIMATELY USD $87,899.00). GREENSKY LLC GREENSKY 2021-CFPB-0004 07/12/2021 CONSUMER FINANCIAL PROTECTION BUREAU ("CFPB"), United States ON JULY 12, 2021, THE CONSUMER FINANCIAL PROTECTION BUREAU ("CFPB") ENTERED A CONSENT ORDER AGAINST GREENSKY LLC ("GREENSKY") AFTER DETERMINING GREENSKY VIOLATED SECTIONS 1031(A) AND 1036(A)(1)(B) OF THE CONSUMER FINANCIAL PROTECTION ACT. FROM MARCH 2014 THROUGH JULY 2021, THE CFPB IDENTIFIED MULTIPLE INSTANCES OF GREENSKY ENGAGING IN UNFAIR ACTS AND PRACTICES WITH REGARD TO LOANS TO CONSUMERS WHO DID NOT AUTHORIZE THEM AND BY STRUCTURING ITS LOAN ORIGINATION AND SERVICING ACTIVITIES IN A MANNER THAT ENABLED UNAUTHORIZED LOANS. ON JULY 12, 2021, THE CONSUMER FINANCIAL PROTECTION BUREAU ("CFPB") ENTERED A CONSENT ORDER AGAINST GREENSKY LLC ("GREENSKY") AFTER DETERMINING GREENSKY VIOLATED SECTIONS 1031(A) AND 1036(A)(1)(B) OF THE CONSUMER FINANCIAL PROTECTION ACT. IN ADDITION, A CIVIL PENALTY OF $2,5000,000 WAS ORDERED TO BE PAID TO THE CFPB. GOLDMAN SACHS (SINGAPORE) PTE. (GSSP) SO/EFD-2/SD/304/SEP/2019 07/19/2019 SECURITIES AND EXCHANGE BOARD OF INDIA, India GOLDMAN SACHS (SINGAPORE) PTE. ("GSSP") SUBMITTED A SETTLEMENT PROPOSAL TO THE SECURITIES AND EXCHANGE BOARD OF INDIA ("SEBI") ON JULY 23, 2019 IN ORDER TO RESOLVE ALLEGATIONS OF DISCREPANCIES IN THE MONTHLY REPORTING OF OFFSHORE DERIVATIVE INSTRUMENTS IN DEFAULT OF REGULATION 22 OF THE SEBI REGULATIONS. THE SETTLEMENT ORDER WAS PASSED BY SEBI AND WENT INTO IMMEDIATE EFFECT ON SEPTEMBER 26, 2019. WITHOUT ADMITTING OR DENYING FAULT, GSSP AGREED TO A FINE IN THE AMOUNT OF RUPEES 2,535,000 (APPROXIMATELY USD 35,286.74), WHICH WAS PAID BY SUBMISSION OF A WIRE ON SEPTEMBER 5, 2019. THE SETTLEMENT ORDER WAS PASSED BY SEBI AND WENT INTO IMMEDIATE EFFECT ON SEPTEMBER 26, 2019. GOLDMAN SACHS INVESTMENTS (MAURITIUS) I LIMITED (GSMI) SO/EFD-2/SD/305/SEP/2019 07/19/2019 SECURITIES AND EXCHANGE BOARD OF INDIA, India GOLDMAN SACHS INVESTMENTS (MAURITIUS) I LIMITED ("GSMI") SUBMITTED A SETTLEMENT PROPOSAL TO THE SECURITIES AND EXCHANGE BOARD OF INDIA ("SEBI") ON JULY 23, 2019 IN ORDER TO RESOLVE ALLEGATIONS OF DISCREPANCIES IN THE MONTHLY REPORTING OF OFFSHORE DERIVATIVE INSTRUMENTS IN DEFAULT OF REGULATION 22 OF THE SEBI REGULATIONS. THE SETTLEMENT ORDER WAS PASSED BY SEBI AND WENT INTO IMMEDIATE EFFECT ON SEPTEMBER 26, 2019. WITHOUT ADMITTING OR DENYING FAULT, GSMI AGREED TO A FINE IN THE AMOUNT OF RUPEES 2,535,000 (APPROXIMATELY USD 35,286.74), WHICH WAS PAID BY SUBMISSION OF A WIRE ON SEPTEMBER 5, 2019. THE SETTLEMENT ORDER WAS PASSED BY SEBI AND WENT INTO IMMEDIATE EFFECT ON SEPTEMBER 26, 2019. GOLDMAN SACHS INTERNATIONAL (GSI) 442 2-629 06/16/2021 THE SWISS FEDERAL DEPARTMENT OF FINANCE, Switzerland ON JUNE 16, 2021, THE SWISS FEDERAL DEPARTMENT OF FINANCE CONCLUDED THEIR ADMINISTRATIVE CRIMINAL INVESTIGATION AND DETERMINED THAT GOLDMAN SACHS INTERNATIONAL ("GSI") VIOLATED THE DISCLOSURE REQUIREMENTS OF ARTICLE 151 AND ARTICLE 134 OF THE FINANCIAL MARKET INFRASTRUCTURES ACT, BY SUBMITTING LATE NOTICES FOR TWELVE TRANSACTIONS EXECUTED DURING AN ONGOING TENDER OFFER OF A SWISS ISSUER. THE SWISS FEDERAL DEPARTMENT OF FINANCE ISSUED A FINE OF CHF 3640 (APPROXIMATELY USD 3997.76) WHICH WAS PAID BY A SUBMISSION OF A WIRE ON NOVEMBER 10, 2021. GOLDMAN SACHS DO BRASIL BANCO MULTIPLO S.A. (GS BRAZIL) AND DANIEL MOTTA CAMARGO SILVA 19957.000791/2020-59 06/01/2021 COMISSAO DE VALORES MOBILIARIOS, Brazil GOLDMAN SACHS DO BRASIL BANCO MULTIPLO S.A. ("GS BRAZIL"), GOLDMAN SACHS INTERNATIONAL ("GSI"), AND DANIEL MOTTA CAMARGO SILVA, A DIRECTOR OF THE TRADING DESK (FICC) OF GS BRAZIL, SUBMITTED A SETTLEMENT PROPOSAL THAT WAS ACCEPTED BY THE COMISSAO DE VALORES MOBILIARIOS ("CVM") BOARD OF COMMISSIONERS. THE SETTLEMENT RESOLVED ALLEGATIONS THAT BETWEEN JANUARY 1, 2018 AND DECEMBER 31, 2019, GSI AND GS BRAZIL CREATED ARTIFICIAL CONDITIONS OF DEMAND, OFFER, OR PRICE BY CROSSING IN THE BRAZILIAN EXCHANGE DI X US DOLLAR SPREAD FUTURES IN VIOLATION OF CVM INSTRUCTION N. 08/79. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS BRAZIL, GSI, AND MR. SILVA ENTERED INTO A SETTLEMENT AGREEMENT ON JULY 22, 2021 WITH THE CVM FOR A TOTAL AMOUNT OF BRAZILIAN REAIS 7,480,000 (APPROXIMATELY USD 1,454,941.55), WHICH WAS PAID BY A WIRE SUBMISSION ON AUGUST 5, 2021. GOLDMAN SACHS INTERNATIONAL (GSI) 19957.000791/2020-59 06/01/2021 COMISSAO DE VALORES MOBILIARIOS, Brazil GOLDMAN SACHS DO BRASIL BANCO MULTIPLO S.A. ("GS BRAZIL"), GOLDMAN SACHS INTERNATIONAL ("GSI"), AND DANIEL MOTTA CAMARGO SILVA, A DIRECTOR OF THE TRADING DESK (FICC) OF GS BRAZIL, SUBMITTED A SETTLEMENT PROPOSAL THAT WAS ACCEPTED BY THE COMISSAO DE VALORES MOBILIARIOS ("CVM") BOARD OF COMMISSIONERS. THE SETTLEMENT RESOLVED ALLEGATIONS THAT BETWEEN JANUARY 1, 2018 AND DECEMBER 31, 2019, GSI AND GS BRAZIL CREATED ARTIFICIAL CONDITIONS OF DEMAND, OFFER, OR PRICE BY CROSSING IN THE BRAZILIAN EXCHANGE DI X US DOLLAR SPREAD FUTURES IN VIOLATION OF CVM INSTRUCTION N. 08/79. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, GS BRAZIL, GSI, AND MR. SILVA ENTERED INTO A SETTLEMENT AGREEMENT ON JULY 22, 2021 WITH THE CVM FOR A TOTAL AMOUNT OF BRAZILIAN REAIS 7,480,000 (APPROXIMATELY USD 1,454,941.55), WHICH WAS PAID BY A WIRE SUBMISSION ON AUGUST 5, 2021. GOLDMAN SACHS INTERNATIONAL (GSI) 2021/10 04/20/2021 EUREX DEUTSCHLAND, Germany EUREX DEUTSCHLAND INTITIATED SANCTION PROCEEDINGS AGAINST GOLDMAN SACHS INTERNATIONAL ("GSI") AND A GSI SALES TRADER ON APRIL 20, 2021 IN RELATION TO FOUR REQUESTS FOR CROSS IN THE EUREX PRODUCT ADIDAS DEC23 WITHOUT SUBSEQUENT ENTRY OR A CORRESPONDING TRADE OR ORDER. EUREX DEUTSCHLAND ALLEGES THAT SUBMISSION OF THE CROSS REQUESTS WAS IN VIOLATION OF NUMBER 2.6 OF THE EXCHANGE RULES OF EUREX DEUTSCHLAND. EUREX DEUTSCHLAND INITITATED SANCTION PROCEEDINGS AGAINST GOLDMAN SACHS INTERNATIONAL ("GSI") ON APRIL 20, 2021 AND ISSUED A SUMMARY FINE OF EURO 1,000 (APPROXIMATELY USD 854.55) TO GSI, WHICH WAS PAID BY SUBMISSION OF A WIRE ON AUGUST 18, 2021. GOLDMAN SACHS INTERNATIONAL (GSI) 442.2-591 03/18/2021 THE SWISS FEDERAL DEPARTMENT OF FINANCE, Switzerland ON MARCH 18, 2021, THE SWISS FEDERAL DEPARTMENT OF FINANCE DETERMINED THAT GOLDMAN SACHS INTERNATIONAL ("GSI") VIOLATED THE DISCLOSURE REQUIREMENTS OF ARTICLE 151 AND ARTICLE 120 OF THE FINANCIAL MARKET INFRASTRUCTURES ACT, BY NEGLIGENTLY NOT REPORTING THE CONSOLIDATED POSITION FOR GOLDMAN SACHS IN CASTLE PRIVATE EQUITY LTD, A SWISS COMPANY LISTED ON THE SWISS STOCK EXCHANGE, WITHIN THE TIME LIMIT REQUIRED. ON MARCH 18, 2021, THE SWISS FEDERAL DEPARTMENT OF FINANCE IMPOSED A VIOLATION PENALTY OF CHF 1500 (PLUS ADMINISTRATIVE COST OF CHF 60) AGAINST GSI. GSI PAID THE FINE OF CHF 1560 (APPROXIMATELY USD 1735.84) ON MAY 21, 2021 BY SUBMISSION OF A WIRE. GOLDMAN SACHS GROUP, INC., GOLDMAN SACHS INTERNATIONAL 20,4962 02/24/2021 FINANSTILSYNET, Norway 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. 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 15, 2021. GOLDMAN SACHS & CO. LLC 20/4962 02/24/2021 FINANSTILSYNET, Norway 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. 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 15, 2021. GOLDMAN SACHS (ASIA) L.L.C. (GS ASIA) Action imposed following inquiry/investigation related to 1MDB 10/22/2020 HONG KONG SECURITIES AND FUTURES COMMISSION, Hong Kong THE HONG KONG SECURITIES AND FUTURES COMMISSION ("HKSFC") ISSUED A STATEMENT OF DISCIPLINARY ACTION (THE "SFC STATEMENT") AGAINST GOLDMAN SACHS (ASIA) L.L.C. ("GS ASIA"), AN INDIRECT WHOLLY OWNED SUBSIDIARY OF THE GOLDMAN SACHS GROUP, INC., ON OCTOBER 22, 2020, RELATING TO GS ASIA'S FAILURE TO PROPERLY EXAMINE AND ADDRESS RED FLAGS IN CONNECTION WITH THE 1MALAYSIA DEVELOPMENT BERHAD ("1MDB") TRANSACTIONS AND TO DILIGENTLY SUPERVISE ITS SENIOR PERSONNEL IN CONNECTION WITH THEIR PARTICIPATION IN THE 1MDB TRANSACTIONS. GS ASIA PAID A FINANCIAL PENALTY IN THE AMOUNT OF $350,000,000 IN CONNECTION WITH THE SFC STATEMENT. GOLDMAN SACHS (SINGAPORE) PTE (GS SINGAPORE) HHQ/DOW/TCK/308392/7 10/22/2020 THE MONETARY AUTHORITY OF SINGAPORE, Singapore ON OCTOBER 22, 2020, GOLDMAN SACHS (SINGAPORE) PTE ("GS SINGAPORE") RECEIVED A NOTICE OF CONDITIONAL WARNING FROM THE SINGAPORE COMMERCIAL AFFAIRS DEPARTMENT ("SCAD"), AT THE DIRECTION OF THE SINGAPORE ATTORNEY GENERAL'S CHAMBERS (THE "SINGAPORE NOTICE"), WHICH ALLEGED GS SINGAPORE CORRUPTLY GAVE GRATIFICATION AS A REWARD IN RELATION TO EACH OF THE 1MALAYSIA DEVELOPMENT BERHAD BOND TRANSACTIONS. GS SINGAPORE PAID A FINANCIAL PENALTY IN THE AMOUNT OF $122,000,000 IN CONNECTION WITH THE SINGAPORE NOTICE. GOLDMAN SACHS INTERNATIONAL (GSI) 142888 10/22/2020 UK FINANCIAL CONDUCT AUTHORITY, United Kingdom GOLDMAN SACHS INTERNATIONAL ("GSI"), AN INDIRECT WHOLLY OWNED SUBSIDIARY OF THE GOLDMAN SACHS GROUP, INC., RECEIVED ON OCTOBER 22, 2020 A WARNING NOTICE FROM THE UK FINANCIAL CONDUCT AUTHORITY (THE "FCA" AND THE NOTICE, THE "FCA NOTICE"), WHICH CITES GSI'S FAILURE TO (I) ASSESS AND MANAGE THE RISKS ASSOCIATED WITH THE 1MALAYSIA DEVELOPMENT BERHAD TRANSACTIONS; (II) PROPERLY RECORD HOW GSI COMMITTEES ASSESSED AND MANAGED THOSE RISKS AND; (III) RESPOND APPROPRIATELY TO ALLEGATIONS OF BRIBERY AND MISCONDUCT. GSI PAID A FINANCIAL PENALTY IN THE AMOUNT OF $63,000,000 IN CONNECTION WITH THE FCA NOTICE. GOLDMAN SACHS INTERNATIONAL (GSI) 142888 10/22/2020 THE BANK OF ENGLAND PRUDENTIAL REGULATION AUTHORITY, United Kingdom GOLDMAN SACHS INTERNATIONAL ("GSI"), AN INDIRECT WHOLLY OWNED SUBSIDIARY OF THE GOLDMAN SACHS GROUP, INC., RECEIVED ON OCTOBER 22, 2020 A WARNING NOTICE FROM THE BANK OF ENGLAND PRUDENTIAL REGULATION AUTHORITY (THE "PRA" AND THE WARNING NOTICE, THE "PRA NOTICE"), WHICH CITES GSI'S FAILURE TO (I) ASSESS AND MANAGE THE RISKS ASSOCIATED WITH THE 1MALAYSIA DEVELOPMENT BERHAD TRANSACTIONS; (II) PROPERLY RECORD HOW GSI COMMITTEES ASSESSED AND MANAGED THOSE RISKS; AND (III) RESPOND APPROPRIATELY TO ALLEGATIONS OF BRIBERY AND MISCONDUCT. GSI PAID A FINANCIAL PENALTY IN THE AMOUNT OF $63,000,000 IN CONNECTION WITH THE PRA NOTICE. GOLDMAN SACHS GROUP, INC. (GS GROUP) 20-018-B-HC; 20-018-CMP-HC 10/22/2020 FEDERAL RESERVE, United States 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. 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. GOLDMAN SACHS GROUP, INC. (GS GROUP) Action imposed following inquiry/investigation related to 1MDB 10/22/2020 THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES, United States 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 SUPERINTENDENT 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. GS GROUP PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $150,000,000 TO THE DFS. GOLDMANS SACHS & CO. LLC (GSCO) FI DNR 17-17349 04/01/2020 FINANSINSPEKTIONEN, Sweden ON APRIL 1, 2020, THE SWEDISH FINANCIAL SUPERVISORY AUTHORITY (FINANSINSPEKTIONEN - "SFSA") IMPOSED A FINE ON GOLDMAN SACHS & CO. LLC ("GSCO") IN THE AMOUNT OF 315,000 SWEDISH KRONA (SEK). SFSA ALLEGES A VIOLATION OF CHAPTER 4 OF THE FINANCIAL INSTRUMENTS TRADING ACT (SFS 1991:1980), IN RELATION TO A LATE DISCLOSURE OF CHANGES IN MAJOR HOLDINGS OF SHARES IN MICRONIC AB BETWEEN JUNE AND SEPTEMBER OF 2017. GSCO PAID THE FINE OF 315,000 SEK ON JUNE 8, 2020 TO THE SFSA BY WIRE. WHILE THE ACTUAL PAYMENT OF THE FINE WAS MADE IN SEK, USING THE FEDERAL RESERVE'S FOREIGN EXCHANGE RATE OF 1 USD: 9.2138 SEK AS OF JUNE 8, 2020, THE EQUIVALENT U.S. DOLLAR VALUE WAS APPROXIMATELY 34,187.85 USD. GOLDMAN SACHS AUSTRALIA PTY LTD (GSA) 2019001 11/13/2019 THE AUSTRALIA SECURITIES EXCHANGE, Australia ON NOVEMBER 13, 2019, THE AUSTRALIA SECURITIES EXCHANGE ("ASX") IMPOSED A FINE ON GOLDMAN SACHS AUSTRALIA PTY LTD ("GSA") IN THE AMOUNT OF 50,000 AUSTRALIAN DOLLARS (AUD). ASX CITED VIOLATIONS OF ASX CLEAR (FUTURES) OPERATING RULE 46.1 AND RULE 46.5 IN RELATION TO FUTURES CLEARING AND THE DAILY CLOSE OUT OF BACK-TO-BACK FUTURES POSITIONS, IN PARTICULAR FOR PHYSICALLY SETTLED BANK BILLS FUTURES CONTRACTS. THE FINE IMPOSED BY ASX WAS IN THE AMOUNT OF 50,000 AUD, WHICH WAS PAID BY GSA BY WIRE ON DECEMBER 10, 2019. ASX INTENDS TO PUBLISH A PUBLIC NOTICE ON 16 DECEMBER, 2019 CONCERNING THE CONTRAVENTION. GOLDMAN SACHS GROUP, INC. (GS GROUP) Matter of GS Group 09/20/2019 FINANSINSPEKTIONEN, Swden ON SEPTEMBER 20, 2019 THE SWEDISH FINANCIAL SUPERVISORY AUTHORITY (FINANSINSPEKTIONEN - "SFSA") IMPOSED AN ADMINISTRATIVE FINE ON 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. GS GROUP 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. GOLDMAN SACHS INDIA INVESTMENTS (SINGAPORE) PTE. LTD. KRPL Matter of GS India Investments (SINGAPORE) PTE. LTD. 03/07/2019 THE FINANCIAL SERVICES COMMISSION OF THE REPUBLIC OF KOREA, The Republic of Korea THE FINANCIAL SERVICES COMMISSION OF THE REPUBLIC OF KOREA ("FSC") HAS IMPOSED AN ADMINISTRATIVE FINE ON GOLDMAN SACHS INDIA INVESTMENTS (SINGAPORE) PTE. LTD. ("KRPL") FOR VIOLATION OF CERTAIN SHORT SALE RESTRICTIONS AS SET OUT IN ARTICLE 180(1) OF THE FINANCIAL INVESTMENT SERVICES AND CAPITAL MARKETS ACT (THE "ACT") WITH RESPECT TO CERTAIN OF KRPL'S SHORT SALE ORDERS ON OCTOBER 31, 2017 AND JANUARY 9, 2018. THE FINE WAS IMPOSED PURSUANT TO ARTICLE 449 OF THE ACT, ARTICLE 390 OF THE ENFORCEMENT DECREE OF THE ACT, AND ARTICLES 26 AND 48 OF THE REGULATION ON SANCTIONS AGAINST FINANCIAL INSTITUTIONS. THE FINE IMPOSED BY THE FSC WAS IN THE AMOUNT OF 72,000,000 SOUTH KOREAN WON ("KRW"), WHICH WAS PAID BY KRPL BY WIRE ON APRIL 2, 2019. GOLDMAN SACHS INTERNATIONAL (GSI) Matter of GSI 12/10/2018 THE FINANCIAL SERVICES COMMISSION OF THE REPUBLIC OF KOREA, The Republic of Korea THE FINANCIAL SERVICES COMMISSION OF THE REPUBLIC OF KOREA ("FSC") HAS IMPOSED AN ADMINISTRATIVE FINE ON GOLDMAN SACHS INTERNATIONAL ("GSI") FOR VIOLATION OF CERTAIN SHORT SALE RESTRICTIONS AS SET OUT IN ARTICLES 180(1) AND 180-2(1) OF THE FINANCIAL INVESTMENT SERVICES AND CAPITAL MARKETS ACT (THE "ACT") WITH RESPECT TO CERTAIN OF GSI'S SHORT SALE ORDERS AND SHORT POSITION REPORTS. THE FINE WAS IMPOSED PURSUANT TO ARTICLE 449 OF THE ACT, ARTICLE 390 OF THE ENFORCEMENT DECREE OF THE ACT, ARTICLES 26 AND 48 OF THE REGULATION ON INVESTIGATION OF CAPITAL MARKETS, AND ARTICLE 20 OF THE REGULATION ON EXAMINATION AND SANCTIONS AGAINST FINANCIAL INSTITUTIONS. THE FINE IMPOSED BY THE FSC WAS IN THE AMOUNT OF 7,504,800,000 SOUTH KOREAN WON (KRW), WHICH WAS PAID BY GSI BY WIRE ON DECEMBER 18, 2018. GOLDMAN SACHS GROUP, INC 2017 / 158544 / 570; 2018 / 095899 / CNB / 110 01/04/2018 CZECH NATIONAL BANK, Czech Republic 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. 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. GOLDMAN SACHS SAUDI ARABIA (GSSA) S/3/7/876/17 02/22/2017 KINGDOM OF SAUDI ARABIA CAPITAL MARKET AUTHORITY, Saudi Arabia IN A LETTER TO GOLDMAN SACHS SAUDI ARABIA ("GSSA") DATED FEBRUARY 16, 2017, THAT WAS RECEIVED BY HAND DELIVERY ON FEBRUARY 22, 2017, FROM THE KINGDOM OF SAUDI ARABIA CAPITAL MARKET AUTHORITY (THE "CMA"), THE CMA INFORMED GSSA OF A CMA DECISION ALLEGING A DELAY OF MORE THAN THREE DAYS IN PROVIDING THE CMA WITH THE CERTAIN ACCOUNT INFORMATION REQUIRED BY VIRTUE OF CMA CIRCULAR NO. S/6/6/9214/16, DATED DECEMBER 6, 2016, IN ALLEGED VIOLATION OF SECTION (A) OF ARTICLE 3 OF THE AUTHORIZED PERSONS REGULATIONS. GSSA AGREED TO THE PAYMENT OF A FINANCIAL PENALTY TO THE CMA IN THE AMOUNT OF 10,000 SAUDI ARABIAN RIYALS (SAR), WHICH WAS PAID BY SUBMISSION OF A WIRE ON MARCH 1, 2017. GOLDMAN SACHS INTERNATIONAL (GSI) H--15-2016 12/07/2016 FRANKFURT STOCK EXCHANGE, Germany THE FRANKFURT STOCK EXCHANGE ("FSE") SANCTIONS COMMITTEE (THE "SANCTIONS COMMITTEE") ALLEGED THAT GOLDMAN SACHS INTERNATIONAL ("GSI") VIOLATED SEC. 72A OF THE EXCHANGE RULES OF THE FSE BY CONVEYING CERTAIN UNLABELED ORDERS GENERATED BY ALGORITHMIC TRADING TO THE XETRA TRADING PLATFORM OF THE FSE IN THE PERIOD FROM MARCH 29, 2016 TO SEPTEMBER 20, 2016. THE FSE ISSUED A REPRIMAND TO GSI, AND REQUIRED GSI TO PAY A 500 EURO FEE FOR THE PROCEEDINGS. IN ITS DECISION, THE FSE NOTED THAT GSI DISCOVERED THE ERROR ITSELF AND THEN IMMEDIATELY DISCLOSED AND REMEDIED IT. GOLDMANS SACHS & CO. LLC (GSCO) SEU-2008-048 06/20/2016 DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS, HAWAII, United States VARIOUS STATE REGULATORS, INCLUDING THE COMMISSIONER OF SECURITIES, DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS, HAWAII, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. IN THE CONSENT ORDER, THE COMMISSIONER OF SECURITIES, DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS, HAWAII, ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") ENGAGED IN UNETHICAL PRACTICES IN THE OFFER AND SALE OF ARS AND FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE COMMISSIONER OF SECURITIES, DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS, HAWAII, ON JUNE 20, 2016, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $47,703.26 TO THE COMMISSIONER OF SECURITIES, DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS, HAWAII, WHICH AMOUNT WAS PAID ON JUNE 28, 2016. GOLDMAN SACHS SAUDI ARABIA (GSSA) 375/10/2015 05/12/2016 KINGDOM OF SAUDI ARABIA CAPITAL MARKET AUTHORITY, Saudi Arabia IN A LETTER DATED MAY 12, 2016 TO GOLDMAN SACHS SAUDI ARABIA ("GSSA") FROM THE KINGDOM OF SAUDI ARABIA CAPITAL MARKET AUTHORITY (THE "CMA"), THE CMA INFORMED GSSA OF A CMA DECISION ALLEGING THAT THERE WAS ONLY ONE INDIVIDUAL ASSOCIATED WITH GSSA REGISTERED WITH THE CMA UNDER INVESTMENT FUND MANAGEMENT AND CLIENT PORTFOLIO MANAGEMENT ACTIVITIES, IN ALLEGED VIOLATION OF CMA CIRCULAR NO. T/1/6/9/15, DATED JUNE 17, 2015. GSSA AGREED TO THE PAYMENT OF A FINANCIAL PENALTY TO THE CMA IN THE AMOUNT OF 10,000 SAUDI ARABIAN RIYALS (SAR), WHICH WAS PAID BY SUBMISSION OF A WIRE ON MAY 23, 2016. THE CMA'S DECISION STIPULATED THE NEED FOR GSSA TO DISCUSS THE MATTER OF THE VIOLATION AT THE NEXT MEETING OF THE BOARD OF DIRECTORS OF GSSA. GOLDMAN SACHS (ASIA) L.L.C. (GS ASIA) 6209/2014 02/02/2016 SECURITIES AND FUTURES COMMISSION OF HONG KONG, Hong Kong THE SECURITIES AND FUTURES COMMISSION OF HONG KONG ("SFC") CENSURED GOLDMAN SACHS (ASIA) L.L.C. ("GS ASIA") IN RESPECT TO GS ASIA'S FAILURE, WHILE ACTING AS A FINANCIAL ADVISOR IN RELATION TO A VOLUNTARY GENERAL SECURITIES OFFERING OF AN ISSUER, TO (I) DISCLOSE ITS DEALINGS IN THE RELEVANT SECURITIES BETWEEN NOVEMBER 8, 2013 AND JANUARY 6, 2014, (II) SEEK, DURING THE OFFER PERIOD, THE SFC'S CONSENT PRIOR TO DEALING IN PRINCIPAL TRADES IN THE RELEVANT SECURITIES OF THE ISSUER WHICH FELL OUTSIDE THE SCOPE OF DEALINGS COVERED BY THE EXEMPT PRINCIPAL TRADING AND EXEMPT FUND MANAGER STATUS GRANTED TO CERTAIN GOLDMAN SACHS ENTITIES AND, (III) COMPLY WITH CERTAIN REQUIREMENTS IN RELATION TO RESEARCH REPORTS ON THE ISSUER, IN BREACH OF RULES 22, 21.5, NOTE 4 TO RULE 8.1 AND 10 OF THE CODE ON TAKEOVERS AND MERGERS. THE SFC ISSUED A PUBLIC CENSURE OF GS ASIA DATED FEBRUARY 2, 2016 (THE "CENSURE"). IN DECIDING THE CENSURE, THE SFC TOOK INTO ACCOUNT GOLDMAN SACHS' COOPERATION AND SELF-REPORTING OF THE BREACHES. Goldman Sachs Group 442.2-164/194 12/08/2015 FEDERAL DEPARTMENT OF FINANCE, United States 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"). 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. Goldman Sachs Group Matter of GS Group 10/28/2015 THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES, United States 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. 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"). GOLDMAN SACHS PAID A CIVIL MONETARY PENALTY IN THE AMOUNT OF $50 MILLION ON NOVEMBER 9, 2015. GOLDMAN SACHS INTERNATIONAL (GSI) WA 17-WP 3120-2012/0035 - 3121-2014/0027 08/12/2015 THE FEDERAL FINANCIAL SUPERVISORY AUTHORITY OF GERMANY, Germany THE FEDERAL FINANCIAL SUPERVISORY AUTHORITY OF GERMANY (BUNDESANSTALT FUR FINANZDIENSTLEISTUNGSAUFSICHT - "BAFIN") ALLEGED CERTAIN BREACHES BY GOLDMAN SACHS INTERNATIONAL ("GSI") OF THE OWNERSHIP THRESHOLD NOTIFICATION REQUIREMENTS OF SECTIONS 21, 25 AND 25A OF THE GERMAN SECURITIES TRADING ACT (WERTPAPIERHANDELSGESETZ - "WPHG"). BAFIN IMPOSED A MONETARY PENALTY ON GSI OF 1,107,503.50 EUROS IN THE AGGREGATE, REPRESENTING AN ADMINISTRATIVE FINE OF 1,100,000 EUROS AND PROCEDURAL EXPENSES OF 7,503.50 EUROS, WHICH AMOUNT WAS PAID ON DECEMBER 18, 2015. GOLDMAN SACHS INTERNATIONAL (GSI) Matter of GSI 07/20/2015 AKK, Hungary AKK - ALLAMADOSSAG KEZELO KOZPONT ZARTKORUEN MUKODO RESZVENYTARSASAG ALLEGED THAT DURING THE MONTH OF JUNE 2015, GOLDMAN SACHS INTERNATIONAL ("GSI") FAILED TO MEET PRIMARY DEALER QUOTING OBLIGATIONS IN ACCORDANCE WITH THE AGENCY CONTRACT BETWEEN GSI AND AKK AND THE RELEVANT MARKET MAKING RULES. THE AKK IMPOSED A FINE ON GSI IN THE AMOUNT OF HUF$500,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON AUGUST 13, 2015. GOLDMAN SACHS DO BRASIL BANCO MULTIPLO S.A. (GSBR) 005/2015 07/22/2015 ASSOCIACAO BRASILEIRA DAS ENTIDADES DOS MERCADOS FINANCEIRO E DE CAPITAIS ("ANBIMA"), Brazil ANBIMA - ASSOCIACAO BRASILEIRA DAS ENTIDADES DOS MERCADOS FINANCEIRO E DE CAPITAIS ("ANBIMA") FILED A PROCEEDING FOR INVESTIGATION OF IRREGULARITIES ("PAI") TO INVESTIGATE WHETHER GOLDMAN SACHS DO BRASIL BANCO MULTIPLO S.A. ("GSBR") MAY HAVE VIOLATED ARTICLE 27, PARAGRAPH 3, V OF THE ANBIMA CODE OF REGULATION AND BEST PRACTICES TO INVESTMENT FUNDS (CODIGO ANBIMA DE REGULACAO E MELHORES PRATICAS PARA FUNDOS DE INVESTIMENTO, "ANBIMA'S CODE OF FUNDS") IN CONNECTION WITH GSBR'S TAX TREATMENT OF PAYMENTS OF INTEREST ON CAPITAL IN CONNECTION WITH STOCK LENDING TRADES INVOLVING A BRAZILIAN INVESTMENT FUND MANAGED BY GSBR (THE "FUND"). WITHOUT ADMITTING OR DENYING THE RULE VIOLATION, ANBIMA AND GSBR ENTERED INTO A SETTLEMENT AGREEMENT ON JULY 22, 2015. IN ADDITION, GSBR AGREED TO MAKE A FINANCIAL PAYMENT TO ANBIMA IN THE AMOUNT OF FIVE HUNDRED THOUSAND REAIS (BRL$500,000.00), WHICH AMOUNT WAS PAID BY GSBR ON AUGUST 3, 2015. GOLDMANS SACHS & CO. LLC (GSCO) 161/4/2015 06/17/2015 THE KINGDOM OF SAUDI ARABIA CAPITAL MARKET AUTHORITY, Saudi Arabia IN A LETTER DATED JUNE 17, 2015 TO GOLDMAN SACHS SAUDI ARABIA ("GSSA") FROM THE KINGDOM OF SAUDI ARABIA CAPITAL MARKET AUTHORITY (THE "CMA"), THE CMA INFORMED GSSA OF A CMA DECISION ALLEGING THAT GSSA WAS LATE IN NOTIFYING THE CMA OF THE RESIGNATION OF GSSA'S CHIEF EXECUTIVE OFFICER, IN ALLEGED VIOLATION OF ARTICLE 15 PARAGRAPH A OF THE CMA LICENSEES REGULATIONS. GSSA AGREED TO THE PAYMENT OF A FINANCIAL PENALTY TO THE CMA IN THE AMOUNT OF 10,000 SAUDI ARABIAN RIYALS (SAR), WHICH WAS PAID BY SUBMISSION OF A WIRE ON JULY 5, 2015. THE CMA'S DECISION STIPULATED THE NEED FOR GSSA TO DISCUSS THE MATTER OF THE VIOLATION AT THE NEXT MEETING OF THE BOARD OF DIRECTORS OF GSSA AND TO NOTIFY THE CMA OF THE BOARD'S RESPONSE IN THIS REGARD. GOLDMAN SACHS DO BRASIL BANCO MULTIPLO S.A. Matter of GS DO BRASIL BANCO MULTIPLO S.A. 03/18/2015 ASSOCIACAO BRASILEIRA DAS ENTIDADES DOS MERCADOS FINANCEIRO E DE CAPITAIS ("ANBIMA"), Brazil ANBIMA - ASSOCIACAO BRASILEIRA DAS ENTIDADES DOS MERCADOS FINANCEIRO E DE CAPITAIS ("ANBIMA") ALLEGED THAT, CERTAIN BRAZILIAN FINANCIAL INSTITUTIONS, INCLUDING GOLDMAN SACHS DO BRASIL BANCO MULTIPLO S.A. ("OFFERING COORDINATORS") ACTING IN A PUBLIC OFFERING (THE "OFFERING") OF EQUITY SECURITIES OF THE BRAZILIAN ISSUER OI S.A. (THE "ISSUER"), FAILED TO APPROPRIATELY DISCLOSE CERTAIN RELATIONSHIPS IN THE OFFERING MATERIALS ASSOCIATED WITH CERTAIN OFFERING COORDINATORS BEING CREDITORS AND SECURITY HOLDERS OF THE ISSUER WHO USED PART OF THE PROCEEDS FROM THE OFFERING TO AMORTIZE SUCH LOANS (PARTIALLY OR TOTALLY), IN ALLEGED CONTRAVENTION OF ARTICLE 10 OF THE ANBIMA CODE OF REGULATION AND BEST PRACTICES TO PUBLIC OFFERINGS (CODIGO ANBIMA DE REGULACAO E MELHORES PRATICAS PARA OFERTAS PUBLICAS DE DISTRIBUICAO E AQUISICAO DE VALORES MOBILIARIOS, "ANBIMA'S CODE"). ANBIMA AND THE OFFERING COORDINATORS ENTERED INTO A SETTLEMENT AGREEMENT ON MARCH 18, 2015, IN WHICH THE OFFERING COORDINATORS AGREED TO PREPARE AN EDUCATIONAL MATERIAL AND SCHEDULE INTERNAL WORKSHOPS TO BE PRESENTED BY REPRESENTATIVES FROM ANBIMA TO THE INVESTMENT BANKING TEAM OF EACH OFFERING COORDINATOR ON THE RULES OF ANBIMA'S CODE. IN ADDITION, THE OFFERING COORDINATORS AGREED TO A FINANCIAL PAYMENT TO ANBIMA, GOLDMAN SACHS DO BRASIL BANCO MULTIPLO S.A.'S PORTION OF WHICH WAS BRL$18,894.83, WHICH AMOUNT WILL BE PAID BY GOLDMAN SACHS DO BRASIL BANCO MULTIPLO S.A. UPON RECEIPT OF AN INVOICE. Goldman Sachs Mexico 211/21378/2015 02/17/2015 THE MEXICAN NATIONAL BANKING AND SECURITIES COMMISSION, Mexico ON FEBRUARY 17, 2015, THE MEXICAN NATIONAL BANKING AND SECURITIES COMMISSION NOTIFIED GOLDMAN SACHS MEXICO, CASA DE BOLSA, S.A. DE C.V. ("GS MEXICO") OF ITS DECISION TO IMPOSE AN ADMINISTRATIVE PENALTY FOR THE FAILURE BY GS MEXICO TO TIMELY FILE A QUARTERLY REPORT OF U.S. DOLLAR CASH TRANSACTIONS EFFECTED DURING THE FIRST QUARTER OF 2014 IN ACCORDANCE WITH SECTION 35 OF THE NEW GENERAL GUIDELINES TO ARTICLE 212 OF THE MEXICAN SECURITIES MARKET LAW (NUEVAS DISPOSICIONES DE CARACTER GENERAL A QUE SE REFIERE EL ARTICULO 212 DE LA LEY DEL MERCADO DE VALORES). THE MEXICAN NATIONAL BANKING AND SECURITIES COMMISSION IMPOSED AN ADMINISTRATIVE FINANCIAL PENALTY ON GS MEXICO IN THE AMOUNT OF MXN$269,160, WHICH AMOUNT WAS PAID BY SUBMISSION OF A WIRE ON MARCH 10, 2015. GOLDMAN SACHS INTERNATIONAL (GSI) 442.2-126 10/27/2014 THE FEDERAL DEPARTMENT OF FINANCE, Switzerland THE FEDERAL DEPARTMENT OF FINANCE ("FDF") OF THE SWISS CONFEDERATION ALLEGED THAT GOLDMAN SACHS INTERNATIONAL ("GSI") WAS LATE IN PUBLISHING A DROP BELOW A NOTIFIABLE THRESHOLD IN THE FIRM'S HOLDINGS IN A QUALIFIED INTEREST IN CERTAIN SECURITIES IN THE PERIOD BETWEEN SEPTEMBER 25, 2012, AND DECEMBER 20, 2012, IN ALLEGED INFRINGEMENT OF ARTICLE 41 OF THE SWISS FEDERAL ACT ON STOCK EXCHANGES AND SECURITIES TRADING (SESTA). WITHOUT ADMITTING ANY INTENTIONAL INFRINGEMENT OF SESTA ARTICLES OR WRONGDOING, GSI ENTERED INTO A SETTLEMENT AGREEMENT WITH FDF ON OCTOBER 27, 2014, AND CONSENTED TO A PAYMENT TO THE SWISS CONFEDERATION IN THE AMOUNT OF CHF20,000, WHICH AMOUNT WAS PAID ON NOVEMBER 4, 2014. GOLDMANS SACHS & CO. LLC (GSCO) SAN0372014 08/25/2014 MERCADO MEXICANO DE DERIVADOS, S.A. DE C.V., Mexico IN A NOTICE OF A DISCIPLINARY MEASURE DATED AUGUST 25, 2014, THE SECRETARY OF THE DISCIPLINARY AND ARBITRATION COMMITTEE OF MEXDER, MERCADO MEXICANO DE DERIVADOS, S.A. DE C.V. ("MEXDER"), INFORMED GOLDMAN, SACHS & CO. (THE "FIRM") OF MEXDER'S CONCLUSION THAT THE FIRM FAILED TO TIMELY NOTIFY MEXDER OF THE WITHDRAWAL FROM REGISTRATION WITH MEXDER OF AN EMPLOYEE OF THE FIRM WHO WAS AN ACCREDITED MEXDER SALES REPRESENTATIVE AND TRADER, IN ALLEGED FAILURE TO COMPLY WITH ARTICLE 6036.00 SUBSECTION III OF MEXDER INTERNAL REGULATIONS. MEXDER IMPOSED AN ECONOMIC PENALTY ON THE FIRM IN THE AMOUNT OF $11,268.24 MEXICAN PESOS IN THE AGGREGATE, WHICH AMOUNT WAS PAID BY SUBMISSION OF A WIRE ON SEPTEMBER 18, 2014. GOLDMANS SACHS & CO. LLC (GSCO) 12-011-DISC 07/16/2014 BOURSE DE MONTREAL INC., Canada IN AN ORIGINATING NOTICE TO GOLDMAN, SACHS & CO. (THE "FIRM") DATED JUNE 18, 2013, THE BOURSE DE MONTREAL INC. (THE "BOURSE") ALLEGED THAT, DURING THE PERIOD FROM DECEMBER 1, 2005 TO JUNE 30, 2012, THE FIRM PROVIDED CERTAIN PERSONNEL ACCESS TO THE ELECTRONIC TRADING SYSTEM OF THE BOURSE WITHOUT HAVING OBTAINED THE PRIOR APPROVAL OF THE BOURSE, IN ALLEGED CONTRAVENTION OF SECTION A) OF ARTICLE 6366 OF THE RULES OF THE BOURSE. ON NOVEMBER 25, 2014, THE DISCIPLINARY COMMITTEE OF THE BOURSE (THE "COMMITTEE") INFORMED THE FIRM OF THE COMMITTEE'S APPROVAL OF AN OFFER OF SETTLEMENT (THE "OFFER OF SETTLEMENT") NEGOTIATED BETWEEN THE STAFF OF THE REGULATORY DIVISION OF THE BOURSE AND THE FIRM. IN THE OFFER OF SETTLEMENT, THE FIRM AGREED TO THE PAYMENT OF A FINE IN THE AMOUNT OF CAD$65,000, AS WELL AS AN ADDITIONAL AMOUNT OF CAD$6,500 FOR COSTS, WHICH AMOUNT WAS PAID BY SUBMISSION OF A WIRE ON DECEMBER 18, 2014. GOLDMANS SACHS & CO. LLC (GSCO) 09SEC049 06/18/2014 NORTH CAROLINA DEPARTMENT OF THE SECRETARY OF STATE, SECURITIES DIVISION, United States VARIOUS STATE REGULATORS, INCLUDING THE NORTH CAROLINA DEPARTMENT OF THE SECRETARY OF STATE, SECURITIES DIVISION, CONDUCTED AN INDUSTRY-WIDE, JOINT INVESTIGATION INTO THE MARKETING AND SALES OF ARS. IN THE ADMINISTRATIVE CONSENT ORDER, THE NORTH CAROLINA DEPARTMENT OF THE SECRETARY OF STATE, SECURITIES DIVISION, ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") ENGAGED IN UNETHICAL PRACTICES IN THE OFFER AND SALE OF ARS AND FAILED ADEQUATELY TO SUPERVISE CERTAIN OF ITS SALESPEOPLE IN CONNECTION WITH THE MARKETING AND SALE OF ARS. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM ENTERED INTO AN ADMINISTRATIVE CONSENT ORDER WITH THE NORTH CAROLINA DEPARTMENT OF THE SECRETARY OF STATE, SECURITIES DIVISION, ON JUNE 18, 2014, IN WHICH IT AGREED, AS PART OF A GLOBAL SETTLEMENT WITH STATE REGULATORS, TO PAY A TOTAL MONETARY PENALTY IN THE AMOUNT OF $22.5 MILLION, INCLUDING $125,175.05 TO THE NORTH CAROLINA DEPARTMENT OF THE SECRETARY OF STATE, SECURITIES DIVISION, WHICH AMOUNT WAS PAID ON JUNE 26, 2014. GOLDMAN SACHS BANK EUROPE SE (GSBE) GW 5-K 5112-100395-2020/0001 12/18/2020 FEDERAL FINANCIAL SUPERVISORY AUTHORITY OF GERMANY, Germany THE FEDERAL FINANCIAL SUPERVISORY AUTHORITY OF GERMANY ("BAFIN") CONDUCTED A SPECIAL AUDIT, PURSUANT TO SECTION 51, GELDWASCHEGESETZ - MONEY LAUNDERING ACT, AND SUBSEQUENTLY ISSUED AN ORDER AGAINST GOLDMAN SACHS BANK EUROPE SE ("GSBE") ON DECEMBER 18, 2020. THE ORDER REQUIRED REMEDIATION OF ALL DISCREPANCIES IDENITIFED IN THE SPECIAL AUDIT. ON DECEMBER 18, 2020, BAFIN ORDERED GSBE TO REMEDIATE ALL DISCREPANCIES IDENTIFIED IN THE SPECIAL AUDIT AND TO BEAR THE COSTS OF THE PROCEEDING RESULTING IN AN ADMINISTRATIVE FEE OF EUR 585 (APPROXIMATELY USD 478.09). THE FIRM ADDRESSED ALL REMEDIATIONS REQUIRED IN THE ORDER BY APRIL 28, 2021 AND NOTIFIED BAFIN OF THE STEPS TAKEN DURING THE REMEDIATION PROCESS ON MAY 14, 2021. GOLDMAN SACHS INTERNATIONAL (GSI) Matter of GSI 10/09/2020 AKK, Hungary AKK - ALLAMADOSSAG KEZELO KOZPONT ZARTKORUEN MUKODO RESZVENYTARSASAG ALLEGED THAT DURING THE MONTH OF SEPTEMBER 2020, GOLDMAN SACHS INTERNATIONAL ("GSI") FAILED TO MEET ITS PRIMARY DEALER QUOTING OBLIGATIONS IN ACCORDANCE WITH THE AGENCY CONTRACT BETWEEN GSI AND AKK AND THE RELEVANT MARKET MAKING RULES. THE AKK IMPOSED A FINE ON GSI IN THE AMOUNT OF HUF 500,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON OCTOBER 27, 2020. GOLDMAN SACHS INTERNATIONAL (GSI) Matter of GSI 07/02/2019 AKK, Hungary AKK - ALLAMADOSSAG KEZELO KOZPONT ZARTKORUEN MUKODO RESZVENYTARSASAG ALLEGED THAT DURING THE FIRST HALF OF THE CALENDAR YEAR 2019, GOLDMAN SACHS INTERNATIONAL ("GSI") FAILED TO MEET ITS PRIMARY DEALER QUOTING OBLIGATIONS IN ACCORDANCE WITH THE AGENCY CONTRACT BETWEEN GSI AND AKK AND THE RELEVANT MARKET MAKING RULES. THE AKK IMPOSED A FINE ON GSI IN THE AMOUNT OF HUF 500,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON AUGUST 1, 2019. GOLDMANS SACHS & CO. LLC (GSCO) 4140 05/14/2019 ICE FUTURES EUROPE, Europe THE ICE FUTURES EUROPE ("THE EXCHANGE") CONDUCTED AN INVESTIGATION OF THE FIRM'S PRE- AND POST-TRADE CONTROLS. AS A RESULT OF ITS FINDINGS IN THE INVESTIGATION, THE EXCHANGE ALLEGES THAT THE TIMING AND NATURE OF CERTAIN ORDERS WAS MANIPULATIVE, VIOLATING EXCHANGE RULES A.11.1 (D), E.2.1(B), E.2.2 (A)(VI), (XIII) AND (XIV), E.2.2A AND G.20. THE EXCHANGE'S ASSERTIONS WERE REFERRED TO THE AUTHORISATION, RULES AND CONDUCT (ARC) COMMITTEE. WITHOUT ADMITTING OR DENYING THE ASSERTIONS, GSCO ENTERED A SETTLEMENT AGREEMENT WITH THE EXCHANGE. ON OCTOBER 4, 2019, THE EXCHANGE ISSUED A DISCIPLINARY NOTICE: SETTLEMENT OF DISCIPLINARY PROCEEDINGS AGAINST GSCO, CONFIRMING THE TERMS OF THE SETTLEMENT WERE 1) ON THE OCCASION DESCRIBED, GSCO HAD NOT ACTED IN COMPLIANCE WITH THE EXCHANGE'S RULES, SPECIFICALLY RULES A.11.1(D), E.2.2(A)(XIII) AND (XIV), AND G.20., AND 2) GSCO PAID A TOTAL SETTLEMENT AMOUNT OF 125,000 Pounds, INCLUSIVE OF A DISCRETIONARY 1/3 DISCOUNT FROM 187,500. GSCO PAID THE 125,000 BY SUBMISSION OF A WIRE ON OCTOBER 2, 2019. GOLDMAN SACHS INTERNATIONAL (GSI) H 9-2018 03/14/2019 FRANKFURT STOCK EXCHANGE, Germany A BREACH OF ORGANIZATIONAL DUTIES BY FORWARDING UNFLAGGED ORDERS TRANSMITTED BY ONE OF OUR CUSTOMERS VIA DIRECT ELECTRONIC ACCESS TO THE XETRA TRADING PLATFORM OF THE FRANKFURT STOCK EXCHANGE. THIS IS SPECIFICALLY IN REFERENCE TO SECTION 3 (1) OF THE CONDITIONS FOR BUSINESS TRANSACTIONS. A FURTHER BREACH OF THE ORGANIZATIONAL DUTIES OF THE PARTY AS THE INDIRECT TRADING PARTICIPANT WERE NOT AWARE OF THE FWB'S CROSS-TRADE RULES SHOWS THAT THE PARTY DID NOT INFORM OR ONLY INADEQUATELY INFORMED ITS CUSTOMER OF THE FWB'S STOCK EXCHANGE RULES. THIS IS SPECIFICALLY IN REFERENCE TO SECTION 37 (3) OF THE EXCHANGE RULES FOR THE FRANKFURTER WERTPAPIERBORSE. THE FINE IMPOSED BY FWB WAS IN THE AMOUNT OF 3,000 EUR, WHICH WAS PAID BY GSI BY WIRE ON MAY 31, 2019. GOLDMAN SACHS INTERNATIONAL (GSI) 142888 03/28/2019 FINANCIAL CONDUCT AUTHORITY, United Kingdom THE FCA HAS IMPOSED A FINANCIAL PENALTY OF 34,344,700 POUNDS ON GOLDMAN SACHS INTERNATIONAL ("GSI") FOR FAILURE TO PROVIDE ACCURATE AND TIMELY INFORMATION IN RELATION TO CERTAIN REPORTABLE TRANSACTIONS TO THE FINANCIAL CONDUCT AUTHORITY ("FCA") IN ALLEGED VIOLATION OF SUP 17.4.1EU, SUP 17.1.4R AND SUP 15.6.1R. GSI ALSO FAILED TO TAKE REASONABLE CARE TO ORGANISE AND CONTROL ITS AFFAIRS RESPONSIBLY AND EFFECTIVELY IN RESPECT OF ITS TRANSACTION REPORTING IN ALLEGED VIOLATION OF PRINCIPLE 3 OF THE FCA'S PRINCIPLES FOR BUSINESSES. THE FINE WAS IMPOSED PURSUANT TO SECTION 206 OF THE FINANCIAL SERVICES AND MARKETS ACT 2000. THE FINE IMPOSED BY THE FINANCIAL CONDUCT AUTHORITY WAS IN THE AMOUNT OF 49,063,900. HOWEVER, GOLDMAN SACHS INTERNATIONAL AGREED TO RESOLVE THE CASE AND THEREFORE QUALIFIED FOR A 30% DISCOUNT IN THE OVERALL PENALTY REDUCING THE FINE TO 34,344,700. THE FINE WAS PAID BY WIRE ON APRIL 2, 2019. WHILE THE ACTUAL PAYMENT OF THE FINE WAS MADE IN POUND STERLING, THE EQUIVALENT U.S. DOLLAR VALUE ON THE DATE OF THE WIRE WAS $44,768,316.4, WHICH AMOUNT IS REFLECTED IN ITEM 12.A. ABOVE. GOLDMAN SACHS INTERNATIONAL (GSI) H 9-2018 11/05/2018 FRANKFURT STOCK EXCHANGE, Germany A BREACH OF ORGANIZATIONAL DUTIES BY FORWARDING UNFLAGGED ORDERS TRANSMITTED BY ONE OF OUR CUSTOMERS VIA DIRECT ELECTRONIC ACCESS TO THE XETRA TRADING PLATFORM OF THE FRANKFURT STOCK EXCHANGE. THIS IS SPECIFICALLY IN REFERENCE TO SECTION 3 (1) OF THE CONDITIONS FOR BUSINESS TRANSACTIONS. A FURTHER BREACH OF THE ORGANIZATIONAL DUTIES OF THE PARTY AS THE INDIRECT TRADING PARTICIPANT WERE NOT AWARE OF THE FWB'S CROSS-TRADE RULES SHOWS THAT THE PARTY DID NOT INFORM OR ONLY INADEQUATELY INFORMED ITS CUSTOMER OF THE FWB'S STOCK EXCHANGE RULES. THIS IS SPECIFICALLY IN REFERENCE TO SECTION 37 (3) OF THE EXCHANGE RULES FOR THE FRANKFURTER WERTPAPIERBORSE. THE FINE IMPOSED BY FWB WAS IN THE AMOUNT OF 3,000 EUR, WHICH WAS PAID BY GSI BY WIRE ON MAY 31, 2019. GOLDMAN SACHS GROUP, INC. Matter of GS Group and GS Bank USA 05/01/2018 THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES, United States 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. 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"). GOLDMAN SACHS PAID A CIVIL MONETARY PENALTY IN THE AMOUNT OF $54,750,000 ON MAY 8, 2018. GOLDMAN SACHS INTERNATIONAL (GSI) GZ: WA 17-WP 3121-2017/0003 09/19/2017 FEDERAL FINANCIAL SUPERVISORY AUTHORITY OF GERMANY, Germany ON SEPTEMBER 19, 2017 FEDERAL FINANCIAL SUPERVISORY AUTHORITY OF GERMANY (BUNDESANSTALT FUR FINANZDIENSTLEISTUNGSAUFSICHT - "BAFIN") HAS ALLEGED CERTAIN BREACHES BY GOLDMAN SACHS INTERNATIONAL ("GSI") IN MARCH 2017 OF SECTIONS 21(1) AND 25(1) OF THE GERMAN SECURITIES TRADING ACT (WERTPAPIERHANDELSGESETZ - "WPHG") AS A RESULT OF GSI'S LATE SUBMISSION OF A SHAREHOLDER VOTING RIGHTS NOTIFICATION. ON AUGUST 12, 2019 BAFIN IMPOSED AN ADMINISTRATIVE FINE ON GSI IN THE AMOUNT OF 800,000 EUROS FOR A BREACH OF SECTION 130(1) OF THE GERMAN ACT OF BREACHES OF ADMINISTRATIVE REGULATIONS IN CONJUNCTION WITH SECTION 25(1) OF THE GERMAN SECURITIES TRADING ACT. THIS FINE CONCLUDED CASES WA 17-WP 3121-2017/0003 AND WA 17-WP 3120-2016/0060. THE FINE IMPOSED BY BAFIN WAS IN THE AMOUNT OF 800,000 EUR, WHICH WAS PAID BY GSI BY WIRE ON SEPTEMBER 4, 2019. GOLDMAN SACHS INTERNATIONAL (GSI) GZ: WA 17-WP 3120-2016/0060 05/02/2017 FEDERAL FINANCIAL SUPERVISORY AUTHORITY OF GERMANY, Germany ON MAY 2, 2017 FEDERAL FINANCIAL SUPERVISORY AUTHORITY OF GERMANY (BUNDESANSTALT FUR FINANZDIENSTLEISTUNGSAUFSICHT - "BAFIN") HAS ALLEGED CERTAIN BREACHES BY GOLDMAN SACHS INTERNATIONAL ("GSI") IN MAY 2016 OF SECTIONS 21(1) AND 25(1) OF THE GERMAN SECURITIES TRADING ACT (WERTPAPIERHANDELSGESETZ - "WPHG") AS A RESULT OF GSI'S LATE SUBMISSION OF A SHAREHOLDER VOTING RIGHTS NOTIFICATION. ON AUGUST 12, 2019 BAFIN IMPOSED AN ADMINISTRATIVE FINE ON GSI IN THE AMOUNT OF 800,000 EUROS FOR A BREACH OF SECTION 130(1) OF THE GERMAN ACT OF BREACHES OF ADMINISTRATIVE REGULATIONS IN CONJUNCTION WITH SECTION 25(1) OF THE GERMAN SECURITIES TRADING ACT. THIS FINE CONCLUDED CASES WA 17-WP 3121-2017/0003 AND WA 17-WP 3120-2016/0060. THE FINE IMPOSED BY BAFIN WAS IN THE AMOUNT OF 800,000 EUR, WHICH WAS PAID BY GSI BY WIRE ON SEPTEMBER 4, 2019. GOLDMAN SACHS INTERNATIONAL 20/4962 02/24/2021 FINANSTILSYNET, NORWAY 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. 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 15, 2021. GOLDMAN SACHS BANK USA Matter of GS Group and GS Bank USA 05/01/2018 THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES, UNITED STATES 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. ON MAY 1, 2018, GOLDMAN SACHS AND THE DFS ENTERED INTO A CONSENT ORDER UNDER NEW YORK STATE BANKING LAWS 39 AND 44 (THE "CONSENT ORDER"). GOLDMAN SACHS PAID A CIVIL MONETARY PENALTY IN THE AMOUNT OF $54,750,000 ON MAY 8, 2018. Goldman Sachs Mexico, S.A. de C.V. Casa de Bolsa 211-2/81637-RDGH/2020 08/19/2020 NATIONAL BANKING AND SECURITIES COMMISSION, Mexico On August 19, 2020, Goldman Sachs Mexico, S.A. de C.V. Casa de Bolsa ("MCBO") received a fine imposed by the National Banking and Securities Commission (Comision Nacional Bancaria y de Valores - "CNBV") of 403,000 pesos (approximately 18,500 USD), for an alleged violation of article 212, paragraph one, sub-section I, of the LMV. CNBV alleged MCBO failed to maintain an appropriate financial crimes risk assessment policy. MCBO paid the fine of 403,000 pesos on September 29, 2020. An administrative and a judicial appeal were filed, leading ultimately on March 2022 to a resolve of this matter in favor of MCBO. The penalty imposed by the CNBV was annulled, and MCBO obtained a refund in the updated amount (based on inflation index) of 440,842 pesos (approximately 20,700 USD). An administrative and a judicial appeal were filed, leading ultimately on March 2022 to a resolve of this matter in favor of MCBO. The penalty imposed by the CNBV was annulled, and MCBO obtained a refund in the updated amount (based on inflation index) of 440,842 pesos (approximately 20,700 USD). Goldman Sachs Bank USA 2024-CFPB-0011 10/23/2024 Consumer Financial Protection Bureau ON OCTOBER 23, 2024, GOLDMAN SACHS BANK USA ("GS BANK") ENTERED INTO A CONSENT ORDER (THE "ORDER") WITH THE CONSUMER FINANCIAL PROTECTION BUREAU ("CFPB") RELATED TO THE ADMINISTRATION OF THE APPLE CARD BETWEEN 2019 AND 2021. SPECIFICALLY, THE CFPB CONDUCTED AN INVESTIGATION OF GS BANK'S HANDLING OF DISPUTES AND ITS OFFERING OF THE INTEREST-FREE PURCHASE PROMOTION KNOWN AS APPLE CARD MONTHLY INSTALLMENTS ("ACMI"). IN THE ORDER, THE CFPB ALLEGED THAT BETWEEN DECEMBER 2019 AND APPROXIMATELY JULY 2020, GS BANK MADE MISLEADING REPRESENTATIONS ABOUT ACMI ENROLLMENT AND, BETWEEN DECEMBER 2019 AND APPROXIMATELY MAY 2021, MISREPRESENTED HOW REFUNDS TO CONSUMERS' ACMI AND NON-ACMI BALANCES WOULD BE APPLIED. IN ADDITION, THE CFPB ALLEGED THAT GS BANK'S HANDLING OF CREDIT CARD TRANSACTION DISPUTES BETWEEN PRODUCT LAUNCH IN AUGUST 2019 AND APPROXIMATELY DECEMBER 2021 VIOLATED THE TRUTH IN LENDING ACT AND ITS IMPLEMENTING REGULATION Z, AND ALSO INVOLVED UNFAIR PRACTICES UNDER THE CONSUMER FINANCIAL PROTECTION ACT OF 2010. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS IN THE ORDER, GS BANK STIPULATED TO THE ENTRY OF THE ORDER AND AGREED TO PAY A $45 MILLION CIVIL MONEY PENALTY TO THE CFPB, $19.8 MILLION IN REDRESS TO CONSUMERS WITH CREDIT GIVEN FOR RESTITUTION GS BANK ALREADY PROVIDED TO AFFECTED CONSUMERS, TO REFRAIN FROM VIOLATING RELEVANT STATUES AND REGULATIONS, AND TO TAKE CERTAIN OTHER REMEDIAL MEASURES, INCLUDING CREATING AND IMPLEMENTING A COMPREHENSIVE COMPLIANCE PLAN DESIGNED TO ENSURE COMPLIANCE WITH APPLICABLE LAWS. Goldman Sachs Specjalistyczny Fundusz Inwestycyjny Otwarty 1472-SPP-2.4227.4.2.2025.1.ID 01/14/2025 Second Mazovian Tax Office in Warsaw On January 14, 2025, the Second Mazovian Tax Office in Warsaw (the Polish Tax Authority) imposed a fine of PLN 3,700 (approximately USD 900) against Goldman Sachs Specjalistyczny Fundusz Inwestycyjny Otwarty (the Fund) for non-compliance with a Polish tax requirement to notify the Polish Tax Authority of the web address on which the Fund posted its tax strategy for the fiscal year 2022. The Fund correctly published its full tax strategy on its website but missed the statutory deadline to forward the web address to the Polish Tax Authority. The Polish Tax Authority imposed a fine of PLN 3,700 (approximately USD 900), which the Fund paid on January 28, 2025. Goldman Sachs (India) Alternative Investment Management Private Limited M&A/10/2020/01/CD 01/14/2025 Competition Commission of India On January 14, 2025, the Competition Commission of India (CCI) issued an order directing Goldman Sachs (India) Alternative Investment Management Private Limited (GS AIM) to pay a civil penalty of INR 40,00,000 (USD 46,000) for failing to notify a certain investment transaction to the CCI, which the CCI considers was required under Section 6(2) of the Competition Act, 2002. The penalty is payable within 60 days. The CCI imposed a civil penalty of INR 40,00,000 (USD 46,000), payable within 60 days. GS AIM is arranging the payment. N Y Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org 02/27/2023 Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org GREENSKY LLC (GREENSKY) 2021-CFPB-0004 07/12/2021 CONSUMER FINANCIAL PROTECTION BUREAU ("CFPB"), United States ON JULY 12, 2021, THE CONSUMER FINANCIAL PROTECTION BUREAU ("CFPB") ENTERED A CONSENT ORDER AGAINST GREENSKY LLC ("GREENSKY") AFTER DETERMINING GREENSKY VIOLATED SECTIONS 1031(A) AND 1036(A)(1)(B) OF THE CONSUMER FINANCIAL PROTECTION ACT. FROM MARCH 2014 THROUGH JULY 2021, THE CFPB IDENTIFIED MULTIPLE INSTANCES OF GREENSKY ENGAGING IN UNFAIR ACTS AND PRACTICES WITH REGARD TO LOANS TO CONSUMERS WHO DID NOT AUTHORIZE THEM AND BY STRUCTURING ITS LOAN ORIGINATION AND SERVICING ACTIVITIES IN A MANNER THAT ENABLED UNAUTHORIZED LOANS. ON JULY 12, 2021, THE CONSUMER FINANCIAL PROTECTION BUREAU ("CFPB") ENTERED A CONSENT ORDER AGAINST GREENSKY LLC ("GREENSKY") AFTER DETERMINING GREENSKY VIOLATED SECTIONS 1031(A) AND 1036(A)(1)(B) OF THE CONSUMER FINANCIAL PROTECTION ACT. IN ADDITION, A CIVIL PENALTY OF $2,5000,000 WAS ORDERED TO BE PAID TO THE CFPB. GOLDMAN SACHS (ASIA) L.L.C. (GS ASIA) Action imposed following inquiry/investigation related to 1MDB 10/22/2020 HONG KONG SECURITIES AND FUTURES COMMISSION, Hong Kong THE HONG KONG SECURITIES AND FUTURES COMMISSION ("HKSFC") ISSUED A STATEMENT OF DISCIPLINARY ACTION (THE "SFC STATEMENT") AGAINST GOLDMAN SACHS (ASIA) L.L.C. ("GS ASIA"), AN INDIRECT WHOLLY OWNED SUBSIDIARY OF THE GOLDMAN SACHS GROUP, INC., ON OCTOBER 22, 2020, RELATING TO GS ASIA'S FAILURE TO PROPERLY EXAMINE AND ADDRESS RED FLAGS IN CONNECTION WITH THE 1MALAYSIA DEVELOPMENT BERHAD ("1MDB") TRANSACTIONS AND TO DILIGENTLY SUPERVISE ITS SENIOR PERSONNEL IN CONNECTION WITH THEIR PARTICIPATION IN THE 1MDB TRANSACTIONS. GS ASIA PAID A FINANCIAL PENALTY IN THE AMOUNT OF $350,000,000 IN CONNECTION WITH THE SFC STATEMENT. GOLDMAN SACHS (SINGAPORE) PTE (GS SINGAPORE) 6422 5358 10/22/2020 THE MONETARY AUTHORITY OF SINGAPORE, Singapore ON OCTOBER 22, 2020, GOLDMAN SACHS (SINGAPORE) PTE ("GS SINGAPORE") RECEIVED A LETTER OF DIRECTION FROM THE MONETARY AUTHORITY OF SINGAPORE (THE "MAS LETTER"), REQUIRING GS SINGAPORE TO APPOINT AN INDEPENDENT AUDITOR TO REVIEW THE EFFECTIVENESS AND SUSTAINABILITY OF THE REMEDIAL MEASURES IMPLEMENTED BY GS SINGAPORE FOLLOWING THE MONETARY AUTHORITY OF SINGAPORE'S INSPECTION. THE MSA LETTER REQUIRES GS SINGAPORE TO APPOINT AN INDEPENDENT AUDITOR TO REVIEW THE EFFECTIVENESS AND SUSTAINABILITY OF THE REMEDIAL MEASURES IMPLEMENTED BY GS SINGAPORE FOLLOWING THE MONETARY AUTHORITY OF SINGAPORE'S INSPECTION. GOLDMAN SACHS (SINGAPORE) PTE (GS SINGAPORE) HHQ/DOW/TCK/308392/7 10/22/2020 THE MONETARY AUTHORITY OF SINGAPORE, Singapore ON OCTOBER 22, 2020, GOLDMAN SACHS (SINGAPORE) PTE ("GS SINGAPORE") RECEIVED A NOTICE OF CONDITIONAL WARNING FROM THE SINGAPORE COMMERCIAL AFFAIRS DEPARTMENT ("SCAD"), AT THE DIRECTION OF THE SINGAPORE ATTORNEY GENERAL'S CHAMBERS (THE "SINGAPORE NOTICE"), WHICH ALLEGED GS SINGAPORE CORRUPTLY GAVE GRATIFICATION AS A REWARD IN RELATION TO EACH OF THE 1MALAYSIA DEVELOPMENT BERHAD BOND TRANSACTIONS. GS SINGAPORE PAID A FINANCIAL PENALTY IN THE AMOUNT OF $122,000,000 IN CONNECTION WITH THE SINGAPORE NOTICE. GOLDMAN SACHS INTERNATIONAL (GSI) 142888 10/22/2020 UK FINANCIAL CONDUCT AUTHORITY, United Kingdom GOLDMAN SACHS INTERNATIONAL ("GSI"), AN INDIRECT WHOLLY OWNED SUBSIDIARY OF THE GOLDMAN SACHS GROUP, INC., RECEIVED ON OCTOBER 22, 2020 A WARNING NOTICE FROM THE UK FINANCIAL CONDUCT AUTHORITY (THE "FCA" AND THE NOTICE, THE "FCA NOTICE"), WHICH CITES GSI'S FAILURE TO (I) ASSESS AND MANAGE THE RISKS ASSOCIATED WITH THE 1MALAYSIA DEVELOPMENT BERHAD TRANSACTIONS; (II) PROPERLY RECORD HOW GSI COMMITTEES ASSESSED AND MANAGED THOSE RISKS AND; (III) RESPOND APPROPRIATELY TO ALLEGATIONS OF BRIBERY AND MISCONDUCT. GSI PAID A FINANCIAL PENALTY IN THE AMOUNT OF $63,000,000 IN CONNECTION WITH THE FCA NOTICE. GOLDMAN SACHS INTERNATIONAL (GSI) 142888 10/22/2020 THE BANK OF ENGLAND PRUDENTIAL REGULATION AUTHORITY, United Kingdom GOLDMAN SACHS INTERNATIONAL ("GSI"), AN INDIRECT WHOLLY OWNED SUBSIDIARY OF THE GOLDMAN SACHS GROUP, INC., RECEIVED ON OCTOBER 22, 2020 A WARNING NOTICE FROM THE BANK OF ENGLAND PRUDENTIAL REGULATION AUTHORITY (THE "PRA" AND THE WARNING NOTICE, THE "PRA NOTICE"), WHICH CITES GSI'S FAILURE TO (I) ASSESS AND MANAGE THE RISKS ASSOCIATED WITH THE 1MALAYSIA DEVELOPMENT BERHAD TRANSACTIONS; (II) PROPERLY RECORD HOW GSI COMMITTEES ASSESSED AND MANAGED THOSE RISKS; AND (III) RESPOND APPROPRIATELY TO ALLEGATIONS OF BRIBERY AND MISCONDUCT. GSI PAID A FINANCIAL PENALTY IN THE AMOUNT OF $63,000,000 IN CONNECTION WITH THE PRA NOTICE. GOLDMAN SACHS GROUP, INC. (GS GROUP) 20-018-B-HC; 20-018-CMP-HC 10/22/2020 FEDERAL RESERVE, United States 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. 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. GOLDMAN SACHS GROUP, INC. (GS GROUP) Action imposed following inquiry/investigation related to 1MDB 10/22/2020 THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES, United States 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 SUPERINTENDENT 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. GS GROUP PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $150,000,000 TO THE DFS. GOLDMAN SACHS GROUP, INC. (GS GROUP) 18-015-B-HC; 18-015-CMP-HC 05/01/2018 THE FEDERAL RESERVE, United States 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. 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"). THE FIRM PAID A CIVIL MONETARY PENALTY IN THE AMOUNT OF $54,750,000 ON MAY 2, 2018. GOLDMAN SACHS BANK USA (GS BANK) 17-045-CMP-SM 01/12/2018 THE FEDERAL RESERVE, United States THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM (THE "FEDERAL RESERVE") ALLEGED THAT GOLDMAN SACHS BANK USA ("GS BANK"), ENGAGED IN A PATTERN OR PRACTICE OF VIOLATIONS UNDER SECTION 102(F)(2) OF THE NATIONAL FLOOD INSURANCE ACT, 42 U.S.C. 4012A(F). ON JANUARY 12, 2018, PRIOR TO THE TAKING OF ANY TESTIMONY OR ADJUDICATION OF OR FINDING ON ANY ISSUE OF FACT OR LAW, AND SOLELY FOR THE PURPOSE OF SETTLEMENT OF THE MATTER WITHOUT A FORMAL PROCEEDING BEING FILED AND WITHOUT THE NECESSITY FOR PROTRACTED OR EXTENDED HEARINGS OR TESTIMONY, GS BANK AND THE FEDERAL RESERVE ENTERED INTO AN ORDER OF ASSESSMENT OF A CIVIL MONEY PENALTY PURSUANT TO THE NATIONAL FLOOD INSURANCE ACT, AS AMENDED, WHICH ASSESSES GS BANK A CIVIL MONEY PENALTY IN THE AMOUNT OF $90,000, WHICH WAS PAID TO THE FEDERAL RESERVE BY SUBMISSION OF A CHECK ON JANUARY 12, 2018. GOLDMAN SACHS GROUP, INC. (GS GROUP) 17-047-CMP-HC; 17-047-CMP-SM 01/12/2018 THE FEDERAL RESERVE, United States 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). 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. GOLDMAN SACHS BANK USA (GS BANK) 17-047-CMP-HC; 17-047-CMP-SM 01/12/2018 THE FEDERAL RESERVE, United States 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). 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. GOLDMAN SACHS GROUP, INC 2017 / 158544 / 570; 2018 / 095899/ CNB / 110 01/04/2018 CZECH NATIONAL BANK , Czech Republic 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. 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. GOLDMAN SACHS (INDIA) SECURITIES PRIVATE LIMITED GIPL EAD-2/DSR/RG/14036/2017-PM/RR/02/2018-19 06/16/2017 SECURITIES AND EXCHANGE BOARD OF INDIA, India IN A NOTICE TO GOLDMAN SACHS (INDIA) SECURITIES PRIVATE LIMITED ("GIPL"), THE SECURITIES AND EXCHANGE BOARD OF INDIA ("SEBI") ALLEGED THAT GIPL MADE CERTAIN MISLEADING STATEMENTS TO SEBI FOLLOWING THE DEFERRAL OF A QUALIFIED INSTITUTIONAL PLACEMENT OF SECURITIES IN INDIA, IN ALLEGED VIOLATION OF PARAGRAPH 20 OF THE CODE OF CONDUCT FOR MERCHANT BANKERS UNDER THE SEBI (MERCHANT BANKERS) REGULATIONS, 1992. WITHOUT ADMITTING OR DENYING THE FINDINGS OF FACT AND CONCLUSIONS OF LAW, GIPL SUBMITTED A SETTLEMENT APPLICATION TO SEBI WHICH WAS ACCEPTED BY SEBI ON JUNE 29, 2018, IN WHICH GIPL AGREED TO MAKE A MONETARY PAYMENT TO SEBI IN THE AMOUNT OF 20,80,242 INDIAN RUPEES (INR), WHICH WAS PAID BY SUBMISSION OF A BANK DEMAND DRAFT ON JUNE 19, 2018. Goldman Sachs Group Matter of GS Group 10/28/2015 THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES, United States 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. 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"). GOLDMAN SACHS PAID A CIVIL MONETARY PENALTY IN THE AMOUNT OF $50 MILLION ON NOVEMBER 9, 2015. GOLDMAN SACHS BANK EUROPE SE (GSBE) GW 5-K 5112-100395-2020/0001 12/18/2020 FEDERAL FINANCIAL SUPERVISORY AUTHORITY OF GERMANY, Germany THE FEDERAL FINANCIAL SUPERVISORY AUTHORITY OF GERMANY ("BAFIN") CONDUCTED A SPECIAL AUDIT, PURSUANT TO SECTION 51, GELDWASCHEGESETZ - MONEY LAUNDERING ACT, AND SUBSEQUENTLY ISSUED AN ORDER AGAINST GOLDMAN SACHS BANK EUROPE SE ("GSBE") ON DECEMBER 18, 2020. THE ORDER REQUIRED REMEDIATION OF ALL DISCREPANCIES IDENITIFED IN THE SPECIAL AUDIT. ON DECEMBER 18, 2020, BAFIN ORDERED GSBE TO REMEDIATE ALL DISCREPANCIES IDENTIFIED IN THE SPECIAL AUDIT AND TO BEAR THE COSTS OF THE PROCEEDING RESULTING IN AN ADMINISTRATIVE FEE OF EUR 585 (APPROXIMATELY USD 478.09). THE FIRM ADDRESSED ALL REMEDIATIONS REQUIRED IN THE ORDER BY APRIL 28, 2021 AND NOTIFIED BAFIN OF THE STEPS TAKEN DURING THE REMEDIATION PROCESS ON MAY 14, 2021. GOLDMAN SACHS GROUP, INC. Matter of GS Group and GS Bank USA 05/01/2018 THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES, United States 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. ON MAY 1, 2018, GOLDMAN SACHS AND THE DFS ENTERED INTO A CONSENT ORDER UNDER NEW YORK STATE BANKING LAWS 39 AND 44 (THE "CONSENT ORDER"). GOLDMAN SACHS PAID A CIVIL MONETARY PENALTY IN THE AMOUNT OF $54,750,000 ON MAY 8, 2018. GOLDMAN SACHS BANK USA Matter of GS Group and GS Bank USA 05/01/2018 THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES, UNITED STATES 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. ON MAY 1, 2018, GOLDMAN SACHS AND THE DFS ENTERED INTO A CONSENT ORDER UNDER NEW YORK STATE BANKING LAWS 39 AND 44 (THE "CONSENT ORDER"). GOLDMAN SACHS PAID A CIVIL MONETARY PENALTY IN THE AMOUNT OF $54,750,000 ON MAY 8, 2018. Y Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org 02/27/2023 Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org GOLDMANS SACHS & CO. LLC (GSCO) 16-011-BH-C; 16-011-CMP-HC 08/02/2016 FEDERAL RESERVE, United States 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. 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"). THE FIRM PAID A CIVIL MONETARY PENALTY IN THE AMOUNT OF $36,300,000 ON AUGUST 3, 2016. Goldman Sachs Group Matter of GS Group 10/28/2015 THE NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES, United States 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. 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"). GOLDMAN SACHS PAID A CIVIL MONETARY PENALTY IN THE AMOUNT OF $50 MILLION ON NOVEMBER 9, 2015. N N Y GOLDMAN SACHS & CO. LLC LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2018059146502 04/04/2023 NASDAQ STOCK MARKET LLC C/O FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA") DEPARTMENT OF ENFORCEMENT BROOKFIELD PLACE 200 LIBERTY STREET, 11TH FLOOR, NEW YORK, NY 10281 ON APRIL 4, 2023, THE NASDAQ STOCK MARKET LLC ("NASDAQ") ACCEPTED A LETTER OF ACCEPTANCE, WAIVER, AND CONSENT ("AWC") SUBMITTED BY GOLDMAN SACHS & CO. LLC ("GSCO"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED NASDAQ'S FINDINGS. FINRA AND 11 EXCHANGES FOUND, AMONG OTHER THINGS, THAT GSCO INCORRECTLY MARKED 59,981,252 SHORT SALE ORDERS AS LONG OVER A 3-YEAR PERIOD FROM OCTOBER 2015 TO APRIL 2018. THE MISMARKED ORDERS WERE CAUSED BY GSCO'S IMPLEMENTATION OF AN UPGRADE TO RELEVANT AUTOMATED TRADING SOFTWARE THAT WAS INTENDED TO SIMPLIFY CERTAIN ORDER FLOW. ACCORDING TO THE AWC, THESE MISMARKED ORDERS VIOLATED RULE 200(G) OF THE EXCHANGE ACT. THE FINDINGS DIFFER AMONGTHE DIFFERENT EXCHANGES AND FINRA, BUT ALSO GENERALLY ALLEGE TRADE REPORTING AND RECORDKEEPING VIOLATIONS AS DESCRIBED IN THE AWC (NO. 2018059146502). THE FIRM CORRECTED THE CODING AND LOGIC ISSUES CAUSING THE MISMARKED ORDERS UPON NOTIFICATION OF THE SAME, HAS ENHANCED ITS ORDER MARKING SURVEILLANCE REPORT, AND ALSO ADDED AN ADDITIONAL CONTROL DESIGNED TO DETECT AND PREVENT THE ROUTING OF INACCURATELY MARKED SHORT SALE ORDERS. PURSUANT TO THE AWC, GSCO AGREED TO PAY A TOTAL MONETARY FINE IN THE AMOUNT OF $3,000,000. THE ALLOCATION AMOUNT PAYABLE TO NASDAQ IS $381,400, WHICH WILL BE AUTO-DEBITED. THE REMAINDER OF THE FINE WILL BE ALLOCATED TO CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., INVESTORS EXCHANGE LLC, NASDAQ PHLX LLC, NASDAQ BX, INC., NEW YORK STOCK EXCHANGE LLC, NYSE AMERICAN LLC, NYSE ARCA, INC. AND THE FINANCIAL INDUSTRY REGULATORY AUTHORITY FOR SIMILAR VIOLATIONS GOLDMAN SACHS & CO. LLC LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2018059146504 04/04/2023 NASDAQ PHLX LLC C/O FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA") DEPARTMENT OF ENFORCEMENT BROOKFIELD PLACE 200 LIBERTY STREET, 11TH FLOOR, NEW YORK, NY 10281 ON APRIL 4, 2023, NASDAQ PHLX LLC ("PHLX") ACCEPTED A LETTER OF ACCEPTANCE, WAIVER, AND CONSENT ("AWC") SUBMITTED BY GOLDMAN SACHS & CO. LLC ("GSCO"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED PHLX'S FINDINGS. FINRA AND 11 EXCHANGES FOUND, AMONG OTHER THINGS, THAT GSCO INCORRECTLY MARKED 59,981,252 SHORT SALE ORDERS AS LONG OVER A 3-YEAR PERIOD FROM OCTOBER 2015 TO APRIL 2018. THE MISMARKED ORDERS WERE CAUSED BY GSCO'S IMPLEMENTATION OF AN UPGRADE TO RELEVANT AUTOMATED TRADING SOFTWARE THAT WAS INTENDED TO SIMPLIFY CERTAIN ORDER FLOW. ACCORDING TO THE AWC, THESE MISMARKED ORDERS VIOLATED RULE 200(G) OF THE EXCHANGE ACT. THE FINDINGS DIFFER AMONGTHE DIFFERENT EXCHANGES AND FINRA, BUT ALSO GENERALLY ALLEGE TRADE REPORTING AND RECORDKEEPING VIOLATIONS AS DESCRIBED IN THE AWC (NO. 2018059146504). THE FIRM CORRECTED THE CODING AND LOGIC ISSUES CAUSING THE MISMARKED ORDERS UPON NOTIFICATION OF THE SAME, HAS ENHANCED ITS ORDER MARKING SURVEILLANCE REPORT, AND ALSO ADDED AN ADDITIONAL CONTROL DESIGNED TO DETECT AND PREVENT THE ROUTING OF INACCURATELY MARKED SHORT SALE ORDERS. PURSUANT TO THE AWC, GSCO AGREED TO PAY A TOTAL MONETARY FINE IN THE AMOUNT OF $3,000,000. THE ALLOCATION AMOUNT PAYABLE TO PHLX IS $87,100, WHICH WILL BE AUTO-DEBITED. THE REMAINDER OF THE FINE WILL BE ALLOCATED TO CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., INVESTORS EXCHANGE LLC, THE NASDAQ STOCK MARKET LLC, NASDAQ BX, INC., NEW YORK STOCK EXCHANGE LLC, NYSE AMERICAN LLC, NYSE ARCA, INC. AND THE FINANCIAL INDUSTRY REGULATORY AUTHORITY FOR SIMILAR VIOLATIONS. GOLDMAN SACHS & CO. LLC LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2018059146503 04/04/2023 NASDAQ BX, INC. C/O FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA") DEPARTMENT OF ENFORCEMENT BROOKFIELD PLACE 200 LIBERTY STREET, 11TH FLOOR, NEW YORK, NY 10281 ON APRIL 4, 2023, NASDAQ BX, INC. ("BX") ACCEPTED A LETTER OF ACCEPTANCE, WAIVER, AND CONSENT ("AWC") SUBMITTED BY GOLDMAN SACHS & CO. LLC ("GSCO"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED BX'S FINDINGS. FINRA AND 11 EXCHANGES FOUND, AMONG OTHER THINGS, THAT GSCO INCORRECTLY MARKED 59,981,252 SHORT SALE ORDERS AS LONG OVER A 3-YEAR PERIOD FROM OCTOBER 2015 TO APRIL 2018. THE MISMARKED ORDERS WERE CAUSED BY GSCO'S IMPLEMENTATION OF AN UPGRADE TO RELEVANT AUTOMATED TRADING SOFTWARE THAT WAS INTENDED TO SIMPLIFY CERTAIN ORDER FLOW. ACCORDING TO THE AWC, THESE MISMARKED ORDERS VIOLATED RULE 200(G) OF THE EXCHANGE ACT. THE FINDINGS DIFFER AMONGTHE DIFFERENT EXCHANGES AND FINRA, BUT ALSO GENERALLY ALLEGE TRADE REPORTING AND RECORDKEEPING VIOLATIONS AS DESCRIBED IN THE AWC (NO. 2018059146503). THE FIRM CORRECTED THE CODING AND LOGIC ISSUES CAUSING THE MISMARKED ORDERS UPON NOTIFICATION OF THE SAME, HAS ENHANCED ITS ORDER MARKING SURVEILLANCE REPORT, AND ALSO ADDED AN ADDITIONAL CONTROL DESIGNED TO DETECT AND PREVENT THE ROUTING OF INACCURATELY MARKED SHORT SALE ORDERS. PURSUANT TO THE AWC, GSCO AGREED TO PAY A TOTAL MONETARY FINE IN THE AMOUNT OF $3,000,000. THE ALLOCATION AMOUNT PAYABLE TO BX IS $70,900, WHICH WILL BE AUTO-DEBITED. THE REMAINDER OF THE FINE WILL BE ALLOCATED TO CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., INVESTORS EXCHANGE LLC, THE NASDAQ STOCK MARKET LLC, NASDAQ PHLX, INC., NEW YORK STOCK EXCHANGE LLC, NYSE AMERICAN LLC, NYSE ARCA, INC. AND THE FINANCIAL INDUSTRY REGULATORY AUTHORITY FOR SIMILAR VIOLATIONS GOLDMAN SACHS & CO. LLC LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2018059146501 04/04/2023 FINANCIAL INDUSTRY REGULATORY AUTHORITY DEPARTMENT OF ENFORCEMENT 200 LIBERTY STREET, 11TH FLOOR, NEW YORK, NY 10281 ON APRIL 4, 2023, THE FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA") ACCEPTED A LETTER OF ACCEPTANCE, WAIVER, AND CONSENT ("AWC") SUBMITTED BY GOLDMAN SACHS & CO. LLC ("GSCO"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED FINRA'S FINDINGS. FINRA AND 11 EXCHANGES FOUND, AMONG OTHER THINGS, THAT GSCO INCORRECTLY MARKED 59,981,252 SHORT SALE ORDERS AS LONG OVER A 3-YEAR PERIOD FROM OCTOBER 2015 TO APRIL 2018. THE MISMARKED ORDERS WERE CAUSED BY GSCO'S IMPLEMENTATION OF AN UPGRADE TO RELEVANT AUTOMATED TRADING SOFTWARE THAT WAS INTENDED TO SIMPLIFY CERTAIN ORDER FLOW. ACCORDING TO THE AWC, THESE MISMARKED ORDERS VIOLATED RULE 200(G) OF THE EXCHANGE ACT. THE FINDINGS DIFFER AMONG THE DIFFERENT EXCHANGES AND FINRA, BUT ALSO GENERALLY ALLEGE TRADE REPORTING AND RECORDKEEPING VIOLATIONS AS DESCRIBED IN THE AWC (NO. 2018059146501). THE FIRM CORRECTED THE CODING AND LOGIC ISSUES CAUSING THE MISMARKED ORDERS UPON NOTIFICATION OF THE SAME, HAS ENHANCED ITS ORDER MARKING SURVEILLANCE REPORT, AND ALSO ADDED AN ADDITIONAL CONTROL DESIGNED TO DETECT AND PREVENT THE ROUTING OF INACCURATELY MARKED SHORT SALE ORDERS. PURSUANT TO THE AWC, GSCO AGREED TO PAY A TOTAL MONETARY FINE IN THE AMOUNT OF $3,000,000. THE ALLOCATION AMOUNT PAYABLE TO FINRA IS $1,147,500, WHICH WAS PAID IN FULL VIA WIRE ON APRIL 19, 2023. THE REMAINDER OF THE FINE WILL BE ALLOCATED TO CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., INVESTORS EXCHANGE LLC, NASDAQ STOCK MARKET LLC, NASDAQ BX, INC., NASDAQ PHLX LLC, NEW YORK STOCK EXCHANGE LLC, NYSE AMERICAN LLC, AND NYSE ARCA, INC. FOR SIMILAR VIOLATIONS. GOLDMAN SACHS & CO. LLC LETTER OF CONSENT STAR NO. 2018059146508/FILE NO. URE-40-05 03/22/2023 CBOE BZX EXCHANGE, INC. CBOE GLOBAL MARKETS, INC. 28851 NETWORK PLACE CHICAGO, IL60673-1288 ON MARCH 24, 2023, CBOE BZX EXCHANGE, INC. ("BZX" OR THE "EXCHANGE") ACCEPTED A LETTER OF CONSENT ("LOC") SUBMITTED BY GOLDMAN SACHS & CO. LLC ("GSCO"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE EXCHANGE'S FINDINGS. FINRA AND 11 EXCHANGES FOUND, AMONG OTHER THINGS, THAT GSCO INCORRECTLY MARKED 59,981,252 SHORT SALE ORDERS AS LONG OVER A 3-YEAR PERIOD FROM OCTOBER 2015 TO APRIL 2018. THE MISMARKED ORDERS WERE CAUSED BY GSCO'S IMPLEMENTATION OF AN UPGRADE TO RELEVANT AUTOMATED TRADING SOFTWARE THAT WAS INTENDED TO SIMPLIFY CERTAIN ORDER FLOW. ACCORDING TO THE LOC, THESE MISMARKED ORDERS VIOLATED RULE 200(G) OF THE EXCHANGE ACT. THE FINDINGS DIFFER AMONG THE DIFFERENT EXCHANGES AND FINRA, BUT ALSO GENERALLY ALLEGE TRADE REPORTING AND RECORDKEEPING VIOLATIONS AS DESCRIBED IN THE LOC. THE FIRM CORRECTED THE CODING AND LOGIC ISSUES CAUSING THE MISMARKED ORDERS UPON NOTIFICATION OF THE SAME, HAS ENHANCED ITS ORDER MARKING SURVEILLANCE REPORT, AND ALSO ADDED AN ADDITIONAL CONTROL DESIGNED TO DETECT AND PREVENT THE ROUTING OF INACCURATELY MARKED SHORT SALE ORDERS. PURSUANT TO THE LOC, GSCO AGREED TO PAY A TOTAL MONETARY FINE IN THE AMOUNT OF $3,000,000. THE ALLOCATION AMOUNT PAYABLE TO BZX IS $395,044, WHICH WAS PAID IN FULL VIA WIRE ON APRIL 05, 2023. THE REMAINDER OF THE FINE WILL BE ALLOCATED TO CBOE BYX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ STOCK MARKET LLC, NASDAQ PHLX LLC, NASDAQ BX, INC., INVESTORS EXCHANGE LLC, NEW YORK STOCK EXCHANGE LLC, NYSE AMERICAN LLC, NYSE ARCA, INC. AND THE FINANCIAL INDUSTRY REGULATORY AUTHORITY FOR SIMILAR VIOLATIONS GOLDMAN SACHS & CO. LLC LETTER OF CONSENT STAR NO. 2018059146509/FILE NO. URE-40-06 03/22/2023 CBOE BYX EXCHANGE, INC. CBOE GLOBAL MARKETS, INC. 28851 NETWORK PLACE CHICAGO, IL60673-1288 ON MARCH 24, 2023, CBOE BYX EXCHANGE, INC. ("BYX" OR THE "EXCHANGE") ACCEPTED A LETTER OF CONSENT ("LOC") SUBMITTED BY GOLDMAN SACHS & CO. LLC ("GSCO"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE EXCHANGE'S FINDINGS. FINRA AND 11 EXCHANGES FOUND, AMONG OTHER THINGS, THAT GSCO INCORRECTLY MARKED 59,981,252 SHORT SALE ORDERS AS LONG OVER A 3-YEAR PERIOD FROM OCTOBER 2015 TO APRIL 2018. THE MISMARKED ORDERS WERE CAUSED BY GSCO'S IMPLEMENTATION OF AN UPGRADE TO RELEVANT AUTOMATED TRADING SOFTWARE THAT WAS INTENDED TO SIMPLIFY CERTAIN ORDER FLOW. ACCORDING TO THE LOC, THESE MISMARKED ORDERS VIOLATED RULE 200(G) OF THE EXCHANGE ACT. THE FINDINGS DIFFER AMONG THE DIFFERENT EXCHANGES AND FINRA, BUT ALSO GENERALLY ALLEGE TRADE REPORTING AND RECORDKEEPING VIOLATIONS AS DESCRIBED IN THE LOC. THE FIRM CORRECTED THE CODING AND LOGIC ISSUES CAUSING THE MISMARKED ORDERS UPON NOTIFICATION OF THE SAME, HAS ENHANCED ITS ORDER MARKING SURVEILLANCE REPORT, AND ALSO ADDED AN ADDITIONAL CONTROL DESIGNED TO DETECT AND PREVENT THE ROUTING OF INACCURATELY MARKED SHORT SALE ORDERS. PURSUANT TO THE LOC, GSCO AGREED TO PAY A TOTAL MONETARY FINE IN THE AMOUNT OF $3,000,000. THE ALLOCATION AMOUNT PAYABLE TO BYX IS $89,758, WHICH WAS PAID IN FULL VIA WIRE ON APRIL 05, 2023. THE REMAINDER OF THE FINE WILL BE ALLOCATED TO CBOE BZX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ STOCK MARKET LLC, NASDAQ PHLX LLC, NASDAQ BX, INC., INVESTORS EXCHANGE LLC, NEW YORK STOCK EXCHANGE LLC, NYSE AMERICAN LLC, NYSE ARCA, INC. AND THE FINANCIAL INDUSTRY REGULATORY AUTHORITY FOR SIMILAR VIOLATIONS. GOLDMAN SACHS & CO. LLC LETTER OF CONSENT STAR NO. 2018059146511/FILE NO. URE-40-07 03/22/2023 CBOE EDGX EXCHANGE, INC. CBOE GLOBAL MARKETS, INC. 28851 NETWORK PLACE CHICAGO, IL 60673-1288 ON MARCH 24, 2023, CBOE EDGX EXCHANGE, INC. ("EDGX" OR THE "EXCHANGE") ACCEPTED A LETTER OF CONSENT ("LOC") SUBMITTED BY GOLDMAN SACHS & CO. LLC ("GSCO"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE EXCHANGE'S FINDINGS. FINRA AND 11 EXCHANGES FOUND, AMONG OTHER THINGS, THAT GSCO INCORRECTLY MARKED 59,981,252 SHORT SALE ORDERS AS LONG OVER A 3-YEAR PERIOD FROM OCTOBER 2015 TO APRIL 2018. THE MISMARKED ORDERS WERE CAUSED BY GSCO'S IMPLEMENTATION OF AN UPGRADE TO RELEVANT AUTOMATED TRADING SOFTWARE THAT WAS INTENDED TO SIMPLIFY CERTAIN ORDER FLOW. ACCORDING TO THE LOC, THESE MISMARKED ORDERS VIOLATED RULE 200(G) OF THE EXCHANGE ACT. THE FINDINGS DIFFER AMONG THE DIFFERENT EXCHANGES AND FINRA, BUT ALSO GENERALLY ALLEGE TRADE REPORTING AND RECORDKEEPING VIOLATIONS AS DESCRIBED IN THE LOC. THE FIRM CORRECTED THE CODING AND LOGIC ISSUES CAUSING THE MISMARKED ORDERS UPON NOTIFICATION OF THE SAME, HAS ENHANCED ITS ORDER MARKING SURVEILLANCE REPORT, AND ALSO ADDED AN ADDITIONAL CONTROL DESIGNED TO DETECT AND PREVENT THE ROUTING OF INACCURATELY MARKED SHORT SALE ORDERS. PURSUANT TO THE LOC, GSCO AGREED TO PAY A TOTAL MONETARY FINE IN THE AMOUNT OF $3,000,000. THE ALLOCATION AMOUNT PAYABLE TO EDGX IS $166,850, WHICH WAS PAID IN FULL VIA WIRE ON APRIL 05, 2023. THE REMAINDER OF THE FINE WILL BE ALLOCATED TO CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., NASDAQ STOCK MARKET LLC, NASDAQ PHLX LLC, NASDAQ BX, INC., INVESTORS EXCHANGE LLC, NEW YORK STOCK EXCHANGE LLC, NYSE AMERICAN LLC, NYSE ARCA, INC. AND THE FINANCIAL INDUSTRY REGULATORY AUTHORITY FOR SIMILAR VIOLATIONS. GOLDMAN SACHS & CO. LLC LETTER OF CONSENT STAR NO. 2018059146510/FILE NO. URE-40-08 03/22/2023 CBOE EDGA EXCHANGE, INC. CBOE GLOBAL MARKETS, INC. 28851 NETWORK PLACE CHICAGO, IL 60673-1288 ON MARCH 24, 2023, CBOE EDGA EXCHANGE, INC. ("EDGA" OR THE "EXCHANGE") ACCEPTED A LETTER OF CONSENT ("LOC") SUBMITTED BY GOLDMAN SACHS & CO. LLC ("GSCO"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE EXCHANGE'S FINDINGS. FINRA AND 11 EXCHANGES FOUND, AMONG OTHER THINGS, THAT GSCO INCORRECTLY MARKED 59,981,252 SHORT SALE ORDERS AS LONG OVER A 3-YEAR PERIOD FROM OCTOBER 2015 TO APRIL 2018. THE MISMARKED ORDERS WERE CAUSED BY GSCO'S IMPLEMENTATION OF AN UPGRADE TO RELEVANT AUTOMATED TRADING SOFTWARE THAT WAS INTENDED TO SIMPLIFY CERTAIN ORDER FLOW. ACCORDING TO THE LOC, THESE MISMARKED ORDERS VIOLATED RULE 200(G) OF THE EXCHANGE ACT. THE FINDINGS DIFFER AMONG THE DIFFERENT EXCHANGES AND FINRA, BUT ALSO GENERALLY ALLEGE TRADE REPORTING AND RECORDKEEPING VIOLATIONS AS DESCRIBED IN THE LOC. THE FIRM CORRECTED THE CODING AND LOGIC ISSUES CAUSING THE MISMARKED ORDERS UPON NOTIFICATION OF THE SAME, HAS ENHANCED ITS ORDER MARKING SURVEILLANCE REPORT, AND ALSO ADDED AN ADDITIONAL CONTROL DESIGNED TO DETECT AND PREVENT THE ROUTING OF INACCURATELY MARKED SHORT SALE ORDERS. PURSUANT TO THE LOC, GSCO AGREED TO PAY A TOTAL MONETARY FINE IN THE AMOUNT OF $3,000,000. THE ALLOCATION AMOUNT PAYABLE TO EDGA IS $148,348, WHICH WAS PAID IN FULL VIA WIRE ON APRIL 05, 2023. THE REMAINDER OF THE FINE WILL BE ALLOCATED TO CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ STOCK MARKET LLC, NASDAQ PHLX LLC, NASDAQ BX, INC., NEW YORK STOCK EXCHANGE LLC, NYSE AMERICAN LLC, NYSE ARCA, INC. AND THE FINANCIAL INDUSTRY REGULATORY AUTHORITY FOR SIMILAR VIOLATIONS. GOLDMAN SACHS & CO. LLC LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2018059146512 04/04/2023 INVESTORS EXCHANGE LLC C/O FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA") DEPARTMENT OF ENFORCEMENT BROOKFIELD PLACE 200 LIBERTY STREET, 11TH FLOOR NEW YORK, NY 10281 ON APRIL 4, 2023, THE INVESTORS EXCHANGE LLC ("IEX" OR THE "EXCHANGE") ACCEPTED A LETTER OF ACCEPTANCE, WAIVER, AND CONSENT ("AWC") SUBMITTED BY GOLDMAN SACHS & CO. LLC ("GSCO"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE EXCHANGE'S FINDINGS. FINRA AND 11 EXCHANGES FOUND, AMONG OTHER THINGS, THAT GSCO INCORRECTLY MARKED 59,981,252 SHORT SALE ORDERS AS LONG OVER A 3-YEAR PERIOD FROM OCTOBER 2015 TO APRIL 2018. THE MISMARKED ORDERS WERE CAUSED BY GSCO'S IMPLEMENTATION OF AN UPGRADE TO RELEVANT AUTOMATED TRADING SOFTWARE THAT WAS INTENDED TO SIMPLIFY CERTAIN ORDER FLOW. ACCORDING TO THE AWC, THESE MISMARKED ORDERS VIOLATED RULE 200(G) OF THE EXCHANGE ACT. THE FINDINGS DIFFER AMONG THE DIFFERENT EXCHANGES AND FINRA, BUT ALSO GENERALLY ALLEGE TRADE REPORTING AND RECORDKEEPING VIOLATIONS AS DESCRIBED IN THE AWC (NO. 2018059146512). THE FIRM CORRECTED THE CODING AND LOGIC ISSUES CAUSING THE MISMARKED ORDERS UPON NOTIFICATION OF THE SAME, HAS ENHANCED ITS ORDER MARKING SURVEILLANCE REPORT, AND ALSO ADDED AN ADDITIONAL CONTROL DESIGNED TO DETECT AND PREVENT THE ROUTING OF INACCURATELY MARKED SHORT SALE ORDERS. PURSUANT TO THE AWC, GSCO AGREED TO PAY A TOTAL MONETARY FINE IN THE AMOUNT OF $3,000,000. THE ALLOCATION AMOUNT PAYABLE TO IEX IS $141,100, WHICH WAS PAID IN FULL VIA WIRE ON APRIL 20, 2023. THE REMAINDER OF THE FINE WILL BE ALLOCATED TO CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ STOCK MARKET LLC, NASDAQ PHLX LLC, NASDAQ BX, INC., NEW YORK STOCK EXCHANGE LLC, NYSE AMERICAN LLC, NYSE ARCA, INC. AND THE FINANCIAL INDUSTRY REGULATORY AUTHORITY FOR SIMILAR VIOLATIONS. GOLDMAN SACHS & CO. LLC LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2018059146506 04/03/2023 NYSE ARCA, INC. C/O FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA") DEPARTMENT OF ENFORCEMENT BROOKFIELD PLACE 200 LIBERTY STREET, 11TH FLOOR NEW YORK, NY 10281 ON MARCH 21, 2023, THE NYSE ARCA, INC. ("NYSE ARCA" OR THE "EXCHANGE") ACCEPTED A LETTER OF ACCEPTANCE, WAIVER, AND CONSENT ("AWC") SUBMITTED BY GOLDMAN SACHS & CO. LLC ("GSCO"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE EXCHANGE'S FINDINGS. FINRA AND 11 EXCHANGES FOUND, AMONG OTHER THINGS, THAT GSCO INCORRECTLY MARKED 59,981,252 SHORT SALE ORDERS AS LONG OVER A 3-YEAR PERIOD FROM OCTOBER 2015 TO APRIL 2018. THE MISMARKED ORDERS WERE CAUSED BY GSCO'S IMPLEMENTATION OF AN UPGRADE TO RELEVANT AUTOMATED TRADING SOFTWARE THAT WAS INTENDED TO SIMPLIFY CERTAIN ORDER FLOW. ACCORDING TO THE AWC, THESE MISMARKED ORDERS VIOLATED RULE 200(G) OF THE EXCHANGE ACT. THE FINDINGS DIFFER AMONG THE DIFFERENT EXCHANGES AND FINRA, BUT ALSO GENERALLY ALLEGE TRADE REPORTING AND RECORDKEEPING VIOLATIONS AS DESCRIBED IN THE AWC (NO. 2018059146506). THE FIRM CORRECTED THE CODING AND LOGIC ISSUES CAUSING THE MISMARKED ORDERS UPON NOTIFICATION OF THE SAME, HAS ENHANCED ITS ORDER MARKING SURVEILLANCE REPORT, AND ALSO ADDED AN ADDITIONAL CONTROL DESIGNED TO DETECT AND PREVENT THE ROUTING OF INACCURATELY MARKED SHORT SALE ORDERS. PURSUANT TO THE AWC, GSCO AGREED TO PAY A TOTAL MONETARY FINE IN THE AMOUNT OF $3,000,000. THE ALLOCATION AMOUNT PAYABLE TO NYSE ARCA IS $227,500, WHICH WAS PAID IN FULL VIA WIRE ON APRIL 20, 2023. THE REMAINDER OF THE FINE WILL BE ALLOCATED TO CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ STOCK MARKET LLC, NASDAQ PHLX LLC, NASDAQ BX, INC., NEW YORK STOCK EXCHANGE LLC, NYSE AMERICAN LLC, INVESTORS EXCHANGE LLC, AND THE FINANCIAL INDUSTRY REGULATORY AUTHORITY FOR SIMILAR VIOLATIONS. GOLDMAN SACHS & CO. LLC LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2018059146507 04/03/2023 NEW YORK STOCK EXCHANGE LLC C/O FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA") DEPARTMENT OF ENFORCEMENT BROOKFIELD PLACE 200 LIBERTY STREET, 11TH FLOOR NEW YORK, NY 10281 ON MARCH 21, 2023, THE NEW YORK STOCK EXCHANGE LLC ("NYSE" OR THE "EXCHANGE") ACCEPTED A LETTER OF ACCEPTANCE, WAIVER, AND CONSENT ("AWC") SUBMITTED BY GOLDMAN SACHS & CO. LLC ("GSCO"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE EXCHANGE'S FINDINGS. FINRA AND 11 EXCHANGES FOUND, AMONG OTHER THINGS, THAT GSCO INCORRECTLY MARKED 59,981,252 SHORT SALE ORDERS AS LONG OVER A 3-YEAR PERIOD FROM OCTOBER 2015 TO APRIL 2018. THE MISMARKED ORDERS WERE CAUSED BY GSCO'S IMPLEMENTATION OF AN UPGRADE TO RELEVANT AUTOMATED TRADING SOFTWARE THAT WAS INTENDED TO SIMPLIFY CERTAIN ORDER FLOW. ACCORDING TO THE AWC, THESE MISMARKED ORDERS VIOLATED RULE 200(G) OF THE EXCHANGE ACT. THE FINDINGS DIFFER AMONG THE DIFFERENT EXCHANGES AND FINRA, BUT ALSO GENERALLY ALLEGE TRADE REPORTING AND RECORDKEEPING VIOLATIONS AS DESCRIBED IN THE AWC (NO. 2018059146507). THE FIRM CORRECTED THE CODING AND LOGIC ISSUES CAUSING THE MISMARKED ORDERS UPON NOTIFICATION OF THE SAME, HAS ENHANCED ITS ORDER MARKING SURVEILLANCE REPORT, AND ALSO ADDED AN ADDITIONAL CONTROL DESIGNED TO DETECT AND PREVENT THE ROUTING OF INACCURATELY MARKED SHORT SALE ORDERS. PURSUANT TO THE AWC, GSCO AGREED TO PAY A TOTAL MONETARY FINE IN THE AMOUNT OF $3,000,000. THE ALLOCATION AMOUNT PAYABLE TO NYSE IS $92,500, WHICH WAS PAID IN FULL VIA WIRE ON APRIL 20, 2023. THE REMAINDER OF THE FINE WILL BE ALLOCATED TO CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ STOCK MARKET LLC, NASDAQ PHLX LLC, NASDAQ BX, INC., NYSE AMERICAN LLC, NYSE ARCA, INC, INVESTORS EXCHANGE LLC AND THE FINANCIAL INDUSTRY REGULATORY AUTHORITY FOR SIMILAR VIOLATIONS. GOLDMAN SACHS & CO. LLC LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2018059146505 04/03/2023 NYSE AMERICAN LLC /O FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA") DEPARTMENT OF ENFORCEMENT BROOKFIELD PLACE 200 LIBERTY STREET, 11TH FLOOR NEW YORK, NY 10281 ON MARCH 21, 2023, THE NYSE AMERICAN LLC ("NYSE AMERICAN" OR THE "EXCHANGE") ACCEPTED A LETTER OF ACCEPTANCE, WAIVER, AND CONSENT ("AWC") SUBMITTED BY GOLDMAN SACHS & CO. LLC ("GSCO"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE EXCHANGE'S FINDINGS. FINRA AND 11 EXCHANGES FOUND, AMONG OTHER THINGS, THAT GSCO INCORRECTLY MARKED 59,981,252 SHORT SALE ORDERS AS LONG OVER A 3-YEAR PERIOD FROM OCTOBER 2015 TO APRIL 2018. THE MISMARKED ORDERS WERE CAUSED BY GSCO'S IMPLEMENTATION OF AN UPGRADE TO RELEVANT AUTOMATED TRADING SOFTWARE THAT WAS INTENDED TO SIMPLIFY CERTAIN ORDER FLOW. ACCORDING TO THE AWC, THESE MISMARKED ORDERS VIOLATED RULE 200(G) OF THE EXCHANGE ACT. THE FINDINGS DIFFER AMONG THE DIFFERENT EXCHANGES AND FINRA, BUT ALSO GENERALLY ALLEGE TRADE REPORTING AND RECORDKEEPING VIOLATIONS AS DESCRIBED IN THE AWC (NO. 2018059146505). THE FIRM CORRECTED THE CODING AND LOGIC ISSUES CAUSING THE MISMARKED ORDERS UPON NOTIFICATION OF THE SAME, HAS ENHANCED ITS ORDER MARKING SURVEILLANCE REPORT, AND ALSO ADDED AN ADDITIONAL CONTROL DESIGNED TO DETECT AND PREVENT THE ROUTING OF INACCURATELY MARKED SHORT SALE ORDERS. PURSUANT TO THE AWC, GSCO AGREED TO PAY A TOTAL MONETARY FINE IN THE AMOUNT OF $3,000,000. THE ALLOCATION AMOUNT PAYABLE TO NYSE AMERICAN IS $52,000 WHICH WAS PAID IN FULL VIA WIRE ON APRIL 20, 2023. THE REMAINDER OF THE FINE WILL BE ALLOCATED TO CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ STOCK MARKET LLC, NASDAQ PHLX LLC, NASDAQ BX, INC., NEW YORK STOCK EXCHANGE LLC, NYSE ARCA, INC., INVESTORS EXCHANGE LLC AND THE FINANCIAL INDUSTRY REGULATORY AUTHORITY FOR SIMILAR VIOLATIONS. GOLDMAN SACHS & CO. LLC RE: 23-CH-2308 03/17/2023 CME GROUP INC. 20 SOUTH WACKER DRIVE, CHICAGO, ILLINOIS 60606 ON JANUARY 19, 2023, THE CLEARING HOUSE RISK COMMITTEE OF THE CME GROUP INC. ("CME") REVIEWED GOLDMAN SACHS & CO. LLC'S ("GSCO") RESPONSE, AND ISSUED A CHARGE LETTER DATED JANUARY 20, 2023, WHICH ALLEGES THAT GSCO VIOLATED CME CUSTOMER GROSS MARGINING TECHNICAL OVERVIEW REQUIREMENTS AND CME RULE 980.G. PURSUANT TO AN OFFER OF SETTLEMENT, IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE RULE VIOLATION UPON WHICH THE PENALTY WAS BASED, GSCO AGREED TO PAY A FINE IN THE AMOUNT OF $50,000. THE FINE WAS PAID IN FULL VIA GSCO'S CME CLEARING FIRM BANK ACCOUNT ON MARCH 31, 2023. J. ARON & CO. LLC RE: SUMMARY FINE - CASE NO. 2022-014 03/02/2023 ICE FUTURES U.S. 353 NORTH CLARK STREET, SUITE 3100, CHICAGO, IL 60654 ON MARCH 2, 2023, THE ICE FUTURES U.S. ("IFUS" OR "EXCHANGE") MARKET REGULATION DEPARTMENT COMPLETED A REVIEW OF BLOCK TRADES SUBMITTED BY J. ARON & CO. LLC ("J. ARON") BETWEEN JULY 2021 AND NOVEMBER 2021, AND FOUND THAT ON MULTIPLE INSTANCES, J. ARON SUBMITTED BLOCK TRADES TO THE EXCHANGE BEYOND THE REQUIRED REPORTING WINDOW THEREBY VIOLATING IFUS RULE 4.07(C). PURSUANT TO IFUS RULE 21.02, J. ARON WAS ISSUED A SUMMARY FINE IN THE AMOUNT OF $5,000 FOR THE VIOLATIONS. THE FINE WAS PAID IN FULL BY SUBMISSION OF A WIRE ON MARCH 17, 2023. GOLDMAN SACHS & CO. LLC (GSCO) 2018059146504 04/22/2022 NASDAQ PHLX LLC ("PHLX"), United States ON APRIL 4, 2023, NASDAQ PHLX LLC ("PHLX") ACCEPTED A LETTER OF ACCEPTANCE, WAIVER, AND CONSENT ("AWC") SUBMITTED BY GOLDMANS SACHS & CO. LLC ("GSCO"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED PHLX'S FINDINGS. FINRA AND 11 EXCHANGES FOUND, AMONG OTHER THINGS, THAT GSCO INCORRECTLY MARKED 59,981,252 SHORT SALE ORDERS AS LONG OVER A 3-YEAR PERIOD FROM OCTOBER 2015 TO APRIL 2018. THE MISMARKED ORDERS WERE CAUSED BY GSCO'S IMPLEMENTATION OF AN UPGRADE TO RELEVANT AUTOMATED TRADING SOFTWARE THAT WAS INTENDED TO SIMPLIFY CERTAIN ORDER FLOW. ACCORDING TO THE AWC, THESE MISMARKED ORDERS VIOLATED RULE 200(G) OF THE EXCHANGE ACT. THE FINDINGS DIFFER AMONG THE DIFFERENT EXCHANGES AND FINRA, BUT ALSO GENERALLY ALLEGE TRADE REPORTING AND RECORDKEEPING VIOLATIONS AS DESCRIBED IN THE AWC (NO. 2018059146504). THE FIRM CORRECTED THE CODING AND LOGIC ISSUES CAUSING THE MISMARKED ORDERS UPON NOTIFICATION OF THE SAME, HAS ENHANCED ITS ORDER MARKING SURVEILLANCE REPORT, AND ALSO ADDED AN ADDITIONAL CONTROL DESIGNED TO DETECT AND PREVENT THE ROUTING OF INACCURATELY MARKED SHORT SALE ORDERS. PURSUANT TO THE AWC, GSCO AGREED TO PAY A TOTAL MONETARY FINE IN THE AMOUNT OF $3,000,000. THE ALLOCATION AMOUNT PAYABLE TO PHLX IS $87,100, WHICH WILL BE AUTO-DEBITED. THE REMAINDER OF THE FINE WILL BE ALLOCATED TO CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., INVESTORS EXCHANGE LLC, THE NASDAQ STOCK MARKET LLC, NASDAQ BX, INC., NEW YORK STOCK EXCHANGE LLC, NYSE AMERICAN LLC, NYSE ARCA, INC. AND THE FINANCIAL INDUSTRY REGULATORY AUTHORITY FOR SIMILAR VIOLATIONS. GOLDMAN SACHS & CO. LLC (GSCO) 23-CH-2308 03/17/2023 CME GROUP, United States ON JANUARY 19, 2023, THE CLEARING HOUSE RISK COMMITTEE OF THE CME GROUP INC. ("CME") REVIEWED GOLDMAN SACHS & CO. LLC'S ("GSCO") RESPONSE, AND ISSUED A CHARGE LETTER DATED JANUARY 20, 2023, WHICH ALLEGES THAT GSCO VIOLATED CME CUSTOMER GROSS MARGINING TECHNICAL OVERVIEW REQUIREMENTS AND CME RULE 980.G. PURSUANT TO AN OFFER OF SETTLEMENT, IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE RULE VIOLATION UPON WHICH THE PENALTY WAS BASED, GSCO AGREED TO PAY A FINE IN THE AMOUNT OF $50,000. THE FINE WAS PAID IN FULL VIA GSCO'S CME CLEARING FIRM BANK ACCOUNT ON MARCH 31, 2023. GOLDMAN SACHS & CO. LLC (GSCO) STAR NO. 20180591465-10/FILE NO. URE-40-08 04/22/2022 CBOE EDGA EXCHANGE, INC., United States ON MARCH 24, 2023, CBOE EDGA EXCHANGE, INC. ("EDGA" OR THE "EXCHANGE") ACCEPTED A LETTER OF CONSENT ("LOC") SUBMITTED BY GOLDMANS SACHS & CO. LLC ("GSCO"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE EXCHANGE'S FINDINGS. FINRA AND 11 EXCHANGES FOUND, AMONG OTHER THINGS, THAT GSCO INCORRECTLY MARKED 59,981,252 SHORT SALE ORDERS AS LONG OVER A 3-YEAR PERIOD FROM OCTOBER 2015 TO APRIL 2018. THE MISMARKED ORDERS WERE CAUSED BY GSCO'S IMPLEMENTATION OF AN UPGRADE TO RELEVANT AUTOMATED TRADING SOFTWARE THAT WAS INTENDED TO SIMPLIFY CERTAIN ORDER FLOW. ACCORDING TO THE LOC, THESE MISMARKED ORDERS VIOLATED RULE 200(G) OF THE EXCHANGE ACT. THE FINDINGS DIFFER AMONG THE DIFFERENT EXCHANGES AND FINRA. BUT ALSO GENERALLY ALLEGE TRADE REPORTING AND RECORDKEEPING VIOLATIONS AS DESCRIBED IN THE LOC. THE FIRM CORRECTED THE CODING AND LOGIC ISSUES CAUSING THE MISMARKED ORDERS UPON NOTIFICATION OF THE SAME, HAS ENHANCED ITS ORDER MARKING SURVEILLANCE REPORT, AND ALSO ADDED AN ADDITIONAL CONTROL DESIGNED TO DETECT AND PREVENT THE ROUTING OF INACCURATELY MARKED SHORT SALE ORDERS. PURSUANT TO THE LOC, GSCO AGREED TO PAY A TOTAL MONETARY FINE IN THE AMOUNT OF $3,000,000. THE ALLOCATION AMOUNT PAYABLE TO EDGA IS $148,348, WHICH WAS PAID IN FULL VIA WIRE ON APRIL 05, 2023. THE REMAINDER OF THE FINE WILL BE ALLOCATED TO CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ STOCK MARKET LLC, NASDAQ PHLX LLC, NASDAQ BX, INC., NEW YORK STOCK EXCHANGE LLC, NYSE AMERICAN LLC, NYSE ARCA, INC. AND THE FINANCIAL INDUSTRY REGULATORY AUTHORITY FOR SIMILAR VIOLATIONS. GOLDMAN SACHS & CO. LLC (GSCO) STAR NO. 20180591465-09/FILE NO. URE-40-06 04/22/2022 CBOE EDGA EXCHANGE, INC., United States ON MARCH 24, 2023, CBOE BYX EXCHANGE, INC. ("BYX" OR THE "EXCHANGE") ACCEPTED A LETTER OF CONSENT ("LOC") SUBMITTED BY GOLDMANS SACHS & CO. LLC ("GSCO"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE EXCHANGE'S FINDINGS. FINRA AND 11 EXCHANGES FOUND, AMONG OTHER THINGS, THAT GSCO INCORRECTLY MARKED 59,981,252 SHORT SALE ORDERS AS LONG OVER A 3-YEAR PERIOD FROM OCTOBER 2015 TO APRIL 2018. THE MISMARKED ORDERS WERE CAUSED BY GSCO'S IMPLEMENTATION OF AN UPGRADE TO RELEVANT AUTOMATED TRADING SOFTWARE THAT WAS INTENDED TO SIMPLIFY CERTAIN ORDER FLOW. ACCORDING TO THE LOC, THESE MISMARKED ORDERS VIOLATED RULE 200(G) OF THE EXCHANGE ACT. THE FINDINGS DIFFER AMONG THE DIFFERENT EXCHANGES AND FINRA, BUT ALSO GENERALLY ALLEGE TRADE REPORTING AND RECORDKEEPING VIOLATIONS AS DESCRIBED IN THE LOC. THE FIRM CORRECTED THE CODING AND LOGIC ISSUES CAUSING THE MISMARKED ORDERS UPON NOTIFICATION OF THE SAME, HAS ENHANCED ITS ORDER MARKING SURVEILLANCE REPORT, AND ALSO ADDED AN ADDITIONAL CONTROL DESIGNED TO DETECT AND PREVENT THE ROUTING OF INACCURATELY MARKED SHORT SALE ORDERS. PURSUANT TO THE LOC, GSCO AGREED TO PAY A TOTAL MONETARY FINE IN THE AMOUNT OF $3,000,000. THE ALLOCATION AMOUNT PAYABLE TO BYX IS $89,758, WHICH WAS PAID IN FULL VIA WIRE ON APRIL 05, 2023. THE REMAINDER OF THE FINE WILL BE ALLOCATED TO CBOE BZX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ STOCK MARKET LLC, NASDAQ PHLX LLC, NASDAQ BX, INC., INVESTORS EXCHANGE LLC, NEW YORK STOCK EXCHANGE LLC, NYSE AMERICAN LLC, NYSE ARCA, INC. AND THE FINANCIAL INDUSTRY REGULATORY AUTHORITY FOR SIMILAR VIOLATIONS. GOLDMAN SACHS & CO. LLC (GSCO) STAR NO. 20180591465-11/FILE NO. URE-40-07 04/22/2022 CBOE EDGA EXCHANGE, INC., United States ON MARCH 24, 2023, CBOE EDGX EXCHANGE, INC. ("EDGX" OR THE "EXCHANGE") ACCEPTED A LETTER OF CONSENT ("LOC") SUBMITTED BY GOLDMANS SACHS & CO. LLC ("GSCO"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE EXCHANGE'S FINDINGS. FINRA AND 11 EXCHANGES FOUND, AMONG OTHER THINGS, THAT GSCO INCORRECTLY MARKED 59,981,252 SHORT SALE ORDERS AS LONG OVER A 3-YEAR PERIOD FROM OCTOBER 2015 TO APRIL 2018. THE MISMARKED ORDERS WERE CAUSED BY GSCO'S IMPLEMENTATION OF AN UPGRADE TO RELEVANT AUTOMATED TRADING SOFTWARE THAT WAS INTENDED TO SIMPLIFY CERTAIN ORDER FLOW. ACCORDING TO THE LOC, THESE MISMARKED ORDERS VIOLATED RULE 200(G) OF THE EXCHANGE ACT. THE FINDINGS DIFFER AMONG THE DIFFERENT EXCHANGES AND FINRA, BUT ALSO GENERALLY ALLEGE TRADE REPORTING AND RECORDKEEPING VIOLATIONS AS DESCRIBED IN THE LOC. THE FIRM CORRECTED THE CODING AND LOGIC ISSUES CAUSING THE MISMARKED ORDERS UPON NOTIFICATION OF THE SAME, HAS ENHANCED ITS ORDER MARKING SURVEILLANCE REPORT, AND ALSO ADDED AN ADDITIONAL CONTROL DESIGNED TO DETECT AND PREVENT THE ROUTING OF INACCURATELY MARKED SHORT SALE ORDERS. PURSUANT TO THE LOC, GSCO AGREED TO PAY A TOTAL MONETARY FINE IN THE AMOUNT OF $3,000,000. THE ALLOCATION AMOUNT PAYABLE TO EDGX IS $166,850, WHICH WAS PAID IN FULL VIA WIRE ON APRIL 05, 2023. THE REMAINDER OF THE FINE WILL BE ALLOCATED TO CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., NASDAQ STOCK MARKET LLC, NASDAQ PHLX LLC, NASDAQ BX, INC., INVESTORS EXCHANGE LLC, NEW YORK STOCK EXCHANGE LLC, NYSE AMERICAN LLC, NYSE ARCA, INC. AND THE FINANCIAL INDUSTRY REGULATORY AUTHORITY FOR SIMILAR VIOLATIONS. GOLDMAN SACHS & CO. LLC (GSCO) STAR NO. 20180591465-08/FILE NO. URE-40-05 04/22/2022 CBOE EDGA EXCHANGE, INC., United States ON MARCH 24, 2023, CBOE BZX EXCHANGE, INC. ("BZX" OR THE "EXCHANGE") ACCEPTED A LETTER OF CONSENT ("LOC") SUBMITTED BY GOLDMANS SACHS & CO. LLC ("GSCO"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE EXCHANGE'S FINDINGS. FINRA AND 11 EXCHANGES FOUND, AMONG OTHER THINGS, THAT GSCO INCORRECTLY MARKED 59,981,252 SHORT SALE ORDERS AS LONG OVER A 3-YEAR PERIOD FROM OCTOBER 2015 TO APRIL 2018. THE MISMARKED ORDERS WERE CAUSED BY GSCO'S IMPLEMENTATION OF AN UPGRADE TO RELEVANT AUTOMATED TRADING SOFTWARE THAT WAS INTENDED TO SIMPLIFY CERTAIN ORDER FLOW. ACCORDING TO THE LOC, THESE MISMARKED ORDERS VIOLATED RULE 200(G) OF THE EXCHANGE ACT. THE FINDINGS DIFFER AMONG THE DIFFERENT EXCHANGES AND FINRA, BUT ALSO GENERALLY ALLEGE TRADE REPORTING AND RECORDKEEPING VIOLATIONS AS DESCRIBED IN THE LOC. THE FIRM CORRECTED THE CODING AND LOGIC ISSUES CAUSING THE MISMARKED ORDERS UPON NOTIFICATION OF THE SAME, HAS ENHANCED ITS ORDER MARKING SURVEILLANCE REPORT, AND ALSO ADDED AN ADDITIONAL CONTROL DESIGNED TO DETECT AND PREVENT THE ROUTING OF INACCURATELY MARKED SHORT SALE ORDERS. PURSUANT TO THE LOC, GSCO AGREED TO PAY A TOTAL MONETARY FINE IN THE AMOUNT OF $3,000,000. THE ALLOCATION AMOUNT PAYABLE TO BZX IS $395,044, WHICH WAS PAID IN FULL VIA WIRE ON APRIL 05, 2023. THE REMAINDER OF THE FINE WILL BE ALLOCATED TO CBOE BYX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ STOCK MARKET LLC, NASDAQ PHLX LLC, NASDAQ BX, INC., INVESTORS EXCHANGE LLC, NEW YORK STOCK EXCHANGE LLC, NYSE AMERICAN LLC, NYSE ARCA, INC. AND THE FINANCIAL INDUSTRY REGULATORY AUTHORITY FOR SIMILAR VIOLATIONS. GOLDMAN SACHS & CO. LLC (GSCO) 2018059146512 04/22/2022 NVESTORS EXCHANGE LLC, United States ON APRIL 4, 2023, INVESTORS EXCHANGE LLC ("IEX" OR THE "EXCHANGE") ACCEPTED A LETTER OF ACCEPTANCE, WAIVER, AND CONSENT ("AWC") SUBMITTED BY GOLDMANS SACHS & CO. LLC ("GSCO"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE EXCHANGE'S FINDINGS. FINRA AND 11 EXCHANGES FOUND, AMONG OTHER THINGS, THAT GSCO INCORRECTLY MARKED 59,981,252 SHORT SALE ORDERS AS LONG OVER A 3-YEAR PERIOD FROM OCTOBER 2015 TO APRIL 2018. THE MISMARKED ORDERS WERE CAUSED BY GSCO'S IMPLEMENTATION OF AN UPGRADE TO RELEVANT AUTOMATED TRADING SOFTWARE THAT WAS INTENDED TO SIMPLIFY CERTAIN ORDER FLOW. ACCORDING TO THE AWC, THESE MISMARKED ORDERS VIOLATED RULE 200(G) OF THE EXCHANGE ACT. THE FINDINGS DIFFER AMONG THE DIFFERENT EXCHANGES AND FINRA, BUT ALSO GENERALLY ALLEGE TRADE REPORTING AND RECORDKEEPING VIOLATIONS AS DESCRIBED IN THE AWC (NO. 2018059146512). THE FIRM CORRECTED THE CODING AND LOGIC ISSUES CAUSING THE MISMARKED ORDERS UPON NOTIFICATION OF THE SAME, HAS ENHANCED ITS ORDER MARKING SURVEILLANCE REPORT, AND ALSO ADDED AN ADDITIONAL CONTROL DESIGNED TO DETECT AND PREVENT THE ROUTING OF INACCURATELY MARKED SHORT SALE ORDERS. PURSUANT TO THE AWC, GSCO AGREED TO PAY A TOTAL MONETARY FINE IN THE AMOUNT OF $3,000,000. THE ALLOCATION AMOUNT PAYABLE TO IEX IS $141,100, WHICH WAS PAID IN FULL VIA WIRE ON APRIL 20, 2023. THE REMAINDER OF THE FINE WILL BE ALLOCATED TO CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ STOCK MARKET LLC, NASDAQ PHLX LLC, NASDAQ BX, INC., NEW YORK STOCK EXCHANGE LLC, NYSE AMERICAN LLC, NYSE ARCA, INC. AND THE FINANCIAL INDUSTRY REGULATORY AUTHORITY FOR SIMILAR VIOLATIONS. GOLDMAN SACHS & CO. LLC (GSCO) 2018059146501 04/22/2022 FINRA, United States ON APRIL 4, 2023, THE FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA") ACCEPTED A LETTER OF ACCEPTANCE, WAIVER, AND CONSENT ("AWC") SUBMITTED BY GOLDMANS SACHS & CO. LLC ("GSCO"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED FINRA'S FINDINGS. FINRA AND 11 EXCHANGES FOUND, AMONG OTHER THINGS, THAT GSCO INCORRECTLY MARKED 59,981,252 SHORT SALE ORDERS AS LONG OVER A 3-YEAR PERIOD FROM OCTOBER 2015 TO APRIL 2018. THE MISMARKED ORDERS WERE CAUSED BY GSCO'S IMPLEMENTATION OF AN UPGRADE TO RELEVANT AUTOMATED TRADING SOFTWARE THAT WAS INTENDED TO SIMPLIFY CERTAIN ORDER FLOW. ACCORDING TO THE AWC, THESE MISMARKED ORDERS VIOLATED RULE 200(G) OF THE EXCHANGE ACT. THE FINDINGS DIFFER AMONG THE DIFFERENT EXCHANGES AND FINRA, BUT ALSO GENERALLY ALLEGE TRADE REPORTING AND RECORDKEEPING VIOLATIONS AS DESCRIBED IN THE AWC (NO. 2018059146501). THE FIRM CORRECTED THE CODING AND LOGIC ISSUES CAUSING THE MISMARKED ORDERS UPON NOTIFICATION OF THE SAME, HAS ENHANCED ITS ORDER MARKING SURVEILLANCE REPORT, AND ALSO ADDED AN ADDITIONAL CONTROL DESIGNED TO DETECT AND PREVENT THE ROUTING OF INACCURATELY MARKED SHORT SALE ORDERS. PURSUANT TO THE AWC, GSCO AGREED TO PAY A TOTAL MONETARY FINE IN THE AMOUNT OF $3,000,000. THE ALLOCATION AMOUNT PAYABLE TO FINRA IS $1,147,500, WHICH WAS PAID IN FULL VIA WIRE ON APRIL 19, 2023. THE REMAINDER OF THE FINE WILL BE ALLOCATED TO CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., INVESTORS EXCHANGE LLC, NASDAQ STOCK MARKET LLC, NASDAQ BX, INC., NASDAQ PHLX LLC, NEW YORK STOCK EXCHANGE LLC, NYSE AMERICAN LLC, AND NYSE ARCA, INC. FOR SIMILAR VIOLATIONS. GOLDMAN SACHS & CO. LLC (GSCO) 2018059146506 04/22/2022 THE NYSE ARCA, INC., United States ON MARCH 21, 2023, THE NYSE ARCA, INC. ("NYSE ARCA" OR THE "EXCHANGE") ACCEPTED A LETTER OF ACCEPTANCE, WAIVER, AND CONSENT ("AWC") SUBMITTED BY GOLDMANS SACHS & CO. LLC ("GSCO"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE EXCHANGE'S FINDINGS. FINRA AND 11 EXCHANGES FOUND, AMONG OTHER THINGS, THAT GSCO INCORRECTLY MARKED 59,981,252 SHORT SALE ORDERS AS LONG OVER A 3-YEAR PERIOD FROM OCTOBER 2015 TO APRIL 2018. THE MISMARKED ORDERS WERE CAUSED BY GSCO'S IMPLEMENTATION OF AN UPGRADE TO RELEVANT AUTOMATED TRADING SOFTWARE THAT WAS INTENDED TO SIMPLIFY CERTAIN ORDER FLOW. ACCORDING TO THE AWC, THESE MISMARKED ORDERS VIOLATED RULE 200(G) OF THE EXCHANGE ACT. THE FINDINGS DIFFER AMONG THE DIFFERENT EXCHANGES AND FINRA, BUT ALSO GENERALLY ALLEGE TRADE REPORTING AND RECORDKEEPING VIOLATIONS AS DESCRIBED IN THE AWC (NO. 2018059146506). THE FIRM CORRECTED THE CODING AND LOGIC ISSUES CAUSING THE MISMARKED ORDERS UPON NOTIFICATION OF THE SAME, HAS ENHANCED ITS ORDER MARKING SURVEILLANCE REPORT, AND ALSO ADDED AN ADDITIONAL CONTROL DESIGNED TO DETECT AND PREVENT THE ROUTING OF INACCURATELY MARKED SHORT SALE ORDERS. PURSUANT TO THE AWC, GSCO AGREED TO PAY A TOTAL MONETARY FINE IN THE AMOUNT OF $3,000,000. THE ALLOCATION AMOUNT PAYABLE TO NYSE ARCA IS $227,500, WHICH WAS PAID IN FULL VIA WIRE ON APRIL 20, 2023. THE REMAINDER OF THE FINE WILL BE ALLOCATED TO CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ STOCK MARKET LLC, NASDAQ PHLX LLC, NASDAQ BX, INC., NEW YORK STOCK EXCHANGE LLC, NYSE AMERICAN LLC, INVESTORS EXCHANGE LLC, AND THE FINANCIAL INDUSTRY REGULATORY AUTHORITY FOR SIMILAR VIOLATIONS. GOLDMAN SACHS & CO. LLC (GSCO) 2018059146507 04/22/2022 THE NEW YORK STOCK EXCHANGE LLC, United States ON MARCH 21, 2023, THE NEW YORK STOCK EXCHANGE LLC ("NYSE" OR THE "EXCHANGE") ACCEPTED A LETTER OF ACCEPTANCE, WAIVER, AND CONSENT ("AWC") SUBMITTED BY GOLDMANS SACHS & CO. LLC ("GSCO"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE EXCHANGE'S FINDINGS. FINRA AND 11 EXCHANGES FOUND, AMONG OTHER THINGS, THAT GSCO INCORRECTLY MARKED 59,981,252 SHORT SALE ORDERS AS LONG OVER A 3-YEAR PERIOD FROM OCTOBER 2015 TO APRIL 2018. THE MISMARKED ORDERS WERE CAUSED BY GSCO'S IMPLEMENTATION OF AN UPGRADE TO RELEVANT AUTOMATED TRADING SOFTWARE THAT WAS INTENDED TO SIMPLIFY CERTAIN ORDER FLOW. ACCORDING TO THE AWC, THESE MISMARKED ORDERS VIOLATED RULE 200(G) OF THE EXCHANGE ACT. THE FINDINGS DIFFER AMONG THE DIFFERENT EXCHANGES AND FINRA, BUT ALSO GENERALLY ALLEGE TRADE REPORTING AND RECORDKEEPING VIOLATIONS AS DESCRIBED IN THE AWC (NO. 2018059146507). THE FIRM CORRECTED THE CODING AND LOGIC ISSUES CAUSING THE MISMARKED ORDERS UPON NOTIFICATION OF THE SAME, HAS ENHANCED ITS ORDER MARKING SURVEILLANCE REPORT, AND ALSO ADDED AN ADDITIONAL CONTROL DESIGNED TO DETECT AND PREVENT THE ROUTING OF INACCURATELY MARKED SHORT SALE ORDERS. PURSUANT TO THE AWC, GSCO AGREED TO PAY A TOTAL MONETARY FINE IN THE AMOUNT OF $3,000,000. THE ALLOCATION AMOUNT PAYABLE TO NYSE IS $92,500, WHICH WAS PAID IN FULL VIA WIRE ON APRIL 20, 2023. THE REMAINDER OF THE FINE WILL BE ALLOCATED TO CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ STOCK MARKET LLC, NASDAQ PHLX LLC, NASDAQ BX, INC., NYSE AMERICAN LLC, NYSE ARCA, INC, INVESTORS EXCHANGE LLC AND THE FINANCIAL INDUSTRY REGULATORY AUTHORITY FOR SIMILAR VIOLATIONS. GOLDMAN SACHS & CO. LLC (GSCO) 20180591465075 04/22/2022 NYSE AMERICAN LLC, United States ON MARCH 21, 2023, NYSE AMERICAN LLC ("NYSE AMERICAN" OR THE "EXCHANGE") ACCEPTED A LETTER OF ACCEPTANCE, WAIVER, AND CONSENT ("AWC") SUBMITTED BY GOLDMANS SACHS & CO. LLC ("GSCO"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE EXCHANGE'S FINDINGS. FINRA AND 11 EXCHANGES FOUND, AMONG OTHER THINGS, THAT GSCO INCORRECTLY MARKED 59,981,252 SHORT SALE ORDERS AS LONG OVER A 3-YEAR PERIOD FROM OCTOBER 2015 TO APRIL 2018. THE MISMARKED ORDERS WERE CAUSED BY GSCO'S IMPLEMENTATION OF AN UPGRADE TO RELEVANT AUTOMATED TRADING SOFTWARE THAT WAS INTENDED TO SIMPLIFY CERTAIN ORDER FLOW. ACCORDING TO THE AWC, THESE MISMARKED ORDERS VIOLATED RULE 200(G) OF THE EXCHANGE ACT. THE FINDINGS DIFFER AMONG THE DIFFERENT EXCHANGES AND FINRA, BUT ALSO GENERALLY ALLEGE TRADE REPORTING AND RECORDKEEPING VIOLATIONS AS DESCRIBED IN THE AWC (NO. 2018059146505). THE FIRM CORRECTED THE CODING AND LOGIC ISSUES CAUSING THE MISMARKED ORDERS UPON NOTIFICATION OF THE SAME, HAS ENHANCED ITS ORDER MARKING SURVEILLANCE REPORT, AND ALSO ADDED AN ADDITIONAL CONTROL DESIGNED TO DETECT AND PREVENT THE ROUTING OF INACCURATELY MARKED SHORT SALE ORDERS. PURSUANT TO THE AWC, GSCO AGREED TO PAY A TOTAL MONETARY FINE IN THE AMOUNT OF $3,000,000. THE ALLOCATION AMOUNT PAYABLE TO NYSE AMERICAN IS $52,000 WHICH WAS PAID IN FULL VIA WIRE ON APRIL 20, 2023. THE REMAINDER OF THE FINE WILL BE ALLOCATED TO CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., NASDAQ STOCK MARKET LLC, NASDAQ PHLX LLC, NASDAQ BX, INC., NEW YORK STOCK EXCHANGE LLC, NYSE ARCA, INC., INVESTORS EXCHANGE LLC AND THE FINANCIAL INDUSTRY REGULATORY AUTHORITY FOR SIMILAR VIOLATIONS. GOLDMAN SACHS & CO. LLC (GSCO) 2022-014 03/02/2023 THE ICE FUTURES U.S. MARKET, United States ON MARCH 2, 2023, THE ICE FUTURES U.S. ("IFUS" OR "EXCHANGE") MARKET REGULATION DEPARTMENT COMPLETED A REVIEW OF BLOCK TRADES SUBMITTED BY J. ARON & CO. LLC ("J. ARON") BETWEEN JULY 2021 AND NOVEMBER 2021, AND FOUND THAT ON MULTIPLE INSTANCES, J. ARON SUBMITTED BLOCK TRADES TO THE EXCHANGE BEYOND THE REQUIRED REPORTING WINDOW THEREBY VIOLATING IFUS RULE 4.07(C). PURSUANT TO IFUS RULE 21.02, J. ARON WAS ISSUED A SUMMARY FINE IN THE AMOUNT OF $5,000 FOR THE VIOLATIONS. THE FINE WAS PAID IN FULL BY SUBMISSION OF A WIRE ON MARCH 17, 2023. GOLDMAN SACHS & CO. LLC (GSCO) RSRH-22-6737 10/06/2022 THE CME GROUP INC., United States ON OCTOBER 6, 2022, THE MARKET REGULATION DEPARTMENT OF THE CME GROUP INC. ("CME") NOTIFIED GOLDMAN SACHS & CO. LLC ("GSCO") THAT CME'S 512 COMMITTEE FOUND THAT GSCO VIOLATED CME RULE 561 FOR LATE ADJUSTMENTS TO LARGE TRADER REPORTING OF CERTAIN LISTED FUTURES AND OPTIONS POSITIONS ON FIVE TRADE DATES IN SEPTEMBER 2022. CME IMPOSED A FINE IN THE AMOUNT OF $10,000, WHICH GSCO PAID BY SUBMISSION OF A WIRE ON OCTOBER 14, 2022. GOLDMAN SACHS & CO. LLC (GSCO) RSRH-22-6644 07/20/2022 CME GROUP INC., United States ON JULY 20, 2022, THE MARKET REGULATION DEPARTMENT OF THE CME GROUP INC. ("CME") NOTIFIED GOLDMAN SACHS & CO. LLC ("GSCO") THAT CME'S 512 COMMITTEE FOUND THAT GSCO VIOLATED CME RULE 561 FOR LATE ADJUSTMENTS TO LARGE TRADER REPORTING OF CERTAIN LISTED FUTURES AND OPTIONS POSITIONS ON SIX TRADE DATES BETWEEN JUNE AND JULY 2022. CME IMPOSED A FINE IN THE AMOUNT OF $7,000, WHICH GSCO PAID BY SUBMISSION OF A WIRE ON AUGUST 8, 2022. GOLDMAN SACHS INTERNATIONAL (GSI) 2020-033 06/29/2022 THE ICE FUTURES U.S., United States ON JUNE 29, 2022, A SUBCOMMITTEE OF THE ICE FUTURES U.S. BUSINESS CONDUCT COMMITTEE ("ICE") ALLEGED THAT GOLDMAN SACHS INTERNATIONAL ("GSI") MAY HAVE VIOLATED EXCHANGE RULES 4.04 AND 4.01(A) BETWEEN MAY 2020 AND JULY 2020 BY ENGAGING IN IMPROPER PRE-HEDGING AND NOT DILIGENTLY SUPERVISING THE ACTIVITIES OF ITS EMPLOYEES WITH REGARD TO ICE'S RULES ON PRE-HEDGING. IN ACCORDANCE WITH THE TERMS OF SETTLEMENT, IN WHICH GSI NEITHER ADMITTED NOR DENIED THE ALLEGED RULE VIOLATIONS, GSI AGREED TO PAY A MONETARY PENALTY OF $125,000 AND DISGORGE $1,319,249.80 IN ALLEGED PROFITS, WHICH GSI PAID IN FULL ON JULY 1, 2022. J. ARON & COMPANY LLC J. ARON 19-1158-BC 05/17/2022 CME Group Inc., United States ON MAY 17, 2022, A PANEL OF THE COMMODITY EXCHANGE (COMEX) BUSINESS CONDUCT COMMITTEE FOUND THAT, ON SEVERAL OCCASIONS IN MAY 2020 AND JULY 2020, J. ARON & COMPANY LLC ("J. ARON"), PRIOR TO ENGAGING IN ANY PRE-HEDGING ACTIVITY, FAILED TO MAKE CLEAR TO ITS COUNTERPARTY THAT IT WAS TRADING PRINCIPALLY THEREBY VIOLATING COMEX RULE 526. PURSUANT TO AN OFFER OF SETTLEMENT, IN WHICH J. ARON NEITHER ADMITTED NOR DENIED THE RULE VIOLATIONS UPON WHICH THE PENALTY IS BASED, J. ARON AGREED TO PAY A FINE IN THE AMOUNT OF $125,000 AND TO DISGORGE PROFITS IN THE AMOUNT OF $10,825. THE FINE WAS PAID IN FULL BY SUBMISSION OF A WIRE ON JUNE 2, 2022. GOLDMAN SACHS & CO. LLC (GSCO) 2019061061102 03/23/2022 Box Exchange LLC, United States ON THE BACK OF AN ESCALATION FROM A TRADING AND FINANCIAL COMPLIANCE EXAM, FINRA ENFORCEMENT FOUND, ON BEHALF OF BOX EXCHANGE LLC, AND OTHER EXCHANGES, THAT GOLDMAN SACHS & CO. LLC ("GSCO") FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF RULE 17A-3, AND THE RELEVANT EXCHANGE RULES. FINRA HAS ALLEGED THAT GSCO DID NOT SYSTEMATICALLY RECORD TIMESTAMPS ON OPTIONS ORDERS THAT WERE ROUTED MANUALLY TO FLOOR BROKERS, AS REQUIRED BY THE APPLICABLE RULES. WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000. GOLDMAN SACHS & CO. LLC (GSCO) 2018059146502 04/22/2022 NASDAQ STOCK MARKET LLC ("NASDAQ"), United States ON APRIL 4, 2023, THE NASDAQ STOCK MARKET LLC ("NASDAQ") ACCEPTED A LETTER OF ACCEPTANCE, WAIVER, AND CONSENT ("AWC") SUBMITTED BY GOLDMANS SACHS & CO. LLC ("GSCO"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED NASDAQ'S FINDINGS. FINRA AND 11 EXCHANGES FOUND, AMONG OTHER THINGS, THAT GSCO INCORRECTLY MARKED 59,981,252 SHORT SALE ORDERS AS LONG OVER A 3-YEAR PERIOD FROM OCTOBER 2015 TO APRIL 2018. THE MISMARKED ORDERS WERE CAUSED BY GSCO'S IMPLEMENTATION OF AN UPGRADE TO RELEVANT AUTOMATED TRADING SOFTWARE THAT WAS INTENDED TO SIMPLIFY CERTAIN ORDER FLOW. ACCORDING TO THE AWC, THESE MISMARKED ORDERS VIOLATED RULE 200(G) OF THE EXCHANGE ACT. THE FINDINGS DIFFER AMONG THE DIFFERENT EXCHANGES AND FINRA, BUT ALSO GENERALLY ALLEGE TRADE REPORTING AND RECORDKEEPING VIOLATIONS AS DESCRIBED IN THE AWC (NO. 2018059146502). THE FIRM CORRECTED THE CODING AND LOGIC ISSUES CAUSING THE MISMARKED ORDERS UPON NOTIFICATION OF THE SAME, HAS ENHANCED ITS ORDER MARKING SURVEILLANCE REPORT, AND ALSO ADDED AN ADDITIONAL CONTROL DESIGNED TO DETECT AND PREVENT THE ROUTING OF INACCURATELY MARKED SHORT SALE ORDERS. PURSUANT TO THE AWC, GSCO AGREED TO PAY A TOTAL MONETARY FINE IN THE AMOUNT OF $3,000,000. THE ALLOCATION AMOUNT PAYABLE TO NASDAQ IS $381,400, WHICH WILL BE AUTO-DEBITED. THE REMAINDER OF THE FINE WILL BE ALLOCATED TO CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., INVESTORS EXCHANGE LLC, NASDAQ PHLX LLC, NASDAQ BX, INC., NEW YORK STOCK EXCHANGE LLC, NYSE AMERICAN LLC, NYSE ARCA, INC. AND THE FINANCIAL INDUSTRY REGULATORY AUTHORITY FOR SIMILAR VIOLATIONS. GOLDMAN SACHS & CO. LLC (GSCO) RSRH-22-6554 04/13/2022 CME GROUP INC., United States ON APRIL 13, 2022, THE MARKET REGULATION DEPARTMENT OF THE CME GROUP INC. ("CME") DETERMINED THAT GOLDMAN SACHS & CO. LLC ("GSCO") VIOLATED CME RULE 561, FOR LATE ADJUSTMENTS TO LARGE TRADER REPORTING OF CERTAIN LISTED FUTURES AND OPTIONS POSITIONS ON SIX DIFFERENT TRADE DATES IN MARCH 2022. CME IMPOSED A FINE IN THE AMOUNT OF $5000 WHICH GSCO PAID BY SUBMISSION OF A WIRE ON APRIL 28, 2022. GOLDMAN SACHS & CO. LLC (GSCO) 2019061061108 03/23/2022 NYSE American LLC, United States ON THE BACK OF AN ESCALATION FROM A TRADING AND FINANCIAL COMPLIANCE EXAM, FINRA ENFORCEMENT FOUND, ON BEHALF OF NYSE AMERICAN LLC, AND OTHER EXCHANGES, THAT GOLDMAN SACHS & CO. LLC ("GSCO") FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF RULE 17A-3, AND THE RELEVANT EXCHANGE RULES. FINRA HAS ALLEGED THAT GSCO DID NOT SYSTEMATICALLY RECORD TIMESTAMPS ON OPTIONS ORDERS THAT WERE ROUTED MANUALLY TO FLOOR BROKERS, AS REQUIRED BY THE APPLICABLE RULES. WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000. GOLDMAN SACHS & CO. LLC (GSCO) 2019061061107 03/23/2022 NYSE ARCA , Inc., United States ON THE BACK OF AN ESCALATION FROM A TRADING AND FINANCIAL COMPLIANCE EXAM, FINRA ENFORCEMENT FOUND, ON BEHALF OF NYSE ARCA, INC., AND OTHER EXCHANGES, THAT GOLDMAN SACHS & CO. LLC ("GSCO") FAILED TO COMPLY WITH RECORDKEEPING REQUIREMENTS AND FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF RULE 17A-3 OF THE SECURITIES EXCHANGE ACT OF 1934, AND THE RELEVANT EXCHANGE RULES. FINRA HAS ALLEGED THAT, DURING THE PERIOD OF JANUARY 2017 - DECEMBER 2020, GSCO DID NOT SYSTEMATICALLY RECORD TIMESTAMPS ON OPTIONS ORDERS THAT WERE ROUTED MANUALLY TO FLOOR BROKERS, AS REQUIRED BY THE APPLICABLE RULES. WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000. GOLDMAN SACHS & CO. LLC (GSCO) 2019061061105 03/23/2022 NASDAQ PHLX LLC, United States ON THE BACK OF AN ESCALATION FROM A TRADING AND FINANCIAL COMPLIANCE EXAM, FINRA ENFORCEMENT FOUND, ON BEHALF OF NASDAQ PHLX, AND OTHER EXCHANGES, THAT GOLDMAN SACHS & CO. LLC ("GSCO") FAILED TO COMPLY WITH RECORDKEEPING REQUIREMENTS AND FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF RULE 17A-3 OF THE SECURITIES EXCHANGE ACT OF 1934, AND THE RELEVANT EXCHANGE RULES. FINRA HAS ALLEGED THAT, DURING THE PERIOD OF JANUARY 2017 - DECEMBER 2020, GSCO DID NOT SYSTEMATICALLY RECORD TIMESTAMPS ON OPTIONS ORDERS THAT WERE ROUTED MANUALLY TO FLOOR BROKERS, AS REQUIRED BY THE APPLICABLE RULES. WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000. GOLDMAN SACHS & CO. LLC (GSCO) 2019061061104 03/23/2022 NASDAQ ISE, LLC, United States ON THE BACK OF AN ESCALATION FROM A TRADING AND FINANCIAL COMPLIANCE EXAM, FINRA ENFORCEMENT FOUND, ON BEHALF OF NASDAQ ISE, LLC, AND OTHER EXCHANGES, THAT GOLDMAN SACHS & CO. LLC ("GSCO") FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF RULE 17A-3, AND THE RELEVANT EXCHANGE RULES. FINRA HAS ALLEGED THAT GSCO DID NOT SYSTEMATICALLY RECORD TIMESTAMPS ON OPTIONS ORDERS THAT WERE ROUTED MANUALLY TO FLOOR BROKERS, AS REQUIRED BY THE APPLICABLE RULES. WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000. GOLDMAN SACHS & CO. LLC (GSCO) 2019061061103 03/23/2022 NASDAQ GEMX, LLC, United States ON THE BACK OF AN ESCALATION FROM A TRADING AND FINANCIAL COMPLIANCE EXAM, FINRA ENFORCEMENT FOUND, ON BEHALF OF NASDAQ GEMX, LLC, AND OTHER EXCHANGES, THAT GOLDMAN SACHS & CO. LLC ("GSCO") FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF RULE 17A-3, AND THE RELEVANT EXCHANGE RULES. FINRA HAS ALLEGED THAT GSCO DID NOT SYSTEMATICALLY RECORD TIMESTAMPS ON OPTIONS ORDERS THAT WERE ROUTED MANUALLY TO FLOOR BROKERS, AS REQUIRED BY THE APPLICABLE RULES. WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000. GOLDMAN SACHS & CO. LLC (GSCO) 2019061061106 03/23/2022 NASDAQ MRX, LLC, United States ON THE BACK OF AN ESCALATION FROM A TRADING AND FINANCIAL COMPLIANCE EXAM, FINRA ENFORCEMENT FOUND, ON BEHALF OF NASDAQ MRX, LLC, AND OTHER EXCHANGES, THAT GOLDMAN SACHS & CO. LLC ("GSCO") FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF RULE 17A-3, AND THE RELEVANT EXCHANGE RULES. FINRA HAS ALLEGED THAT GSCO DID NOT SYSTEMATICALLY RECORD TIMESTAMPS ON OPTIONS ORDERS THAT WERE ROUTED MANUALLY TO FLOOR BROKERS, AS REQUIRED BY THE APPLICABLE RULES. WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000. GOLDMAN SACHS & CO. LLC (GSCO) 22-CH-2203 03/18/2022 CME GROUP INC., United States ON MARCH 17, 2022, THE CLEARING HOUSE RISK COMMITTEE OF THE CME GROUP INC. ("CME") REVIEWED GOLDMAN SACHS & CO. LLC'S ("GSCO") RISK BASED EXAMINATION REPORT AND THE FIRM'S RESPONSE, AND ISSUED A CHARGE LETTER DATED MARCH 18, 2022, WHICH ALLEGES THAT GSCO VIOLATED CBOT RULE 930.E.3 IN REGARDS TO MAINTAINING SUFFICIENT WRITTEN PERFORMANCE BOND RECORDS. PURSUANT TO AN OFFER OF SETTLEMENT, IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE RULE VIOLATION UPON WHICH THE PENALTY IS BASED, GSCO AGREED TO PAY A FINE IN THE AMOUNT OF $75,000. THE FINE WAS PAID IN FULL VIA GSCO'S CME CLEARING FIRM BANK ACCOUNT ON JULY 25, 2022. GOLDMAN SACHS & CO. LLC (GSCO) 2019061061101 03/23/2022 NASDAQ OPTIONS MARKET, United States ON THE BACK OF AN ESCALATION FROM A TRADING AND FINANCIAL COMPLIANCE EXAM, FINRA ENFORCEMENT FOUND, ON BEHALF OF NASDAQ OPTIONS MARKET, AND OTHER EXCHANGES, THAT GOLDMAN SACHS & CO. LLC ("GSCO") FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF RULE 17A-3, AND THE RELEVANT EXCHANGE RULES. FINRA HAS ALLEGED THAT GSCO DID NOT SYSTEMATICALLY RECORD TIMESTAMPS ON OPTIONS ORDERS THAT WERE ROUTED MANUALLY TO FLOOR BROKERS, AS REQUIRED BY THE APPLICABLE RULES. WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000. GOLDMAN SACHS & CO. LLC (GSCO) STAR NO. 20190610611-14 / FILE NOS. USE-2251-01 & URE-39-01 03/23/2022 FINRA , United States ON THE BACK OF AN ESCALATION FROM A TRADING AND FINANCIAL COMPLIANCE EXAM, FINRA ENFORCEMENT FOUND, ON BEHALF OF CBOE EXCHANGE, INC., AND OTHER EXCHANGES, THAT GOLDMAN SACHS & CO. LLC ("GSCO") FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF RULE 17A-3, AND THE RELEVANT EXCHANGE RULES. FINRA HAS ALLEGED THAT GSCO DID NOT SYSTEMATICALLY RECORD TIMESTAMPS ON OPTIONS ORDERS THAT WERE ROUTED MANUALLY TO FLOOR BROKERS, AS REQUIRED BY THE APPLICABLE RULES. WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000. GOLDMAN SACHS & CO. LLC (GSCO) STAR NO. 20190610611-15 / FILE NOS. USE-2251-03 & URE-39-03 03/23/2022 FINRA, United States ON THE BACK OF AN ESCALATION FROM A TRADING AND FINANCIAL COMPLIANCE EXAM, FINRA ENFORCEMENT FOUND, ON BEHALF OF CBOE BZX EXCHANGE, INC., AND OTHER EXCHANGES, THAT GOLDMAN SACHS & CO. LLC ("GSCO") FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF RULE 17A-3, AND THE RELEVANT EXCHANGE RULES. FINRA HAS ALLEGED THAT GSCO DID NOT SYSTEMATICALLY RECORD TIMESTAMPS ON OPTIONS ORDERS THAT WERE ROUTED MANUALLY TO FLOOR BROKERS, AS REQUIRED BY THE APPLICABLE RULES. WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000. GOLDMAN SACHS & CO. LLC (GSCO) STAR NO. 20190610611-12 / FILE NOS. USE-2251-04 & URE-39-04 03/23/2022 FINRA , United States ON THE BACK OF AN ESCALATION FROM A TRADING AND FINANCIAL COMPLIANCE EXAM, FINRA ENFORCEMENT FOUND, ON BEHALF OF CBOE EDGX EXCHANGE, INC., AND OTHER EXCHANGES, THAT GOLDMAN SACHS & CO. LLC ("GSCO") FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF RULE 17A-3, AND THE RELEVANT EXCHANGE RULES. FINRA HAS ALLEGED THAT GSCO DID NOT SYSTEMATICALLY RECORD TIMESTAMPS ON OPTIONS ORDERS THAT WERE ROUTED MANUALLY TO FLOOR BROKERS, AS REQUIRED BY THE APPLICABLE RULES. WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000. GOLDMAN SACHS & CO. LLC (GSCO) STAR NO. 20190610611-13 / FILE NOS. USE-2251-02 & URE-39-02 03/23/2022 FINRA, United States ON THE BACK OF AN ESCALATION FROM A TRADING AND FINANCIAL COMPLIANCE EXAM, FINRA ENFORCEMENT FOUND, ON BEHALF OF CBOE C2 EXCHANGE, INC., AND OTHER EXCHANGES, THAT GOLDMAN SACHS & CO. LLC ("GSCO") FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF RULE 17A-3, AND THE RELEVANT EXCHANGE RULES. FINRA HAS ALLEGED THAT GSCO DID NOT SYSTEMATICALLY RECORD TIMESTAMPS ON OPTIONS ORDERS THAT WERE ROUTED MANUALLY TO FLOOR BROKERS, AS REQUIRED BY THE APPLICABLE RULES. WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000. GOLDMAN SACHS & CO. LLC (GSCO) 22-BCC-003 03/31/2022 NFA, United States ON MARCH 31, 2022, IN CONJUNCTION WITH ACCEPTING GOLDMAN SACHS & CO. LLC'S OFFER TO SETTLE THE MATTER, THE NFA'S BUSINESS CONDUCT COMMITTEE ("BCC") ISSUED A COMPLAINT AGAINST THE FIRM ALLEGING VIOLATIONS OF NFA RULE 2-49(A), FOR FAILURE TO COMPLY WITH CERTAIN REQUIREMENTS UNDER CFTC REGULATION 23, AND NFA RULE 2-49(B), FOR FAILING TO PROMPTLY SUBMIT ACCURATE AND COMPLETE INFORMATION AS REQUIRED BY THE NFA. GOLDMAN SACHS & CO. LLC MADE AN OFFER TO SETTLE THE MATTER, WITHOUT ADMITTING OR DENYING LIABILITY, BY PAYING A FINE OF $2,500,000 TO NFA. ON MARCH 31, 2022, THE BCC ACCEPTED THE OFFER, AND ISSUED A DECISION (EFFECTIVE ON APRIL 15, 2022) ORDERING GOLDMAN SACHS & CO. LLC TO PAY A FINE IN THAT AMOUNT. AS PART OF A SIDE LETTER EXECUTED IN CONNECTION WITH THE OFFER, THE FIRM AND NFA ALSO AGREED TO ADDITIONAL TERMS AND CONDITIONS WITH REGARD TO A SEPARATE SET OF ISSUES SELF-DISCLOSED TO NFA. GOLDMAN SACHS & CO. LLC (GSCO) 2019061061111 03/23/2022 FINRA, United States ON THE BACK OF AN ESCALATION FROM A TRADING AND FINANCIAL COMPLIANCE EXAM, FINRA ENFORCEMENT FOUND, ON BEHALF OF MIAMI INTERNATIONAL SECURITIES EXCHANGE, LLC, AND OTHER EXCHANGES, THAT GOLDMAN SACHS & CO. LLC ("GSCO") FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF RULE 17A-3, AND THE RELEVANT EXCHANGE RULES. FINRA HAS ALLEGED THAT GSCO DID NOT SYSTEMATICALLY RECORD TIMESTAMPS ON OPTIONS ORDERS THAT WERE ROUTED MANUALLY TO FLOOR BROKERS, AS REQUIRED BY THE APPLICABLE RULES. WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000. GOLDMAN SACHS & CO. LLC (GSCO) 2019061061110 03/23/2022 FINRA, United States ON THE BACK OF AN ESCALATION FROM A TRADING AND FINANCIAL COMPLIANCE EXAM, FINRA ENFORCEMENT FOUND, ON BEHALF OF MIAX PEARL, LLC, AND OTHER EXCHANGES, THAT GOLDMAN SACHS & CO. LLC ("GSCO") FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF RULE 17A-3, AND THE RELEVANT EXCHANGE RULES. FINRA HAS ALLEGED THAT GSCO DID NOT SYSTEMATICALLY RECORD TIMESTAMPS ON OPTIONS ORDERS THAT WERE ROUTED MANUALLY TO FLOOR BROKERS, AS REQUIRED BY THE APPLICABLE RULES. WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000. GOLDMAN SACHS & CO. LLC (GSCO) 2019061061109 03/23/2022 FINRA, United States ON THE BACK OF AN ESCALATION FROM A TRADING AND FINANCIAL COMPLIANCE EXAM, FINRA ENFORCEMENT FOUND, ON BEHALF OF MIAX EMERALD, LLC, AND OTHER EXCHANGES, THAT GOLDMAN SACHS & CO. LLC ("GSCO") FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF RULE 17A-3, AND THE RELEVANT EXCHANGE RULES. FINRA HAS ALLEGED THAT GSCO DID NOT SYSTEMATICALLY RECORD TIMESTAMPS ON OPTIONS ORDERS THAT WERE ROUTED MANUALLY TO FLOOR BROKERS, AS REQUIRED BY THE APPLICABLE RULES. WITHOUT ADMITTING TO OR DENYING THE FINDINGS, GSCO HAS AGREED TO RESOLVE THE MATTER WITH THE EXCHANGES FOR AN AGGREGATE AMOUNT OF $225,000. GOLDMAN SACHS & CO. LLC (GSCO) RSRH-21-6403 11/11/2021 CME GROUP INC., United States ON NOVEMBER 11, 2021, THE MARKET REGULATION DEPARTMENT OF THE CME GROUP INC. ("CME") DETERMINED THAT GOLDMAN SACHS & CO. LLC ("GSCO") VIOLATED CME RULE 561 FOR LATE ADJUSTMENTS TO LARGE TRADER REPORTING OF CERTAIN LISTED FUTURES AND OPTIONS POSITIONS ON SIX TRADE DATES IN POSITIONS IN OCTOBER 2021. CME IMPOSED A SUMMARY FINE IN THE AMOUNT OF $2,500, WHICH GSCO PAID BY SUBMISSION OF A WIRE ON NOVEMBER 23, 2021. GOLDMAN SACHS & CO. LLC (GSCO) RSRH-21-6304 08/10/2021 CME GROUP INC., United States IN A NOTICE DATED AUGUST 10, 2021, THE MARKET REGULATION DEPARTMENT OF THE CME GROUP INC. ("CME") IDENTIFIED A REPORTING INFRACTION RELATED TO A REDUCTION OF OPEN INTEREST OF A FUTURES POSITION BY GOLDMAN SACHS & CO. LLC ("GSCO") IN VIOLATION OF RULE 854, CONCURRENT LONG AND SHORT POSITIONS. CME IMPOSED A FINE IN THE AMOUNT OF $2,500, WHICH GSCO PAID BY SUBMISSION OF A WIRE ON AUGUST 20, 2021. GOLDMAN SACHS & CO. LLC (GSCO) RSRH-21-6265 07/14/2021 CME GROUP INC., United States ON JULY 14, 2021, THE MARKET REGULATION DEPARTMENT OF THE CME GROUP INC. ("CME") DETERMINED THAT GOLDMAN SACHS & CO. LLC ("GSCO") VIOLATED CME RULE 561 FOR LATE ADJUSTMENTS TO LARGE TRADER REPORTING OF LISTED FUTURES POSITIONS IN JUNE 2021. CME IMPOSED A FINE IN THE AMOUNT OF $1,500, WHICH GSCO PAID BY SUBMISSION OF A WIRE ON JULY 28, 2021. GOLDMAN SACHS & CO. LLC (GSCO) 16622 05/26/2021 ICE FUTURES EUROPE, United States IN A NOTICE DATED MAY 26, 2021, ICE FUTURES EUROPE ("ICE") FOUND THAT GOLDMAN SACHS & CO. LLC ("GSCO") VIOLATED ICE RULE P.3 BECAUSE A GSCO CLIENT HELD A POSITION OVER THE POSITION LIMIT IN FEBRUARY 2021 WTI CRUDE FUTURES AT THE CLOSE OF BUSINESS ON JANUARY 14, 2021, WITHOUT AN EXEMPTION. ICE ISSUED A SUMMARY FINE OF EURO 17,500 TO GSCO, WHICH WAS PAID ON JUNE 3, 2021. GOLDMAN SACHS & CO. LLC (GSCO) 2016049001401 05/27/2021 FINRA, United States GOLDMAN SACHS & CO. LLC ("GSCO") SUBMITTED A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") THAT WAS ACCEPTED BY THE FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA") AND BECAME FINAL ON MAY 27, 2021. THE AWC RESOLVED ALLEGED VIOLATIONS OF FINRA RULES 7230A(G)(2), 7330(G)(2), AND 2010 DURING VARIOUS TIME PERIODS BETWEEN JANUARY 2015 AND JUNE 2019. THE AWC STATES THAT GSCO FAILED TO REPORT TIMELY OR OVER-REPORTED CERTAIN TRANSACTIONS TO THE FINRA/NASDAQ TRADE REPORTING FACILITY AND OTC REPORTING FACILITY. ON MAY 27, 2021, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS IN THE AWC, GSCO CONSENTED TO A CENSURE AND A FINE IN THE AMOUNT OF $50,000. GSCO PAID THE FINE BY WIRE SUBMISSION ON JULY 7, 2021. GOLDMAN SACHS & CO. LLC (GSCO) 21-0605 04/26/2021 CME GROUP INC., United States ON MAY 19, 2021, THE MARKET REGULATION DEPARTMENT OF THE CME GROUP INC. ("CME") DETERMINED THAT GOLDMAN SACHS & CO. LLC ("GSCO") TRADE DATA REVIEWED DURING ITS AUDIT OF TRADE DATES DECEMBER 2, 2020 THROUGH JANUARY 29, 2021 REFLECTED A COMPUTERIZED TRADE RECONSTRUCTION ERROR RATE IN EXCESS OF THE APPLICABLE 10% THRESHOLD LEVELS, SET FORTH IN CME RULE 536.F. CME IMPOSED A FINE IN THE AMOUNT OF $2,500, WHICH GSCO PAID BY SUBMISSION OF A WIRE ON MAY 20, 2021. GOLDMAN SACHS & CO. LLC (GSCO) 2018059113701 08/16/2018 FINRA, United States FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") ALLEGED THAT BETWEEN THE PERIOD OF JANUARY 2015 AND NOVEMBER 2019, GOLDMAN SACHS & CO. LLC ("GSCO") VIOLATED (I) SECTION 17(F)(2) OF THE SECURITIES AND EXCHANGE ACT OF 1934 (THE "EXCHANGE ACT") AND FINRA RULE 2010, FOR FAILING TO FINGERPRINT 1,061 ASSOCIATED, NON-REGISTERED INDIVIDUALS; (II) ARTICLE III, SECTION 3(B) OF THE FINRA BY-LAWS, FOR ALLOWING TWO INDIVIDUALS TO BE ASSOCIATED WITH THE FIRM WHO WERE SUBJECT TO STATUTORY DISQUALIFICATION; (III) 17(A)(3) OF THE EXCHANGE ACT AND FINRA RULES 4511 AND 2010, FOR FAILURE TO MAINTAIN ADEQUATE RECORDS OF FINGERPRINTING; AND (IV) FINRA RULES 3110 (A) AND (B) AND 2010, FOR FAILING TO MAINTAIN A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES DESIGNED TO ENSURE FINGERPRINT SCREENING OF CERTAIN POPULATIONS OF NON-REGISTERED ASSOCIATED INDIVIDUALS (NAMELY EMPLOYEES WHO TRANSFERRED TO THE FIRM FROM FOREIGN OFFICES AND EMPLOYEES WHO JOINED THE FIRM AS A RESULT OF AN ACQUISITION). WITHOUT ADMITTING OR DENYING THE VIOLATIONS, THE FIRM ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (THE "AWC") WITH FINRA ON JANUARY 22, 2021. PURSUANT TO THE AWC, THE FIRM CONSENTED TO (I) A CENSURE; (II) A FINE IN THE AMOUNT OF $1,250,000, WHICH WAS PAID IN FULL BY WIRE ON FEBRUARY 9, 2021; AND (III) AN UNDERTAKING TO REVIEW THE FIRM'S SYSTEMS AND PROCEDURES REGARDING THE IDENTIFICATION, FINGERPRINTING, AND SCREENING OF NON-REGISTERED ASSOCIATED PERSONS, ALONG WITH A WRITTEN STATEMENT WITHIN 60 DAYS OF THE AWC DESCRIBING THE METHODOLOGY USED TO CONDUCT THE REVIEW AND CERTIFYING THAT THE FIRM HAS ADOPTED AND IMPLEMENTED POLICIES AND PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE RELEVANT LAWS AND RULES, AS SET FORTH IN THE AWC. GOLDMAN SACHS INTERNATIONAL (GSI) Matter of GSI 11/11/2020 BLOOMBERG SEF LLC, United States ON NOVEMBER 11, 2020, BLOOMBERG SEF LLC ("BSEF") NOTIFIED GOLDMAN SACHS INTERNATIONAL ("GSI") THAT IT HAD COMPLETED ITS INQUIRY AND CONCLUDED THAT GSI VIOLATED BSEF RULE 531.A(D) BY SUBMITTING BLOCK TRADES TO BSEF MORE THAN 10 MINUTES AFTER THE TIME THE PARTICIPANTS AGREED TO THE TERMS OF THE BLOCK TRADES. AS THIS WAS GSI'S SECOND SUCH VIOLATION WITHIN A 12-MONTH PERIOD, BSEF IMPOSED A FINE OF $1,250. THE FINE IMPOSED BY BSEF WAS IN THE AMOUNT OF $1,250, WHICH WAS PAID IN FULL BY GSI BY WIRE ON DECEMBER 21, 2020. GOLDMANS SACHS & CO. LLC (GSCO) 20190800125 06/15/2020 NYSE ARCA, INC., United States ON JUNE 15, 2020, A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") FROM NYSE ARCA, INC. ("NYSE ARCA") DIRECTED AT GOLDMAN SACHS & CO. LLC ("GOLDMAN") WAS FINALIZED. WITHOUT ADMITTING OR DENYING THE FINDINGS, GOLDMAN CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS. THE AWC STATES THAT GOLDMAN VIOLATED NYSE ARCA RULE 6.49-O(B) BY EFFECTING EQUITY TRANSACTIONS AFTER GAINING KNOWLEDGE OF UNDISCLOSED TERMS AND CONDITIONS OF A CUSTOMER ORDER IN THE SAME OPTIONS SERIES. THE FINDINGS STATE THAT A GOLDMAN TRADER RELAYED FACILITATED CROSS ORDERS FOR 800 CALL OPTIONS OF A CERTAIN OPTIONS SERIES TO AN NYSE ARCA FLOOR BROKER THAT WERE SYSTEMATIZED IN SIX SEPARATE PIECES AT SIX DIFFERENT TIMES, FOUR 100 QUANTITIES AND THEN TWO 200 QUANTITIES. THE FINDINGS ADDITIONALLY STATE THAT THE GOLDMAN TRADER SOLD A TOTAL OF 49,000 EQUITY SHARES OF THE OPTIONS SERIES AS HEDGES, AND WHEN DOING SO, HOWEVER, GOLDMAN SOLD MORE SHARES THAN NEEDED TO HEDGE THE DISCLOSED (OR SYSTEMIZED) PORTIONS OF THE SECOND THROUGH SIXTH FACILITATED OPTIONS ORDERS, THEREFORE RESULTING IN OVERHEDGES. ON JUNE 15, 2020, AN AWC FROM NYSE ARCA DIRECTED AT GOLDMAN WAS FINALIZED. IN THE AWC, NYSE ARCA IMPOSES THE SANCTIONS CENSURE AND A FINE OF $30,000 FOR A VIOLATION OF NYSE ARCA RULE 6.49-O(B). THE FINE WAS PAID BY GOLDMAN BY WIRE ON JUNE 22, 2020. GOLDMANS SACHS & CO. LLC (GSCO) 2019-033 05/08/2020 THE ICE FUTURES U.S., United States ON MAY 8, 2020, THE ICE FUTURES U.S. ("IFUS" OR "EXCHANGE") MARKET REGULATION DEPARTMENT NOTIFIED GOLDMAN SACHS & CO. LLC ("GSCO") THAT IT WAS ISSUED A SUMMARY FINE IN THE AMOUNT OF $10,000 PURSUANT TO IFUS RULE 21.02. THE EXCHANGE ALLEGES THAT IN SEVEN INSTANCES, GSCO APPEARED TO HAVE BEEN IN VIOLATION OF IFUS RULE 6.15(A) WHEN IT FAILED TO ACCURATELY SUBMIT REPORTABLE POSITIONS TO THE EXCHANGE. THE FINE IMPOSED BY IFUS WAS IN THE AMOUNT OF $10,000, WHICH WAS PAID IN FULL BY GSCO BY WIRE ON MAY 28, 2020. GOLDMANS SACHS & CO. LLC (GSCO) CBOT 19-1192 03/31/2020 THE CME GROUP, United States ON MARCH 31, 2020, THE CME GROUP MARKET REGULATION DEPARTMENT NOTIFIED GOLDMAN SACHS & CO. LLC (""GSCO"") THAT IT HAD COMPLETED ITS INVESTIGATION INTO ALLEGATIONS THAT GSCO VIOLATED EXCHANGE RULE 562. GSCO HELD A PRO-RATA SHARE OF MELLON INVESTMENT CORPORATION'S POSITION EXCESS FOR THREE BUSINESS DAYS ON SEPTEMBER 11, 2019, SEPTEMBER 12, 2019, AND SEPTEMBER 13, 2019, BEFORE IT WAS LIQUIDATED ON SEPTEMBER 16, 2019. THE CME GROUP MARKET REGULATION DEPARTMENT ALLEGES THAT GSCO FAILED TO LIQUIDATE ITS PRO-RATA SHARE IN EXCESS OF LIMITS OR OTHERWISE FAILED TO ENSURE THAT ITS CUSTOMER WAS IN COMPLIANCE WITH LIMITS WITHIN A REASONABLE PERIOD OF TIME. THE ABOVE MATTER HAS NOW BEEN REFERRED TO THE CME GROUP MARKET REGULATION'S ENFORCEMENT DIVISION. ON JUNE 15, 2020, A PANEL OF THE CBOT BUSINESS CONDUCT COMMITTEE (""PANEL"") CONCLUDED THAT GSCO HAD VIOLATED CBOT RULE 562. IN ACCORDANCE WITH A SETTLEMENT OFFER THAT BECAME EFFECTIVE ON JUNE 17, 2020, THE PANEL ORDERED GSCO TO PAY A FINE IN THE AMOUNT OF $15,000. GSCO NEITHER ADMITTED NOR DENIED THE RULE VIOLATION UPON WHICH THE PENALTY IS BASED. THE FINE WAS PAID BY GSCO BY WIRE ON JUNE 26, 2020. IN ACCORDANCE WITH A SETTLEMENT OFFER THAT BECAME EFFECTIVE ON JUNE 17, 2020, THE PANEL ORDERED GSCO TO PAY A FINE IN THE AMOUNT OF $15,000. GSCO NEITHER ADMITTED NOR DENIED THE RULE VIOLATION UPON WHICH THE PENALTY IS BASED. THE FINE WAS PAID IN BY GSCO BY WIRE ON JUNE 26, 2020. GOLDMANS SACHS & CO. LLC (GSCO) CBOT 19-1109-BC 11/27/2019 THE CHICAGO BOARD OF TRADE, United States THE CHICAGO BOARD OF TRADE ("CBOT") IMPOSED A FINE ON GOLDMAN SACHS & CO. ("GOLDMAN") IN THE AMOUNT OF $15,000. CBOT CITED VIOLATIONS OF CBOT RULE 538.C. IN RELATION TO AN EXCHANGE FOR RELATED POSITION ("EFRP") PACKAGE EXECUTED IN THE TEN -YEAR TREASURY NOTE FUTURES AND OPTIONS MARKETS ON JULY 19, 2018, WHERE THE RELATED POSITION COMPONENTS OF THE EXCHANGE FOR RISK ("EFR") TRANSACTION DID NOT HAVE A REASONABLE DEGREE OF PRICE CORRELATION AND DID NOT HAVE OPPOSING MARKET BIAS TO THE EXCHANGE COMPONENT. FURTHER, THE RELATED COMPONENT OF THE EXCHANGE OF OPTION FOR OPTION ("EOO") TRANSACTION WAS NOT REASONABLY EQUIVALENT TO THE EXCHANGE COMPONENT. THE EFRP PACKAGE WAS THEREFORE NON-BONA FIDE AND IN VIOLATION OF CBOT RULE 538.C. WITHOUT ADMITTING OR DENYING THE RULE VIOLATION OR THE FACTUAL ALLEGATIONS UPON WHICH THE PENALTY IS BASED, GOLDMAN SUBMITTED AN OFFER OF SETTLEMENT, WHICH WAS ACCEPTED, AND IT BECAME EFFECTIVE ON NOVEMBER 27, 2019. THE FINE IMPOSED BY CBOT WAS IN THE AMOUNT OF $15,000, WHICH WAS PAID BY GOLDMAN BY WIRE ON DECEMBER 4, 2019. GOLDMANS SACHS & CO. LLC (GSCO) 2017053432301 12/19/2019 FINRA, United States ON DECEMBER 19, 2019, THE FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA") ACCEPTED A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") IN WHICH WITHOUT ADMITTING OR DENYING THE FINDINGS, GOLDMAN SACHS & CO. LLC ("GOLDMAN") CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS. THE FINDINGS ISSUED BY FINRA NAME A VIOLATION OF MUNICIPAL SECURITIES RULEMAKING BOARD ("MSRB") RULE G-15(F) AND STATE THAT GOLDMAN EFFECTED ON A DISCRETIONARY BASIS CUSTOMER SALE TRANSACTIONS OF MUNICIPAL BONDS IN AMOUNTS LOWER THAN THE MINIMUM DENOMINATIONS OF THE RESPECTIVE ISSUES. GOLDMAN GENERALLY RELIED ON DATA IT RECEIVED FROM THIRD-PARTY VENDORS TO DETERMINE WHETHER A TRANSACTION WAS BELOW AN ISSUE'S MINIMUM DENOMINATION, AND THE VIOLATIVE TRANSACTIONS ARE PRIMARILY ATTRIBUTABLE TO INACCURACIES IN THAT VENDOR DATA. GOLDMAN HAS ALREADY VOLUNTARILY RESCINDED THE VIOLATIVE TRANSACTIONS OR OTHERWISE REIMBURSED AFFECTED CUSTOMERS. ON DECEMBER 19, 2019 FINRA ACCEPTED AN AWC IN WHICH FINRA IMPOSES THE SANCTIONS CENSURE AND A FINE OF $130,000 FOR A VIOLATION OF MSRB RULE G-15(F). THE FINE WAS PAID BY GOLDMAN BY WIRE ON DECEMBER 26, 2019. GOLDMAN SACHS INTERNATIONAL (GSI) A 2019/31 11/07/2019 EUREX DEUTSCHLAND, Germany EUREX DEUTSCHLAND INITIATED A SANCTION PROCEEDING AGAINST GOLDMAN SACHS INTERNATIONAL ("GSI") AND A GSI SALES TRADER ON 7 NOVEMBER 2019 IN RELATION TO A CROSS TRADE IN THE EUREX PRODUCT EURO BUND FUTURE. EUREX DEUTSCHLAND ALLEGED THE CROSS TRADE WAS IN VIOLATION OF PARAGRAPH 2.6 OF THE CONDITIONS FOR TRADING AT EUREX DEUTSCHLAND. GSI RESPONDED TO EUREX DEUTSCHLAND ON 2 DECEMBER 2019 SETTING OUT THE FIRM'S POSITION THAT (A) THE TRADE IN QUESTION, WHICH HAD A LEGITIMATE ECONOMIC RATIONALE, WAS INTENDED TO HAPPEN OFF-EXCHANGE USING INTERNAL FLATTENING CONTROLS BUT INSTEAD WAS INADVERTENTLY ROUTED ONTO THE EXCHANGE, (B) THE NAMED SALES TRADER HAD NO INVOLVEMENT IN THE DECISION TO FLATTEN THE TWO POSITIONS INTERNALLY THAT RESULTED IN THE ON-EXCHANGE TRADE AND SO SHOULD BE REMOVED FROM THE SCOPE OF THE PROCEEDINGS, AND (C) THE TRADE DID NOT HAVE ANY MATERIAL IMPACT ON THE MARKET GIVEN THAT THE PRICE OF THE PRODUCT IN QUESTION MOVED BY ONLY EUR 0.01 IN THE MINUTE WHEN THE TRANSACTION TOOK PLACE (A MOVE OF JUST 0.00558%). ON APRIL 23, 2020, EUREX DEUTSCHLAND ISSUED A REPRIMAND AGAINST GSI AND REQUIRED GSI TO BEAR THE COST OF THE REGULATORY PROCEEDING FOR THE AMOUNT OF EUR 2,000 (APPROXIMATELY USD 1683.50). GSI PAID THE EUR 2,000 ON SEPTEMBER 10, 2020. GOLDMANS SACHS & CO. LLC (GSCO) 2019-032 09/10/2019 ICE FUTURES U.S., INC., United States THE MARKET REGULATION DEPARTMENT OF ICE FUTURES U.S., INC. (""ICE"") DETERMINED THAT GOLDMAN SACHS & CO. LLC (""THE FIRM"") VIOLATED ICE RULE 2.22 BY REPORTING INACCURATE OPEN INTEREST FOR THE SEPTEMBER 2019 FCOJ-A FUTURES CONTRACT FOR THE TRADE DATES OF AUGUST 29, 2019, AUGUST 30, 2019 AND SEPTEMBER 2, 2019. ICE IMPOSED A FINE ON THE FIRM IN THE AMOUNT OF $10,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON SEPTEMBER 18, 2019. ICE IMPOSED A FINE ON THE FIRM IN THE AMOUNT OF $10,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON SEPTEMBER 18, 2019. GOLDMAN SACHS EXECUTION AND CLEARING, L.P. (GSEC) 20140406430 03/04/2019 FINRA, United States FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. (""FINRA"") DEPARTMENT OF ENFORCEMENT ON BEHALF OF NYSE REGULATION ALLEGED THAT GOLDMAN SACHS EXECUTION AND CLEARING, L.P. (""GSEC""), A FORMER AFFILIATE OF GOLDMAN SACHS & CO. LLC (THE ""FIRM"") FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH SECTION 15(C)(3) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 15C3-5 THEREUNDER IN ALLEGED VIOLATION OF NYSE ARCA EQUITIES RULE 6.18. ON JUNE 12, 2017, GSEC AND THE FIRM CONSUMMATED A MERGER OF GSEC WITH AND INTO THE FIRM (THE ""MERGER""), WITH THE FIRM SURVIVING THE MERGER AND ASSUMING ANY REMAINING GSEC ASSETS, LIABILITIES AND OPERATIONS. ON JUNE 13, 2017, GSEC FILED A UNIFORM REQUEST WITHDRAWAL FROM BROKER-DEALER REGISTRATION (FORM BDW) WITH THE SECURITIES AND EXCHANGE COMMISSION, WHICH BECAME EFFECTIVE ON AUGUST 11, 2017. FINRA IMPOSED A FINE FOR MINOR RULE VIOLATIONS IN THE AMOUNT OF $3,500, WHICH WAS PAID BY THE SUBMISSION OF A WIRE ON MARCH 19, 2019. GOLDMANS SACHS & CO. LLC (GSCO) 18-9579 04/12/2018 THE CME GROUP INC., United States THE MARKET REGULATION DEPARTMENT OF THE CME GROUP INC. ("CME") DETERMINED THAT CERTAIN GOLDMAN SACHS & CO. LLC (THE "FIRM") TRADE DATA FOR THE TRADE DATES OF DECEMBER 11, 2017 THROUGH FEBRUARY 23, 2018 REFLECTED A COMPUTERIZED TRADE RECONSTRUCTION (CTR) ERROR RATE IN EXCESS OF APPLICABLE THRESHOLD LEVELS, IN DEEMED VIOLATION OF CHICAGO MERCANTILE EXCHANGE INC. RULE 536.F. THE CME IMPOSED A FINE ON THE FIRM IN THE AMOUNT OF $5,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON MAY 4, 2018. GOLDMANS SACHS & CO. LLC (GSCO) RSRH-18-5008 04/05/2018 THE CME GROUP INC., United States CME GROUP INC. ("CME") MARKET REGULATION ISSUED A SUMMARY FINE NOTICE TO GOLDMAN SACHS & CO. LLC (THE "FIRM") STATING THAT CME MARKET REGULATION IDENTIFIED TWO BLOCK TRADES THAT WERE REPORTED LATE OR MISREPORTED BY THE FIRM DURING JANUARY 2018, IN VIOLATION OF CME RULE 526.F. THE SUMMARY FINE, IN THE AMOUNT OF $1,000, WAS PAID BY SUBMISSION OF A WIRE ON APRIL 24, 2018. GOLDMANS SACHS & CO. LLC (GSCO) 17-9364 11/30/2017 THE CME GROUP INC., United States THE MARKET REGULATION DEPARTMENT OF THE CME GROUP INC. ("CME") DETERMINED, BASED ON A SELF-REPORT FROM GOLDMAN SACHS & CO. LLC (THE "FIRM"), THAT ORDER MODIFICATION OR CANCELLATION MESSAGES ON CERTAIN FIRM SYSTEMS IDENTIFIED THE TAG 50 ID OF THE TRADER WHO ORIGINATED AN ORDER, RATHER THAN THE TAG 50 ID OF THE TRADER WHO MODIFIED OR CANCELLED THE ORDER, IN DEEMED VIOLATION OF CME RULE 576. THE CME IMPOSED A SUMMARY FINE ON THE FIRM IN THE AMOUNT OF $9,000.00, WHICH WAS PAID BY SUBMISSION OF A WIRE ON DECEMBER 11, 2017. GOLDMAN SACHS EXECUTION & CLEARING, L.P. (GSEC) 17-0046/ 20150443193 06/21/2017 CHICAGO BOARD OPTIONS EXCHANGE, United States CHICAGO BOARD OPTIONS EXCHANGE, INCORPORATED ("CBOE") BUSINESS CONDUCT COMMITTEE (THE "COMMITTEE") ALLEGED THAT, FROM ON OR ABOUT NOVEMBER 5, 2011 THROUGH ON OR ABOUT JULY 14, 2016, GOLDMAN SACHS EXECUTION & CLEARING, L.P. ("GSEC"), A FORMER AFFILIATE OF GOLDMAN SACHS & CO. LLC (THE "FIRM"), FAILED TO QUALIFY AND REGISTER ONE ASSOCIATED PERSON (THE "ASSOCIATED PERSON") IN THE APPROPRIATE CATEGORY OF REGISTRATION WITH CBOE, AND FAILED TO REGISTER THE ASSOCIATED PERSON IN THE PREREQUISITE REGISTRATION CATEGORY WITH CBOE, IN ALLEGED VIOLATION OF CBOE RULE 3.6A. ON JUNE 12, 2017, GSEC AND THE FIRM CONSUMMATED A MERGER OF GSEC WITH AND INTO THE FIRM (THE "MERGER"), WITH THE FIRM SURVIVING THE MERGER AND ASSUMING ANY REMAINING GSEC ASSETS, LIABILITIES AND OPERATIONS. ON JUNE 13, 2017, GSEC FILED A UNIFORM REQUEST WITHDRAWAL FROM BROKER-DEALER REGISTRATION (FORM BDW) WITH THE SECURITIES AND EXCHANGE COMMISSION, WHICH BECAME EFFECTIVE ON AUGUST 11, 2017. WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS, ALLEGATIONS OR FINDINGS, THE FIRM SUBMITTED AN OFFER OF SETTLEMENT TO THE COMMITTEE ON AUGUST 8, 2017. ON SEPTEMBER 13, 2017, THE COMMITTEE ISSUED A DECISION ACCEPTING THE OFFER OF SETTLEMENT, AND ON SEPTEMBER 20, 2017, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $5,000. GOLDMANS SACHS & CO. LLC (GSCO) 2015045105501 11/01/2017 FINRA, United States FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF ENFORCEMENT ALLEGED THAT GOLDMAN SACHS & CO. LLC (THE "FIRM"): (A) DURING THE PERIOD FROM DECEMBER 11, 2014 THROUGH DECEMBER 16, 2014, FAILED TO REPORT TO THE OVER-THE-COUNTER ("OTC") REPORTING FACILITY ("OTCRF") THE CORRECT TIME OF EXECUTION FOR CERTAIN TRANSACTIONS IN REPORTABLE SECURITIES IN VIOLATION OF FINRA RULE 7330(D)(4); AND (B) DURING THE PERIODS FROM SEPTEMBER 1, 2014 TO DECEMBER 31, 2014, AND FROM JANUARY 1, 2015 TO APRIL 30, 2015, (I) FAILED TO TRANSMIT TO THE OTCRF CERTAIN LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES WITHIN 10 SECONDS AFTER EXECUTION, IN VIOLATION OF FINRA RULE 6622(A) AND FINRA RULE 2010, AND (II) DID NOT HAVE A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF NASD AND FINRA, CONCERNING OTC EQUITY TRADE REPORTING; SPECIFICALLY, THAT THE FIRM'S WRITTEN SUPERVISORY PROCEDURES WERE NOT SUFFICIENTLY INSTRUCTIVE AS TO HOW OFTEN THE RESPONSIBLE SUPERVISOR(S) SHOULD TAKE THE SPECIFIED STEPS DESIGNED TO ACHIEVE COMPLIANCE, AND THAT THE FIRM FAILED IN CERTAIN RESPECTS TO ENFORCE ITS SUPERVISORY PROCEDURES CONCERNING OTC EQUITY TRADE REPORTING, IN VIOLATION OF NASD RULE 3010 (FOR CONDUCT PRIOR TO DECEMBER 1, 2014), AND FINRA RULES 3110 (FOR CONDUCT ON AND AFTER DECEMBER 1, 2014) AND 2010. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON NOVEMBER 1, 2017, AND ON NOVEMBER 10, 2017, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $39,500. GOLDMAN SACHS EXECUTION & CLEARING, L.P. (GSEC) C2 17-0001/20150443193 06/21/2017 C2 OPTIONS EXCHANGE, United States C2 OPTIONS EXCHANGE, INCORPORATED ("C2") BUSINESS CONDUCT COMMITTEE (THE "COMMITTEE") ALLEGED THAT GOLDMAN SACHS EXECUTION & CLEARING, L.P. ("GSEC"), A FORMER AFFILIATE OF GOLDMAN SACHS & CO. LLC (THE "FIRM"), FAILED: (I) FROM ON OR ABOUT MAY 21, 2014 THROUGH ON OR ABOUT JULY 14, 2016, TO QUALIFY AND REGISTER ONE ASSOCIATED PERSON (THE "ASSOCIATED PERSON") IN THE APPROPRIATE CATEGORY OF REGISTRATION WITH C2, AND TO REGISTER THE ASSOCIATED PERSON IN THE PREREQUISITE REGISTRATION CATEGORY WITH C2; AND (II) FROM ON OR ABOUT MAY 21, 2014 THROUGH ON OR ABOUT MARCH 25, 2015, TO REGISTER THE MINIMUM NUMBER OF INDIVIDUALS REQUIRED TO BE REGISTERED AS A PROPRIETARY TRADER PRINCIPAL (TP) WITH C2, EACH IN ALLEGED VIOLATION OF C2 RULE 3.4. ON JUNE 12, 2017, GSEC AND THE FIRM CONSUMMATED A MERGER OF GSEC WITH AND INTO THE FIRM (THE "MERGER"), WITH THE FIRM SURVIVING THE MERGER AND ASSUMING ANY REMAINING GSEC ASSETS, LIABILITIES AND OPERATIONS. ON JUNE 13, 2017, GSEC FILED A UNIFORM REQUEST WITHDRAWAL FROM BROKER-DEALER REGISTRATION (FORM BDW) WITH THE SECURITIES AND EXCHANGE COMMISSION, WHICH BECAME EFFECTIVE ON AUGUST 11, 2017. WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS, ALLEGATIONS OR FINDINGS, THE FIRM SUBMITTED AN OFFER OF SETTLEMENT TO THE COMMITTEE ON AUGUST 8, 2017. ON SEPTEMBER 13, 2017, THE COMMITTEE ISSUED A DECISION ACCEPTING THE OFFER OF SETTLEMENT, AND ON SEPTEMBER 20, 2017, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $10,000. GOLDMANS SACHS & CO. LLC (GSCO) 2012031318003 07/14/2017 NASDAQ ISE, LLC, United States NASDAQ ISE, LLC ("ISE") ALLEGED THAT DURING THE PERIOD BETWEEN JANUARY 1, 2016 AND JULY 7, 2016, GOLDMAN SACHS & CO. LLC (THE "FIRM"): (I) FAILED TO REPORT AND INACCURATELY REPORTED CERTAIN OPTION POSITIONS TO THE LARGE OPTIONS POSITION REPORTING ("LOPR") SYSTEM, IN ALLEGED VIOLATION OF ISE RULE 415(A); AND (II) FAILED TO ESTABLISH AND MAINTAIN AN ADEQUATE SUPERVISORY SYSTEM, INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW, THAT WAS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE RULES GOVERNING THE REPORTING OF OPTIONS POSITIONS TO THE LOPR SYSTEM INCLUDING SUFFICIENT WRITTEN SUPERVISORY PROCEDURES TO ENSURE THE PROPER REPORTING OF SUBMISSIONS TO THE LOPR, IN ALLEGED VIOLATION OF ISE RULE 401. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE, A CENSURE, AND AN UNDERTAKING, AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") WHICH WAS ACCEPTED BY ISE ON JULY 14, 2017, AND ON JULY 31, 2017, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $300,000. THE AWC WAS CONDITIONED UPON ACCEPTANCE OF PARALLEL SETTLEMENT AGREEMENTS IN RELATED MATTERS BETWEEN THE FIRM AND THE FOLLOWING SELF-REGULATORY ORGANIZATIONS: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC.; BATS BZX EXCHANGE, INC.; AND NASDAQ PHLX LLC. GOLDMANS SACHS & CO. LLC (GSCO) 2012031318001 07/14/2017 FINRA, United States FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT GOLDMAN SACHS & CO. LLC (THE "FIRM"): (I) DURING THE PERIOD BETWEEN AT LEAST JANUARY 9, 2010 AND JULY 7, 2016, FAILED TO REPORT AND INACCURATELY REPORTED CERTAIN OVER-THE-COUNTER ("OTC") OPTION POSITIONS TO THE LARGE OPTIONS POSITION REPORTING ("LOPR") SYSTEM, IN ALLEGED VIOLATION OF FINRA RULE 2360(B)(5); (II) DURING THE PERIOD FROM JULY 31, 2012 THROUGH APRIL 29, 2016, EXCEEDED THE POSITON LIMITS IN THREE DIFFERENT OTC OPTIONS FOR CERTAIN CUSTOMERS AND/OR PROPRIETARY ACCOUNTS, IN ALLEGED VIOLATION OF FINRA RULE 2360(B)(3), AND (III) DURING THE PERIOD BETWEEN AT LEAST JANUARY 19, 2010 AND JULY 7, 2016, FAILED TO ESTABLISH AND MAINTAIN AN ADEQUATE SUPERVISORY SYSTEM, INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW, THAT WAS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE RULES GOVERNING THE REPORTING OF OPTIONS POSITIONS TO THE LOPR SYSTEM AND COMPLIANCE WITH APPLICABLE POSITION LIMITS, INCLUDING SUFFICIENT WRITTEN SUPERVISORY PROCEDURES TO ENSURE THE PROPER REPORTING OF SUBMISSIONS TO THE LOPR, IN ALLEGED VIOLATION OF NASD RULE 3010 (FOR CONDUCT PRIOR TO DECEMBER 1, 2014), AND FINRA RULES 3110 (FOR CONDUCT ON AND AFTER DECEMBER 1, 2014) AND 2010. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE, A CENSURE, AND AN UNDERTAKING, AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") WHICH WAS ACCEPTED BY FINRA ON JULY 14, 2017, AND ON JULY 27, 2017, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $1,425,000. THE AWC WAS CONDITIONED UPON ACCEPTANCE OF PARALLEL SETTLEMENT AGREEMENTS IN RELATED MATTERS BETWEEN THE FIRM AND THE FOLLOWING SELF-REGULATORY ORGANIZATIONS: BATS BZX EXCHANGE, INC.; NASDAQ ISE, LLC (F/K/A THE INTERNATIONAL SECURITIES EXCHANGE, LLC); AND NASDAQ PHLX LLC. GOLDMANS SACHS & CO. LLC (GSCO) 2012031318002 07/14/2017 BATS BZX EXCHANGE, INC., United States BATS BZX EXCHANGE, INC. ("BZX") ALLEGED THAT DURING THE PERIOD BETWEEN AT LEAST FEBRUARY 19, 2010 AND JULY 7, 2016, GOLDMAN SACHS & CO. LLC (THE "FIRM"): (I) FAILED TO REPORT AND INACCURATELY REPORTED CERTAIN OPTION POSITIONS TO THE LARGE OPTIONS POSITION REPORTING ("LOPR") SYSTEM, IN ALLEGED VIOLATION OF BZX RULE 18.10; AND (II) FAILED TO ESTABLISH AND MAINTAIN AN ADEQUATE SUPERVISORY SYSTEM, INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW, THAT WAS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE RULES GOVERNING THE REPORTING OF OPTIONS POSITIONS TO THE LOPR SYSTEM INCLUDING SUFFICIENT WRITTEN SUPERVISORY PROCEDURES TO ENSURE THE PROPER REPORTING OF SUBMISSIONS TO THE LOPR, IN ALLEGED VIOLATION OF BZX RULES 3.1, 5.1, 5.2 AND 5.3. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE, A CENSURE, AND AN UNDERTAKING, AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") WHICH WAS ACCEPTED BY BZX ON JUNE 26, 2017, AND BECAME FINAL ON JULY 14, 2017. ON JULY 31, 2017, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $525,000. THE AWC WAS CONDITIONED UPON ACCEPTANCE OF PARALLEL SETTLEMENT AGREEMENTS IN RELATED MATTERS BETWEEN THE FIRM AND THE FOLLOWING SELF-REGULATORY ORGANIZATIONS: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC.; NASDAQ ISE, LLC (F/K/A THE INTERNATIONAL SECURITIES EXCHANGE, LLC); AND NASDAQ PHLX LLC. GOLDMANS SACHS & CO. LLC (GSCO) 2014043565901 06/23/2017 NASDAQ PHLX LLC. United States THE NASDAQ PHLX LLC ("PHLX") BUSINESS CONDUCT COMMITTEE ALLEGED THAT DURING THE PERIOD BETWEEN JANUARY 19, 2010 AND JANUARY 16, 2016, GOLDMAN SACHS & CO. LLC (THE "FIRM"): (I) FAILED TO REPORT AND INACCURATELY REPORTED CERTAIN OPTION POSITIONS TO THE LARGE OPTIONS POSITION REPORTING ("LOPR") SYSTEM, IN ALLEGED VIOLATION OF PHLX RULES 1003 AND 707; AND (II) FAILED TO ESTABLISH AND MAINTAIN AN ADEQUATE SUPERVISORY SYSTEM, INCLUDING A SYSTEM OF FOLLOW-UP AND REVIEW, THAT WAS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE RULES GOVERNING THE REPORTING OF OPTIONS POSITIONS TO THE LOPR SYSTEM INCLUDING SUFFICIENT WRITTEN SUPERVISORY PROCEDURES TO ENSURE THE PROPER REPORTING OF SUBMISSIONS TO THE LOPR, IN ALLEGED VIOLATION OF PHLX RULES 748(G) (FOR THE PERIOD PRIOR TO NOVEMBER 23, 2012), 748(H) (FOR THE PERIOD ON AND AFTER NOVEMBER 23, 2012), AND 707. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE, CENSURE, AND AN UNDERTAKING, AND ENTERED INTO AN OFFER OF SETTLEMENT, STIPULATION OF FACTS AND CONSENT TO SANCTIONS WITH THE PHLX BUSINESS CONDUCT COMMITTEE (THE "OFFER OF SETTLEMENT"), WHICH WAS ACCEPTED BY THE PHLX BUSINESS CONDUCT COMMITTEE ON JUNE 26, 2017, AND BECAME FINAL ON JULY 14, 2017. ON JULY 31, 2017, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $250,000. THE OFFER OF SETTLEMENT WAS CONDITIONED UPON ACCEPTANCE OF PARALLEL SETTLEMENT AGREEMENTS IN RELATED MATTERS BETWEEN THE FIRM AND THE FOLLOWING SELF-REGULATORY ORGANIZATIONS: BATS BZX EXCHANGE, INC.; NASDAQ ISE, LLC; AND THE FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. GOLDMANS SACHS & CO. LLC (GSCO) 17-9164 04/03/2017 CME GROUP INC., United States THE MARKET REGULATION DEPARTMENT OF THE CME GROUP INC. ("CME") DETERMINED THAT CERTAIN GOLDMAN, SACHS & CO. (THE "FIRM") TRADE DATA FOR THE TRADE DATES OF JANUARY 3, 2017 THROUGH JANUARY 24, 2017 REFLECTED A COMPUTERIZED TRADE RECONSTRUCTION (CTR) ERROR RATE IN EXCESS OF APPLICABLE THRESHOLD LEVELS, IN DEEMED VIOLATION OF CHICAGO MERCANTILE EXCHANGE INC. RULE 536.F. THE CME IMPOSED A FINE ON THE FIRM IN THE AMOUNT OF $2,500, WHICH WAS PAID BY SUBMISSION OF A WIRE ON APRIL 5, 2017. GOLDMANS SACHS & CO. LLC (GSCO) 16-8954 12/07/2016 CME GROUP INC., United States CME GROUP INC. ("CME") MARKET REGULATION ISSUED A SUMMARY FINE NOTICE TO GOLDMAN, SACHS & CO. (THE "FIRM") STATING THAT CME MARKET REGULATION DISCOVERED THAT THE FIRM FAILED TO MAINTAIN A COMPLETE AUDIT TRAIL WITH RESPECT TO CERTAIN TRADING SYSTEMS FOR A MINIMUM OF FIVE YEARS IN VIOLATION OF CME RULE 536.B.2. THE SUMMARY FINE, IN THE AMOUNT OF $5,000, WAS PAID BY SUBMISSION OF A WIRE ON DECEMBER 22, 2016. GOLDMAN SACHS ASSET MANAGEMENT, L.P. (GSAM) NYMEX 16-0438-BC 10/07/2016 NEW YORK MERCANTILE EXCHANGE, United States A PANEL OF THE NEW YORK MERCANTILE EXCHANGE ("NYMEX") BUSINESS CONDUCT COMMITTEE (THE "PANEL") ACCEPTED AN OFFER OF SETTLEMENT MADE BY GOLDMAN SACHS ASSET MANAGEMENT, L.P. ("GSAM") WITH RESPECT TO ALLEGATIONS THAT AT THE CLOSE OF BUSINESS ON APRIL 25, 2016, GSAM HELD A COMMODITY FUTURES EQUIVALENT LONG POSITION THAT WAS OVER THE STANDARD EXPIRATION MONTH LIMIT, WHICH WENT INTO EFFECT AT THE CLOSE OF BUSINESS ON APRIL 22, 2106 AND REMAINED IN EFFECT FOR TRADE DATES APRIL 25, 26 AND 27, 2016, IN ALLEGED VIOLATION OF NYMEX RULE 562. WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS, ALLEGATIONS OR FINDINGS, GSAM SUBMITTED AN OFFER OF SETTLEMENT TO THE PANEL. ON OCTOBER 5, 2016, THE PANEL ACCEPTED THE OFFER OF SETTLEMENT AND ISSUED A NOTICE OF DISCIPLINARY ACTION ON OCTOBER 7, 2016. ON OCTOBER 18, 2016, GSAM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $40,000. GOLDMANS SACHS & CO. LLC (GSCO) 2014042644601 07/12/2016 NASDAQ PHLX LLC, United States THE BUSINESS CONDUCT COMMITTEE (THE "COMMITTEE") OF NASDAQ PHLX LLC ("PHLX") ALLEGED THAT DURING THE PERIOD BETWEEN AUGUST 13, 2014 AND AUGUST 15, 2014, GOLDMAN, SACHS & CO. (THE "FIRM"): (I) EFFECTED TRANSACTIONS IN AN OPTIONS POSITION THAT RESULTED IN ONE OF THE FIRM'S CUSTOMERS EXCEEDING THE APPLICABLE POSITION LIMIT FOR THREE CONSECUTIVE TRADING DAYS, IN ALLEGED VIOLATION OF PHLX RULE 1001; AND (II) FAILED TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES ("WSPS") AND A SYSTEM OF SUPERVISION THAT WAS REASONABLY DESIGNED TO DETECT AND PREVENT VIOLATIONS OF, AND ACHIEVE COMPLIANCE WITH, PHLX'S POSITION LIMIT RULE: SPECIFICALLY, THE TIMING AND REVIEW OF THE FIRM'S POSITION LIMIT REPORTS UNDER ITS WSPS WERE NOT REASONABLY DESIGNED TO TIMELY DETECT CERTAIN POSITION LIMIT OVERAGES FROM THE TRADE DATE, NOTIFY THE FIRM'S CUSTOMERS OF SUCH OVERAGES, OR TAKE CORRECTIVE MEASURES TO REDUCE AND PREVENT FURTHER OVERAGES, IN ALLEGED VIOLATION OF PHLX RULE 748(H). WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE, A CENSURE, AND AN UNDERTAKING TO REVISE ITS WSPS, AND ENTERED INTO AN OFFER OF SETTLEMENT, STIPULATION OF FACTS AND CONSENT TO SANCTIONS WITH THE COMMITTEE WHICH WAS ACCEPTED BY THE COMMITTEE ON JULY 15, 2016, AND ON AUGUST 1, 2016, THE FIRM SUBMITTED A WIRE TO PHLX IN PAYMENT OF THE FINE IN THE AMOUNT OF $25,000. GOLDMANS SACHS & CO. LLC (GSCO) 2013039539801 05/18/2016 FINRA, United States FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT: (I) DURING THE PERIOD OF JANUARY 30, 2009 THROUGH DECEMBER 31, 2011, GOLDMAN, SACHS & CO. (THE "FIRM"), ACTING AS A PROGRAM DEALER IN AUCTION RATE SECURITIES ("ARS"), SUBMITTED INACCURATE INFORMATION IN CERTAIN RESPECTS REGARDING THE RESULT OF AN AUCTION IN CERTAIN INSTANCES TO THE MSRB'S SHORT-TERM OBLIGATION RATE TRANSPARENCY ("SHORT") SYSTEM: SPECIFICALLY, THAT THE FIRM ERRONEOUSLY REPORTED RATE TYPES FOR THE ARS INDICATING THAT THE INTEREST RATES WERE SET BY AUCTION RATHER THAN THE MAXIMUM INTEREST RATES, IN ALLEGED VIOLATION OF MSRB RULE G-34; AND (II) THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE MSRB RULES, RELATING TO MSRB RULE G-34 CONCERNING SHORT REPORTING OF RATE TYPES, IN ALLEGED VIOLATION OF MSRB RULE G-27. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON MAY 18, 2016, AND ON MAY 31, 2016, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $50,000. GOLDMANS SACHS & CO. LLC (GSCO) 2015-106 03/17/2016 ICE FUTURES U.S., INC., United States ICE FUTURES U.S., INC. ("IFUS") MARKET REGULATION DEPARTMENT ISSUED A SUMMARY FINE, DATED MARCH 17, 2016, TO GOLDMAN, SACHS & CO. (THE "FIRM"), STATING THAT THE FIRM MAY HAVE VIOLATED IFUS RULE 6.10 BY FAILING TO ENSURE THAT THE PROPER CUSTOMER TYPE INDICATOR (CTI) CODE WAS AFFIXED TO CERTAIN ORDERS ENTERED BETWEEN MAY AND AUGUST 2015. THE SUMMARY FINE, IN THE AMOUNT OF $2,000, WAS PAID BY SUBMISSION OF A WIRE ON MARCH 31, 2016. GOLDMANS SACHS & CO. LLC (GSCO) 2014040037901 04/05/2016 FINRA, United States FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT FOR THE PERIOD SEPTEMBER 1, 2013 THROUGH DECEMBER 31, 2013, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO ACCEPT OR DECLINE IN THE FINRA/NASDAQ TRADE REPORTING FACILITY (FNTRF) CERTAIN TRANSACTIONS IN REPORTABLE SECURITIES WITHIN TWENTY MINUTES AFTER EXECUTION, IN ALLEGED VIOLATION OF FINRA RULE 7230A(B). WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON APRIL 5, 2016, AND ON APRIL 29, 2016, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $20,000. GOLDMANS SACHS & CO. LLC (GSCO) 2013035825001 04/04/2016 FINRA, United States FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT: (I) FOR TRADE DATES AUGUST 15 AND 16, 2013, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO SUBMIT, OR INACCURATELY SUBMITTED, CERTAIN INFORMATION TO THE ORDER AUDIT TRAIL SYSTEM (OATS), IN ALLEGED VIOLATION OF FINRA RULE 7450; (II) DURING THE PERIOD FROM MAY 17, 2011 THROUGH FEBRUARY 28, 2014, THE FIRM REPORTED CERTAIN SHORT SALE TRANSACTIONS TO THE FINRA TRADE REPORTING FACILITY ("FTRF") WITHOUT THE REQUIRED SHORT SALE MODIFIER, IN ALLEGED VIOLATION OF FINRA RULE 6182; AND (III) THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO FINRA RULE 6182 CONCERNING THE REPORTING OF CORRECT SHORT SALE MODIFIERS TO THE FTRF, IN ALLEGED VIOLATION OF FINRA RULE 2010 AND NASD RULE 3010. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON APRIL 4, 2016, AND ON APRIL 29, 2016, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $260,000. GOLDMANS SACHS & CO. LLC (GSCO) 2015-030 12/14/2015 ICE FUTURES U.S., INC., United States ICE FUTURES U.S., INC. ("IFUS") MARKET REGULATION DEPARTMENT ISSUED A SUMMARY FINE, DATED DECEMBER 14, 2015, TO GOLDMAN, SACHS & CO. (THE "FIRM"), STATING THAT THE FIRM MAY HAVE VIOLATED IFUS RULE 4.02(G)(2) IN ONE INSTANCE ON DECEMBER 12, 2014 BY FAILING TO UTILIZE IFUS'S CROSSING ORDER FUNCTIONALITY. THE SUMMARY FINE, IN THE AMOUNT OF $5,000, WAS PAID BY SUBMISSION OF A WIRE ON DECEMBER 24, 2015. GOLDMAN SACHS INTERNATIONAL (GSI) 2015-404B-038 10/06/2015 ICE CLEAR CREDIT, LLC, United States ICE CLEAR CREDIT, LLC ("ICC") ALLEGED THAT DURING THE MONTH OF SEPTEMBER 2015, GOLDMAN SACHS INTERNATIONAL ("GSI") FAILED TO SUBMIT SEVEN (7) INDEX END OF DAY PRICES IN ACCORDANCE WITH ICC RULES AND PROCEDURES, IN ALLEGED VIOLATION OF ICC RULE 404(B). ICC MADE A SUMMARY ASSESSMENT AGAINST GSI IN THE AMOUNT OF $7,000, WHICH AMOUNT IS DIRECT DEBITED IN THE NEXT ICC MONTHLY CLEARING FEE INVOICE. GOLDMANS SACHS & CO. LLC (GSCO) 2015-404B-039 10/06/2015 ICE CLEAR CREDIT, LLC, United States ICE CLEAR CREDIT, LLC ("ICC") ALLEGED THAT DURING THE MONTH OF SEPTEMBER 2015, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO SUBMIT ONE (1) INDEX END OF DAY PRICE IN ACCORDANCE WITH ICC RULES AND PROCEDURES, IN ALLEGED VIOLATION OF ICC RULE 404(B). ICC MADE A SUMMARY ASSESSMENT AGAINST THE FIRM IN THE AMOUNT OF $1,000, WHICH AMOUNT IS DIRECT DEBITED IN THE NEXT ICC MONTHLY CLEARING FEE INVOICE. J. ARON & COMPANY (J. ARON) 2014-111 08/11/2015 ICE FUTURES U.S., INC., United States AN ICE FUTURES U.S., INC. ("IFUS") SUBCOMMITTEE OF THE BUSINESS CONDUCT COMMITTEE (THE "BCC SUBCOMMITTEE") DETERMINED THAT J. ARON & COMPANY ("J. ARON") MAY HAVE VIOLATED IFUS RULE 6.20(B) IN ONE (1) INSTANCE BY CARRYING A POSITION IN EXCESS OF APPLICABLE SPOT MONTH POSITION LIMITS. WITHOUT ADMITTING OR DENYING ANY VIOLATION OF IFUS RULES, J. ARON ENTERED INTO A SETTLEMENT AGREEMENT, WHICH WAS APPROVED BY THE BCC SUBCOMMITTEE, IN WHICH J. ARON: (I) AGREED TO CEASE AND DESIST FROM FUTURE VIOLATIONS OF IFUS RULE 6.20(B); AND (II) CONSENTED TO A FINE IN THE AMOUNT OF $35,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON SEPTEMBER 2, 2015. GOLDMAN SACHS INTERNATIONAL (GSI) 2015-404B-021 07/08/2015 ICE CLEAR CREDIT LLC, United States ICE CLEAR CREDIT LLC ("ICC") ALLEGED THAT DURING THE MONTH OF JUNE 2015, GOLDMAN SACHS INTERNATIONAL ("GSI") FAILED TO SUBMIT CERTAIN SINGLE NAME END OF DAY PRICES AND CERTAIN INDEX PRICES IN ACCORDANCE WITH ICC RULES AND PROCEDURES, IN ALLEGED VIOLATION OF ICC RULE 404(B). ICC MADE A SUMMARY ASSESSMENT AGAINST GSI IN THE AMOUNT OF $127,000, WHICH AMOUNT WAS DIRECT DEBITED IN AN ICC MONTHLY CLEARING FEE INVOICE. GOLDMANS SACHS & CO. LLC (GSCO) 2015-404B-020 07/08/2015 ICE CLEAR CREDIT LLC, United States ICE CLEAR CREDIT LLC ("ICC") ALLEGED THAT DURING THE MONTH OF JUNE 2015, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO SUBMIT CERTAIN INDEX PRICES IN ACCORDANCE WITH ICC RULES AND PROCEDURES, IN ALLEGED VIOLATION OF ICC RULE 404(B). ICC MADE A SUMMARY ASSESSMENT AGAINST THE FIRM IN THE AMOUNT OF $19,000, WHICH AMOUNT WAS DIRECT DEBITED IN AN ICC MONTHLY CLEARING FEE INVOICE. GOLDMANS SACHS & CO. LLC (GSCO) C2 15-0001 / 20150442481 02/26/2015 C2 OPTIONS EXCHANGE, INCORPORATED, United States C2 OPTIONS EXCHANGE, INCORPORATED ("C2") BUSINESS CONDUCT COMMITTEE (THE "COMMITTEE") ALLEGED THAT, FROM ON OR ABOUT MARCH 27, 2013 THROUGH ON OR ABOUT JULY 11, 2014, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO APPROPRIATELY REGISTER ITS FINANCIAL AND OPERATIONS PRINCIPAL AS A FINANCIAL AND OPERATIONS PRINCIPAL (FN) WITH C2, IN ALLEGED VIOLATION OF C2 RULE 3.4. WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS, ALLEGATIONS OR FINDINGS, THE FIRM SUBMITTED AN OFFER OF SETTLEMENT TO THE COMMITTEE. ON JULY 16, 2015, THE COMMITTEE ISSUED A DECISION ACCEPTING THE OFFER OF SETTLEMENT, AND ON JULY 30, 2015, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $2,500. GOLDMANS SACHS & CO. LLC (GSCO) 15-0005 / 20150442706 02/26/2015 CHICAGO BOARD OPTIONS EXCHANGE, INCORPORATED, United States CHICAGO BOARD OPTIONS EXCHANGE, INCORPORATED ("CBOE") BUSINESS CONDUCT COMMITTEE (THE "COMMITTEE") ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO APPROPRIATELY REGISTER WITH THE CBOE: (I) ON VARIOUS DATES BETWEEN ON OR ABOUT NOVEMBER 5, 2011 THROUGH ON OR ABOUT OCTOBER 10, 2014, FIVE (5) ASSOCIATED PERSONS AS A PROPRIETARY TRADER (PT), AND (II) BY NOVEMBER 5, 2011, ITS CHIEF COMPLIANCE OFFICER AS A PROPRIETARY TRADER COMPLIANCE OFFICER (CT), EACH IN ALLEGED VIOLATION OF CBOE RULE 3.6A. WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS, ALLEGATIONS OR FINDINGS, THE FIRM SUBMITTED AN OFFER OF SETTLEMENT TO THE COMMITTEE. ON JULY 16, 2015, THE COMMITTEE ISSUED A DECISION ACCEPTING THE OFFER OF SETTLEMENT, AND ON JULY 30, 2015, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $15,000. GOLDMANS SACHS & CO. LLC (GSCO) 2015-042 05/26/2015 ICE FUTURES U.S., INC., United States ICE FUTURES U.S., INC. ("IFUS") COMPLIANCE DEPARTMENT ISSUED A NOTICE OF SUMMARY FINE, DATED MAY 26, 2015, TO GOLDMAN, SACHS & CO. (THE "FIRM"), STATING THAT THE FIRM MAY HAVE VIOLATED IFUS RULE 4.07 ON MARCH 9, 2015 BY FAILING TO REPORT A BLOCK TRADE IN A TIMELY MANNER. THE SUMMARY FINE, IN THE AMOUNT OF $1,000, WAS PAID BY SUBMISSION OF A WIRE ON JUNE 9, 2015. GOLDMANS SACHS & CO. LLC (GSCO) 2013037909601 06/03/2015 FINRA, United States FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT: (I) GOLDMAN, SACHS & CO. ("GSCO") FAILED TO TIMELY REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE ("TRACE"), CERTAIN TRANSACTIONS IN (A) TRACE-ELIGIBLE CORPORATE DEBT SECURITIES, DURING THE PERIOD OF APRIL 1, 2013 THROUGH JUNE 30, 2013 IN ALLEGED VIOLATION OF FINRA RULES 6730(A) AND 2010; AND (B) SECURITIZED PRODUCTS AND AGENCY DEBT SECURITIES, DURING THE PERIOD OF JANUARY 1, 2014 THROUGH MARCH 31, 2014, EACH IN ALLEGED VIOLATION OF FINRA RULE 6730(A), AND WITH REGARD TO THE TRACE-ELIGIBLE SECURITIZED PRODUCTS, IN ALLEGED VIOLATION OF FINRA RULE 2010; AND (II) GSCO'S WRITTEN SUPERVISORY PROCEDURES FAILED TO PROVIDE FOR THE MINIMUM REQUIREMENTS FOR TIMELY SUBMISSION OF ACCURATE REPORTS TO TRACE, IN ALLEGED VIOLATION OF FINRA RULE 2010 AND NASD RULE 3010. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE, FINE AND UNDERTAKING AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON JUNE 3, 2015, AND ON JULY 9, 2015, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $185,000. IN THE UNDERTAKING, THE FIRM CONSENTED TO PROVIDE THREE REPORTS, WRITTEN AND ORAL, TO FINRA ON DATES THAT ARE NO MORE THAN 3 MONTHS, 6 MONTHS, AND 12 MONTHS AFTER THE DATE OF THE NOTICE OF ACCEPTANCE OF THE AWC, REGARDING THE EFFECTIVENESS OF THE FIRM'S WRITTEN SUPERVISORY PROCEDURES WITH RESPECT TO TIMELY SUBMISSION OF ACCURATE REPORTS TO TRACE. GOLDMANS SACHS & CO. LLC (GSCO) 105141/107480 04/12/2015 CBOE FUTURES EXCHANGE, LLC, United States CBOE FUTURES EXCHANGE, LLC ("CFE") ALLEGED THAT GOLDMAN, SACHS & CO. FAILED TO DESIGNATE ONE CFE OFF EXCHANGE TRADE ON AN ACCOUNT STATEMENT AS A BLOCK TRADE, AND TO PROVIDE AN ORDER TICKET FOR ANOTHER BLOCK TRADE, EACH IN ALLEGED VIOLATION OF CFE RULE 415(E). THE CFE IMPOSED A FINE FOR MINOR RULE VIOLATIONS IN THE AMOUNT OF $2,500, WHICH WAS PAID BY THE SUBMISSION OF A WIRE ON APRIL 9, 2015. GOLDMANS SACHS & CO. LLC (GSCO) 2012031743301 12/23/2014 FINRA, United States FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT DURING THE PERIOD OF AUGUST 2003 THROUGH DECEMBER 2011, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO: (I) HAVE ADEQUATE PROCEDURES, INCLUDING WRITTEN SUPERVISORY PROCEDURES, REASONABLY DESIGNED TO IDENTIFY MATERIAL CHANGES IN ACCESS AND MANAGEMENT OF CERTAIN ACCOUNTS THAT WERE GRANTED AN EXEMPTION FROM AGGREGATING OPTIONS POSITIONS BY THE INTERMARKET SURVEILLANCE GROUP (ISG) IN ORDER TO ASSURE THAT PROPER NOTICE WAS GIVEN TO CERTAIN OPTIONS EXCHANGES (THE "EXCHANGES"); AND (II) PROVIDE NOTICE TO THE EXCHANGES OF ANY SUCH CHANGES, IN ALLEGED VIOLATION OF NASD RULES 3010 AND 2110 (FOR CONDUCT PRIOR TO DECEMBER 15, 2008) AND FINRA RULE 2010 (FOR CONDUCT ON AND AFTER DECEMBER 15, 2008). WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON DECEMBER 23, 2014, AND ON JANUARY 9, 2015, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $18,750. GOLDMANS SACHS & CO. LLC (GSCO) 14-0047 12/01/2014 CHICAGO BOARD OPTIONS EXCHANGE, INCORPORATED, United States THE CHICAGO BOARD OPTIONS EXCHANGE, INCORPORATED ("CBOE") ALLEGED THAT, DURING THE APPROXIMATE PERIOD FROM IN OR ABOUT JANUARY 2009 THROUGH IN OR ABOUT FEBRUARY 2011, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED: (I) ON CERTAIN OCCASIONS, TO GRANT PRIORITY TO THE HIGHEST BID AND/OR LOWEST OFFER WHEN SUCH BID OR OFFER WAS AVAILABLE, AND TO USE DUE DILIGENCE TO EXECUTE CERTAIN ORDERS AT THE BEST PRICES AVAILABLE, IN ALLEGED VIOLATION OF CBOE RULES 6.45A, 6.45B AND 6.73; AND (II) TO ASSURE COMPLIANCE WITH SUCH RULES, IN ALLEGED VIOLATION OF CBOE RULE 4.2. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF CONSENT WHICH WAS APPROVED BY THE CBOE BUSINESS CONDUCT COMMITTEE ON DECEMBER 1, 2014, AND ON DECEMBER 9, 2014, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $20,000. J. ARON & COMPANY (J. ARON) 2013-155 11/24/2014 ICE FUTURES U.S., INC., United States ICE FUTURES U.S., INC. ("IFUS") BUSINESS CONDUCT COMMITTEE ("BCC") DETERMINED THAT J. ARON & COMPANY ("J. ARON") MAY HAVE, IN ONE (1) INSTANCE, EXCEEDED THE SPOT MONTH SPECULATIVE POSITION LIMIT ESTABLISHED BY IFUS IN AN ENERGY FUTURES CONTRACT DURING CONTRACT EXPIRATION, IN ALLEGED VIOLATION OF IFUS RULE 6.20(B). WITHOUT ADMITTING OR DENYING ANY VIOLATION OF IFUS RULES, J. ARON ENTERED INTO A SETTLEMENT AGREEMENT, WHICH WAS APPROVED BY THE BCC, IN WHICH J. ARON: (I) AGREED TO CEASE AND DESIST FROM FUTURE VIOLATIONS OF IFUS RULE 6.20(B); AND (II) CONSENTED TO A MONETARY PAYMENT OF $82,064 IN THE AGGREGATE, CONSISTING OF A FINE IN THE AMOUNT OF $20,000, AND DISGORGEMENT OF PROFITS IN THE AMOUNT OF $62,064, BOTH OF WHICH WERE PAID BY SUBMISSION OF A WIRE ON NOVEMBER 26, 2014. GOLDMANS SACHS & CO. LLC (GSCO) 2013-016/028 11/19/2014 ICE FUTURES U.S., INC., United States ICE FUTURES U.S., INC. ("IFUS") COMPLIANCE DEPARTMENT ISSUED A NOTICE OF SUMMARY FINE, DATED NOVEMBER 19, 2014, TO GOLDMAN, SACHS & CO. (THE "FIRM"), STATING THAT: (I) ON FEBRUARY 11, 2013 AND MARCH 11, 2013, THE FIRM FAILED TO ENTER CERTAIN CROSSING ORDERS ("CO") FOR CERTAIN OPPOSING ORDERS SUBMITTED SIMULTANEOUSLY BY A COMMON ACCOUNT MANAGER ON BEHALF OF ACCOUNTS WITH SEPARATE BENEFICIAL OWNERS; AND (II) SPECIFICALLY, ON EACH DATE, THE FIRM ENTERED CERTAIN OPPOSING ORDERS WITHOUT THE USE OF IFUS CO FUNCTIONALITY, RESULTING IN CERTAIN FUTURES SPREADS TRANSACTING AGAINST ONE ANOTHER, IN VIOLATION OF IFUS RULE 4.02(I)(2). THE SUMMARY FINE, IN THE AMOUNT OF $15,000, WAS PAID BY SUBMISSION OF A WIRE ON NOVEMBER 28, 2014. GOLDMANS SACHS & CO. LLC (GSCO) 2011030683301 12/10/2014 FINRA, United States FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF ENFORCEMENT ALLEGED THAT IN CONNECTION WITH EFFORTS BY GOLDMAN, SACHS & CO. (THE "FIRM") AND OTHER BROKER-DEALERS TO PARTICIPATE IN A COMPANY'S PLANNED INITIAL PUBLIC OFFERING (IPO), THE FIRM: (A) ALLOWED A RESEARCH ANALYST TO PARTICIPATE IN THE SOLICITATION OF CERTAIN INVESTMENT BANKING BUSINESS; (B) OFFERED FAVORABLE RESEARCH COVERAGE TO INDUCE THE RECEIPT OF INVESTMENT BANKING BUSINESS; AND (C) FAILED TO ADOPT AND IMPLEMENT POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF NASD RULE 2711, IN ALLEGED VIOLATION OF NASD RULES 2711(C)(4), 2711(E), AND 2711(I), RESPECTIVELY, AND EACH IN ALLEGED VIOLATION OF FINRA RULE 2010. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON DECEMBER 10, 2014, AND ON DECEMBER 18, 2014, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $5,000,000. GOLDMAN SACHS INTERNATIONAL (GSI) 2014-404B-025 11/12/2014 ICE CLEAR CREDIT, LLC, United States ICE CLEAR CREDIT, LLC ("ICE") ALLEGED THAT DURING THE MONTH OF SEPTEMBER, 2014, GOLDMAN SACHS INTERNATIONAL ("GSI") FAILED TO SUBMIT FIFTY-FOUR (54) SINGLE NAME END OF DAY PRICES IN ACCORDANCE WITH ICE RULES AND PROCEDURES, IN ALLEGED VIOLATION OF ICE RULE 404(B). ICE MADE A SUMMARY ASSESSMENT AGAINST GSI IN THE AMOUNT OF $20,000, WHICH WAS FINALIZED BY NOTICE DATED NOVEMBER 12, 2014. THE ASSESSMENT AMOUNT WAS BILLED IN AN ICE MONTHLY CLEARING FEE INVOICE, AND WAS PAID ON DECEMBER 18, 2014. GOLDMANS SACHS & CO. LLC (GSCO) CBOT 13-7766-7767-BC 10/30/2014 CHICAGO BOARD OF TRADE, United States A PANEL OF THE CHICAGO BOARD OF TRADE ("CBOT") BUSINESS CONDUCT COMMITTEE (THE "PANEL") ACCEPTED A NEGOTIATED SETTLEMENT OFFER MADE BY GOLDMAN, SACHS & CO. (THE "FIRM") AND SUPPORTED BY THE MARKET REGULATION DEPARTMENT WHICH CONCERNED ALLEGATIONS THAT ON ONE OR MORE OCCASIONS FROM 2010 THROUGH 2013, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO PROPERLY REGISTER CERTAIN TAG50 USER IDS AND ALLOWED CERTAIN ORDERS TO BE ENTERED ON GLOBEX USING INCORRECT TAG50 USER IDS, IN ALLEGED VIOLATION OF CBOT RULE 576. WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS, ALLEGATIONS OR FINDINGS, THE FIRM SUBMITTED A SETTLEMENT OFFER TO THE PANEL. ON OCTOBER 28, 2014, THE PANEL ACCEPTED THE SETTLEMENT OFFER AND ISSUED A DECISION EFFECTIVE ON OCTOBER 30, 2014. ON NOVEMBER 7, 2014, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $1,000. GOLDMANS SACHS & CO. LLC (GSCO) CME 13-7766-7767-BC 10/30/2014 CHICAGO MERCANTILE EXCHANGE, United States A PANEL OF THE CHICAGO MERCANTILE EXCHANGE ("CME") BUSINESS CONDUCT COMMITTEE (THE "PANEL") ACCEPTED A NEGOTIATED SETTLEMENT OFFER MADE BY GOLDMAN, SACHS & CO. (THE "FIRM") AND SUPPORTED BY THE MARKET REGULATION DEPARTMENT WHICH CONCERNED ALLEGATIONS THAT ON ONE OR MORE OCCASIONS FROM 2010 THROUGH 2013, THE FIRM FAILED TO PROPERLY REGISTER CERTAIN TAG50 USER IDS AND ALLOWED CERTAIN ORDERS TO BE ENTERED ON GLOBEX USING INCORRECT TAG50 USER IDS, IN ALLEGED VIOLATION OF CME RULE 576. WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS, ALLEGATIONS OR FINDINGS, THE FIRM SUBMITTED A SETTLEMENT OFFER TO THE PANEL. ON OCTOBER 28, 2014, THE PANEL ACCEPTED THE SETTLEMENT OFFER AND ISSUED A DECISION EFFECTIVE ON OCTOBER 30, 2014. ON NOVEMBER 7, 2014, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $2,500. GOLDMANS SACHS & CO. LLC (GSCO) NYMEX 10-04626-BC 10/30/2014 THE NEW YORK MERCANTILE EXCHANGE, United States A PANEL OF THE NEW YORK MERCANTILE EXCHANGE ("NYMEX") BUSINESS CONDUCT COMMITTEE (THE "PANEL") ACCEPTED A NEGOTIATED SETTLEMENT OFFER MADE BY GOLDMAN, SACHS & CO. (THE "FIRM") AND SUPPORTED BY THE MARKET REGULATION DEPARTMENT WHICH CONCERNED ALLEGATIONS THAT THE FIRM, ON JANUARY 18, 2013, AND JANUARY 23, 2013: (I) EXECUTED CERTAIN BLOCK TRADES IN COMMODITIES FUTURES CONTRACTS THAT WERE NOT REPORTED TO NYMEX WITHIN THE APPLICABLE TIME LIMIT FOLLOWING EXECUTION; (II) REPORTED INACCURATE EXECUTION TIMES FOR THESE BLOCK TRADES; AND (III) EXECUTED THE TRADES AS SPREAD TRANSACTIONS BUT MISREPORTED THEM AS OUTRIGHT TRANSACTIONS, EACH IN ALLEGED VIOLATION OF NYMEX RULE 526.F. WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS, ALLEGATIONS OR FINDINGS, THE FIRM SUBMITTED A SETTLEMENT OFFER TO THE PANEL. ON OCTOBER 28, 2014, THE PANEL ACCEPTED THE SETTLEMENT OFFER AND ISSUED A DECISION EFFECTIVE ON OCTOBER 30, 2014. ON NOVEMBER 7, 2014, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $40,000. GOLDMANS SACHS & CO. LLC (GSCO) CME 10-04626-BC 10/30/2014 CHICAGO MERCANTILE EXCHANGE, United States A PANEL OF THE CHICAGO MERCANTILE EXCHANGE ("CME") BUSINESS CONDUCT COMMITTEE (THE "PANEL") ACCEPTED A NEGOTIATED SETTLEMENT OFFER MADE BY GOLDMAN, SACHS & CO. (THE "FIRM") AND SUPPORTED BY THE MARKET REGULATION DEPARTMENT WHICH CONCERNED ALLEGATIONS THAT THE FIRM: (I) ON THREE OCCASIONS BETWEEN NOVEMBER 28, 2011, AND JUNE 26, 2013, EXECUTED CERTAIN BLOCK TRADES FOR CUSTOMERS IN CME CONTRACTS THAT WERE NOT REPORTED TO CME WITHIN THE APPLICABLE TIME LIMIT FOLLOWING EXECUTION, IN VIOLATION OF CME RULE 526.F, AND ON TWO ADDITIONAL OCCASIONS, EXECUTED BLOCK ELIGIBLE SPREAD TRADES WHERE EACH LEG OF THE SPREAD WAS NOT EXECUTED AT THE SAME PRICE, IN ALLEGED VIOLATION OF CME RULE 526.D; (II) ON JUNE 26, 2013, CONSUMMATED A BLOCK TRADE TO SELL CURRENCY FUTURES TO A CUSTOMER AND, AFTER REALIZING THE TRADE WAS NOT REPORTED TO CME WITHIN THE REQUISITE TIME LIMIT, CANCELED THE BLOCK TRADE AND EXECUTED AN IDENTICAL TRADE WITH THE SAME CUSTOMER, IN ALLEGED VIOLATION OF CME RULE 526.F; AND (III) ON ONE OF THE ABOVE OCCASIONS, FAILED TO MAINTAIN ACCURATE RECORDS WITH RESPECT TO THE BLOCK TRADE EXECUTIONS IN THAT AN ORDER TICKET WAS MISSING, AND ON AT LEAST ONE OF THE ABOVE OCCASIONS, REPORTED TO CME AN INACCURATE EXECUTION TIME OF THE BLOCK TRADE, IN ALLEGED VIOLATION OF CME RULES 536.A AND 526.F. WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS, ALLEGATIONS OR FINDINGS, THE FIRM SUBMITTED A SETTLEMENT OFFER TO THE PANEL. ON OCTOBER 28, 2014, THE PANEL ACCEPTED THE SETTLEMENT OFFER AND ISSUED A DECISION EFFECTIVE ON OCTOBER 30, 2014. ON NOVEMBER 7, 2014, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $70,000. GOLDMANS SACHS & CO. LLC (GSCO) CBOT 10-04626-BC 10/30/2014 CHICAGO BOARD OF TRADE, United States A PANEL OF THE CHICAGO BOARD OF TRADE ("CBOT") BUSINESS CONDUCT COMMITTEE (THE "PANEL") ACCEPTED A NEGOTIATED SETTLEMENT OFFER MADE BY GOLDMAN, SACHS & CO. (THE "FIRM") AND SUPPORTED BY THE MARKET REGULATION DEPARTMENT WHICH CONCERNED ALLEGATIONS THAT THE FIRM: (I) ON SEVERAL OCCASIONS BETWEEN DECEMBER 30, 2009, AND NOVEMBER 27, 2012, EXECUTED MULTIPLE BLOCK TRADES FOR CUSTOMERS IN VARIOUS CBOT INTEREST RATE FUTURES CONTRACTS THAT WERE NOT REPORTED TO CBOT WITHIN THE APPLICABLE TIME LIMIT FOLLOWING EXECUTION, REPORTED TO CBOT INACCURATE EXECUTION TIMES OF CERTAIN BLOCK TRADES, FAILED TO MAINTAIN ACCURATE RECORDS WITH RESPECT TO CERTAIN BLOCK TRADE EXECUTIONS, AND DID NOT ACCURATELY REFLECT THE TIME OF EXECUTION ON CERTAIN ORDER TICKETS, IN ALLEGED VIOLATION OF CBOT RULES 526.F AND 536.A; AND (II) ON JANUARY 6, 2010, AND ON AUGUST 1, 2013, THE FIRM CONSUMMATED A BLOCK TRADE WITH A CUSTOMER AND, AFTER REALIZING THE TRADE WAS NOT REPORTED TO CBOT WITHIN THE REQUISITE TIME LIMIT, CANCELED THE BLOCK TRADE AND EXECUTED AN IDENTICAL TRADE WITH THE SAME CUSTOMER, IN ALLEGED VIOLATION OF CBOT RULE 526.F. WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS, ALLEGATIONS OR FINDINGS, THE FIRM SUBMITTED A SETTLEMENT OFFER TO THE PANEL. ON OCTOBER 28, 2014, THE PANEL ACCEPTED THE SETTLEMENT OFFER AND ISSUED A DECISION EFFECTIVE ON OCTOBER 30, 2014. ON NOVEMBER 7, 2014, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $90,000. GOLDMANS SACHS & CO. LLC (GSCO) 2012033550001 10/06/2014 FINRA, United States FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT, FOR THE PERIOD BETWEEN APRIL 1, 2012 AND JUNE 30, 2012, GOLDMAN, SACHS & CO. (THE "FIRM") IMPROPERLY SUBMITTED CERTAIN EXECUTION OR COMBINED ORDER/EXECUTION REPORTS THAT THE FIRM WAS NOT REQUIRED TO REPORT, IN ALLEGED VIOLATION OF FINRA RULE 7450. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON OCTOBER 6, 2014, AND ON OCTOBER 16, 2014, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $5,000. GOLDMANS SACHS & CO. LLC (GSCO) 2012032500201 08/01/2014 FINRA, United States FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT, DURING THE PERIOD OF OCTOBER 1, 2011 THROUGH MARCH 31, 2012, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO TIMELY REPORT CERTAIN NEW ISSUE OFFERINGS IN TRACE-ELIGIBLE CORPORATE DEBT SECURITIES, IN ALLEGED VIOLATION OF FINRA RULE 6760(C). WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON AUGUST 1, 2014, AND ON AUGUST 13, 2014, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $7,500. GOLDMANS SACHS & CO. LLC (GSCO) 20120333211-01 07/16/2014 FINRA, United States FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT, DURING THE PERIOD OF JANUARY 1, 2012 THROUGH APRIL 30, 2012, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO ACCEPT OR DECLINE IN THE FINRA/NASDAQ TRADE REPORTING FACILITY CERTAIN TRANSACTIONS IN REPORTABLE SECURITIES WITHIN TWENTY MINUTES AFTER EXECUTION, IN ALLEGED VIOLATION OF FINRA RULES 7230A(B) AND 2010. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON JULY 16, 2014, AND ON JULY 29, 2014, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $20,000. GOLDMAN SACHS INTERNATIONAL (GSI) 2014-404B-007 06/09/2014 ICE CLEAR CREDIT, LLC, United States ICE CLEAR CREDIT, LLC ("ICE") ALLEGED THAT DURING THE MONTH OF MAY, 2014, GOLDMAN SACHS INTERNATIONAL ("GSI") FAILED TO SUBMIT SEVENTY-TWO (72) SINGLE NAME AND EIGHT (8) INDEX END OF DAY PRICES IN ACCORDANCE WITH ICE RULES AND PROCEDURES, IN ALLEGED VIOLATION OF ICE RULE 404(B). ICE MADE A SUMMARY ASSESSMENT AGAINST GSI IN THE AMOUNT OF OF $18,000. THE ASSESSMENT AMOUNT WAS BILLED IN AN ICE MONTHLY CLEARING FEE INVOICE, AND WAS PAID ON JULY 17, 2014. GOLDMANS SACHS & CO. LLC (GSCO) 2014-404B-008 06/09/2014 ICE CLEAR CREDIT, LLC, United States ICE CLEAR CREDIT, LLC ("ICE") ALLEGED THAT DURING THE MONTH OF MAY, 2014, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO SUBMIT THREE (3) INDEX END OF DAY PRICES IN ACCORDANCE WITH ICE RULES AND PROCEDURES, IN ALLEGED VIOLATION OF ICE RULE 404(B). ICE MADE A SUMMARY ASSESSMENT AGAINST THE FIRM IN THE AMOUNT OF $3,000. THE ASSESSMENT AMOUNT WAS BILLED IN AN ICE MONTHLY CLEARING FEE INVOICE, AND WAS PAID ON JULY 17, 2014. GOLDMANS SACHS & CO. LLC (GSCO) CBT-RSRH-13-1735 05/20/2014 CME GROUP, INC., United States CME GROUP, INC. ("CME") MARKET REGULATION ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") SUBMITTED A POSITION ADJUSTMENT DECREASING OPEN INTEREST IN THE JUNE 2013 10-YR USD INTEREST RATE SWAP CONTRACT THAT RESULTED IN AN OFFSET OF CONTRACTS REPRESENTING MORE THAN ONE PERCENT OF THE REPORTED OPEN INTEREST, IN ALLEGED VIOLATION OF CBT RULE 854. THE FIRM CONSENTED TO THE IMPOSITION OF A FINE BY THE CME IN THE AMOUNT OF $5,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON MAY 27, 2014. GOLDMANS SACHS & CO. LLC (GSCO) 2013037230001 06/04/2014 FINRA, United States FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM"): (I) BETWEEN 2004 AND 2012, SUBMITTED TO FINRA, THE SECURITIES AND EXCHANGE COMMISSION ("SEC"), AND OTHER REGULATORS, BLUE SHEETS THAT INACCURATELY REPORTED CERTAIN SHORT-SALE TRANSACTIONS AS LONG-SALE TRANSACTIONS, AND BETWEEN NOVEMBER 2012 AND JANUARY 2013, FAILED TO INCLUDE CERTAIN TRANSACTIONS IN ITS BLUE SHEETS SUBMISSIONS TO FINRA, EACH IN ALLEGED VIOLATION OF SECTION 17(A) OF THE SECURITIES AND EXCHANGE ACT OF 1934, AS AMENDED (THE "EXCHANGE ACT"); RULES 17A-4(J) AND 17A-25 THEREUNDER; NASD RULES 8211, 8213, AND 2110 (FOR INACCURATE BLUE SHEETS SUBMITTED BEFORE DECEMBER 15, 2008); AND FINRA RULES 8211, 8213, AND 2010; AND (II) BETWEEN 2004 AND 2013, DID NOT HAVE IN PLACE AN ADEQUATE AUDIT SYSTEM PROVIDING FOR ACCOUNTABILITY OF ITS BLUE SHEET SUBMISSIONS, IN ALLEGED VIOLATION OF SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4(F)(3)(V) THEREUNDER; NASD RULE 2110 AND FINRA RULE 2010. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") WHICH WAS ACCEPTED BY FINRA ON JUNE 4, 2014, AND ON JUNE 18, 2014, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $1,000,000. THE FIRM FURTHER AGREED THAT IT HAS CONDUCTED A REVIEW OF ITS POLICIES, SYSTEMS AND PROCEDURES RELATING TO THE DEFICIENCIES ALLEGED IN THIS AWC. GOLDMANS SACHS & CO. LLC (GSCO) 13-1386 05/02/2014 CME GROUP, INC., United States CME GROUP, INC. ("CME") MARKET REGULATION ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO MAINTAIN A COMPLETE AUDIT TRAIL FOR A MINIMUM OF 5 YEARS, IN ALLEGED VIOLATION OF CME RULE 536.B.2. THE FIRM CONSENTED TO THE IMPOSITION OF A FINE BY THE CME IN THE AMOUNT OF $10,000, WHICH WAS PAID BY SUBMISSION OF A WIRE ON MAY 19, 2014. GOLDMANS SACHS & CO. LLC (GSCO) 20120353783-01 04/16/2014 FINRA, United States FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION, ON BEHALF OF THE NEW YORK STOCK EXCHANGE LLC ("NYSE"), ALLEGED THAT, DURING THE PERIOD BETWEEN APRIL 1, 2009 AND SEPTEMBER 15, 2011, GOLDMAN, SACHS & CO. (THE "FIRM"): (I) SUBMITTED CERTAIN TRADES WITH INACCURATE ACCOUNT TYPE INDICATORS (ATIS) TO THE NYSE FOR COMPARISON AND/OR SETTLEMENT, IN ALLEGED VIOLATION OF NYSE RULE 132(A); AND (II) FAILED TO IMPLEMENT ADEQUATE SYSTEMS AND CONTROLS, INCLUDING A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NYSE RULE 132, IN ALLEGED VIOLATION OF NYSE RULE 342. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON BEHALF OF THE NYSE ON APRIL 16, 2014, AND ON MAY 5, 2014, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $77,500. GOLDMANS SACHS & CO. LLC (GSCO) 20110288572-01 04/14/2014 FINRA, United States FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT, DURING THE PERIOD OF JULY 2010 THROUGH JUNE 2011: (I) CERTAIN SYSTEMS OF GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO ROUTE INTERMARKET SWEEP ORDERS (ISOS) TO BATS Y, EDGE A, AND EDGE X, IN ALLEGED VIOLATION OF SEC RULE 611(A)(2); AND THAT (II) THE FIRM FAILED TO IMPLEMENT REASONABLE PROCEDURES, INCLUDING APPROPRIATE TESTING, TO ENSURE THAT THE ORDER ROUTING LOGIC IN CERTAIN TRADING SYSTEMS WAS UPDATED TO ACCOUNT FOR ALL CURRENT MARKET VENUES TO WHICH THE FIRM ROUTED ORDERS TO PREVENT TRADE-THROUGHS OF PROTECTED QUOTATIONS IN NMS STOCKS, IN ALLEGED VIOLATION OF FINRA RULE 2010 AND NASD RULE 3010. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON APRIL 14, 2014, AND ON APRIL 28, 2014, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $15,000. GOLDMANS SACHS & CO. LLC (GSCO) 2013-141/148 01/10/2014 ICE FUTURES U.S., INC, United States IN A NOTICE OF SUMMARY FINE DATED JANUARY 10, 2014, ICE FUTURES U.S., INC. ("ICE") COMPLIANCE DEPARTMENT INFORMED GOLDMAN, SACHS & CO. (THE "FIRM") THAT ON OCTOBER 23, 2013, OCTOBER 29, 2013, AND NOVEMBER 20, 2013, CERTAIN BLOCK TRADES WERE REPORTED LATE IN ALLEGED VIOLATION OF ICE RULE 4.07(C). WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A FINE IN THE AMOUNT OF $1,500 WHICH WAS PAID BY SUBMISSION OF A WIRE ON FEBRUARY 3, 2014. GOLDMANS SACHS & CO. LLC (GSCO) 2013-404B-056 01/03/2014 ICE CLEAR CREDIT, LLC, United States ICE CLEAR CREDIT, LLC ("ICE") ALLEGED THAT DURING THE MONTH OF DECEMBER, 2013, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO SUBMIT TWO (2) INDEX END OF DAY PRICES IN ACCORDANCE WITH ICE RULES AND PROCEDURES, IN ALLEGED VIOLATION OF ICE RULE 404(B). ICE MADE A SUMMARY ASSESSMENT AGAINST THE FIRM IN THE AMOUNT OF $2,000, WHICH WAS BILLED IN AN ICE MONTHLY CLEARING FEE INVOICE DATED JANUARY 31, 2014, AND PAID ON FEBRUARY 20, 2014. GOLDMAN SACHS INTERNATIONAL (GSI) 2013-404B-57 01/03/2014 ICE CLEAR CREDIT, LLC, United States ICE CLEAR CREDIT, LLC ("ICE") ALLEGED THAT DURING THE MONTH OF DECEMBER, 2013, GOLDMAN SACHS INTERNATIONAL ("GSI") FAILED TO SUBMIT SEVENTY-TWO (72) SINGLE NAME END OF DAY PRICES IN ACCORDANCE WITH ICE RULES AND PROCEDURES, IN ALLEGED VIOLATION OF ICE RULE 404(B). ICE MADE A SUMMARY ASSESSMENT AGAINST GSI IN THE AMOUNT OF $10,000, WHICH WAS BILLED IN AN ICE MONTHLY CLEARING FEE INVOICE DATED JANUARY 31, 2014, AND PAID ON FEBRUARY 20, 2014. GOLDMANS SACHS & CO. LLC (GSCO) 2013-404B-015 11/06/2013 ICE CLEAR CREDIT, LLC, United States ICE CLEAR CREDIT, LLC ("ICE") ALLEGED THAT DURING THE MONTH OF JULY 2013, GOLDMAN, SACHS & CO. (THE "FIRM") FAILED TO SUBMIT ONE (1) INDEX END OF DAY PRICE IN ACCORDANCE WITH ICE RULES AND PROCEDURES, IN ALLEGED VIOLATION OF ICE RULE 404(B). ICE MADE A SUMMARY ASSESSMENT AGAINST THE FIRM OF $1,000, WHICH WAS MADE FINAL ON NOVEMBER 6, 2013. THE ASSESSMENT AMOUNT WAS BILLED IN AN ICE MONTHLY CLEARING FEE INVOICE, AND WAS PAID ON DECEMBER 19, 2013. J. ARON & COMPANY LLC (J. ARON) RSRH-13-1419-1480-1481 11/11/2013 CME GROUP, INC., United States CME GROUP, INC. ("CME") MARKET REGULATION FOUND REPORTING INFRACTIONS WITH RESPECT TO J. ARON & COMPANY'S (THE "COMPANY") REPORTING OF CERTAIN BLOCK TRADES, INCLUDING: (I) LATE REPORTING OF CERTAIN BLOCK TRADES TO THE CHICAGO MERCANTILE EXCHANGE DURING MARCH AND APRIL, 2013; (II) ENTERING TRADES INTO THE CME CLEARPORT PLATFORM ON ONE DATE AS OUTRIGHT TRANSACTIONS WHERE IT APPEARED FROM AUDIT TRAIL DOCUMENTS THEY WERE SPREAD TRANSACTIONS AND WITH EXECUTION TIMES NOT SUPPORTED BY SUCH SUPPORTING DOCUMENTS; AND (III) REPORTING A BLOCK TRANSACTION TO THE NEW YORK MERCANTILE EXCHANGE (NYMEX) FACILITATION DESK, WHILE AUDIT TRAIL DOCUMENTS SUGGESTED THAT THE ORDER WAS EXECUTED IN INCREMENTS, EACH IN ALLEGED VIOLATION OF CME RULE 526.F. THE CME IMPOSED A FINE IN THE AMOUNT OF $2,500, WHICH WAS PAID BY SUBMISSION OF A WIRE ON NOVEMBER 19, 2013. GOLDMAN SACHS INTERNATIONAL (GSI) 2013-404B-020 10/03/2013 ICE CLEAR CREDIT, LLC, United States ICE CLEAR CREDIT, LLC ("ICE") ALLEGED THAT DURING THE MONTH OF SEPTEMBER, 2013, GOLDMAN SACHS INTERNATIONAL ("GSI") FAILED TO SUBMIT EIGHTEEN (18) SINGLE NAME END OF DAY PRICES IN ACCORDANCE WITH ICE RULES AND PROCEDURES, IN ALLEGED VIOLATION OF ICE RULE 404(B). ICE MADE A SUMMARY ASSESSMENT AGAINST GSI OF $10,000, WHICH WAS MADE FINAL ON NOVEMBER 4, 2013. THE ASSESSMENT AMOUNT WAS BILLED IN AN ICE MONTHLY CLEARING FEE INVOICE, AND WAS PAID ON NOVEMBER 20, 2013. GOLDMANS SACHS & CO. LLC (GSCO) 20110284031-01 10/22/2013 FINRA, United States FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT (I) DURING THE PERIOD OF JANUARY 1, 2011 THROUGH MARCH 31, 2011, GOLDMAN, SACHS & CO. (THE "FIRM"): (I) FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE ("TRACE") THE CORRECT TIME OF TRADE EXECUTION FOR CERTAIN P1 TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES, IN ALLEGED VIOLATION OF FINRA RULE 6730(C)(8); (II) REPORTED TO TRACE CERTAIN P1 TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES THAT IT WAS NOT REQUIRED TO REPORT, IN ALLEGED VIOLATION OF FINRA RULE 6730; (III) FAILED TO SHOW THE CORRECT TIME OF EXECUTION ON THE MEMORANDUM OF CERTAIN BROKERAGE ORDERS, IN ALLEGED VIOLATION OF SEC RULE 17A-3 AND NASD RULE 3110; AND (IV) FAILED TO REPORT TO TRACE THE CORRECT CONTRA-PARTY'S IDENTIFIER FOR CERTAIN TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES, IN ALLEGED VIOLATION OF FINRA RULE 6730(C)(6). WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON OCTOBER 22, 2013, AND ON NOVEMBER 7, 2013, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $25,000. GOLDMAN SACHS INTERNATIONAL (GSI) 2013-404B-008 06/06/2013 ICE CLEAR CREDIT, LLC, United States ICE CLEAR CREDIT, LLC ("ICE") ALLEGED THAT DURING THE MONTH OF MAY, 2013, GOLDMAN SACHS INTERNATIONAL ("GSI") FAILED TO SUBMIT NINE (9) SINGLE NAME END OF DAY PRICES IN ACCORDANCE WITH ICE RULES AND PROCEDURES, IN ALLEGED VIOLATION OF ICE RULE 404(B). ICE MADE A SUMMARY ASSESSMENT AGAINST GSI OF $10,000, WHICH WAS MADE FINAL ON JULY 3, 2013. THE ASSESSMENT AMOUNT WAS BILLED IN AN ICE MONTHLY CLEARING FEE INVOICE, AND WAS PAID ON JULY 17, 2013. GOLDMANS SACHS & CO. LLC (GSCO) CBOT 09-03091-BC 05/31/2013 CHICAGO BOARD OF TRADE, United States A CHICAGO BOARD OF TRADE ("CBOT") BUSINESS CONDUCT COMMITTEE ("BCC") PANEL (THE "PANEL") ALLEGED THAT: (I) IN DECEMBER 2008, CME GROUP INC. MARKET REGULATION DEPARTMENT ("MARKET REGULATION") WAS IN REGULAR CONTACT WITH GOLDMAN, SACHS & CO. (THE "FIRM") REGARDING A LARGE POSITION HELD BY THE FIRM IN A TREASURY FUTURES CONTRACT WHICH WAS SET TO EXPIRE (THE "CONTRACT"), AND THAT THE FIRM DID NOT ADEQUATELY RELAY CERTAIN MARKET REGULATION CONCERNS TO CERTAIN FIRM TRADERS; AND (II) DURING THE FINAL MINUTE PRIOR TO EXPIRATION OF THE CONTRACT, A FIRM TRADER EXECUTED A MARKET ORDER, AND THEN SUBMITTED A LIMIT ORDER, WHICH WAS ONLY PARTIALLY FILLED AS A RESULT OF ILLIQUIDITY IN THE MARKET, AND THAT DURING THE COURSE OF THESE ORDERS AND SUBSEQUENT FILLS, THE MARKET TRADED UP RESULTING IN THE FINAL PRICE OF THE CONTRACT SETTLING ABOVE WHAT WAS INDICATED BY THE DECEMBER-MARCH CALENDAR SPREAD, IN ALLEGED VIOLATION OF CBOT RULE 432.W. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM SUBMITTED A SETTLEMENT OFFER TO THE PANEL. ON JUNE 29, 2013, THE PANEL ACCEPTED THE SETTLEMENT OFFER AND ISSUED A DECISION EFFECTIVE ON MAY 31, 2013. ON JUNE 12, 2013, THE FIRM SUBMITTED A WIRE IN PAYMENT OF THE FINE IN THE AMOUNT OF $875,000. GOLDMANS SACHS & CO. LLC (GSCO) 13-9246 05/15/2013 CME GROUP, INC., United States CME GROUP, INC. ("CME") MARKET REGULATION ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") NETTED DOWN 25 JANUARY 2013 COMEX COPPER FUTURES CONTRACTS ON JANUARY 9, 2013, IN ALLEGED VIOLATION OF CME RULE 854.B. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO THE IMPOSITION OF A FINE BY CME IN THE AMOUNT OF $1,000, WHICH WAS PAID BY SUBMISSION OF A CHECK ON MAY 9, 2013. GOLDMANS SACHS & CO. LLC (GSCO) 12-08956 03/20/2013 THE CHICAGO MERCANTILE EXCHANGE INC., United States THE CHICAGO MERCANTILE EXCHANGE INC. ("CME") MARKET REGULATION DEPARTMENT ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") TRADE DATA FOR THE TRADE DATES OF AUGUST 1, 2012 THROUGH OCTOBER 5, 2012 REFLECTED AN UNACCEPTABLE COMPUTERIZED TRADE RECONSTRUCTION (CTR) ERROR RATE, IN ALLEGED VIOLATION OF CME RULE 536.F. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO THE IMPOSITION OF A FINE BY CME IN THE AMOUNT OF $2,500, WHICH WAS PAID BY SUBMISSION OF A CHECK ON MARCH 19, 2013. GOLDMANS SACHS & CO. LLC (GSCO) 2010025148901 04/02/2013 FINRA, United States FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") FAILED: (I) FROM MAY 1 TO AUGUST 31, 2010, TO REPORT TO THE FINRA/NASDAQ TRADE REPORTING FACILITY BY 8:00 P.M. EASTERN TIME CERTAIN TRANSACTIONS THAT REQUIRED A .RO, .RA OR .RX MODIFIER, IN ALLEGED VIOLATION OF FINRA RULE 7230A(G); (II) FROM SEPTEMBER 1 TO DECEMBER 31, 2010, TO TRANSMIT TO THE OTC REPORTING FACILITY WITHIN 30 SECONDS AFTER EXECUTION CERTAIN LAST SALE REPORTS OF TRANSACTIONS IN OTC EQUITY SECURITIES, IN ALLEGED VIOLATION OF FINRA RULES 6622(A) AND 2010, AND TO REPORT TO THE OTC REPORTING FACILITY THE CORRECT TIME OF EXECUTION FOR CERTAIN TRANSACTIONS IN REPORTABLE SECURITIES, IN ALLEGED VIOLATION OF FINRA RULE 7330(D)(4); AND (III) FROM JANUARY 1 TO APRIL 30, 2011, TO ACCEPT OR DECLINE IN THE FINRA/NASDAQ TRADE REPORTING FACILITY CERTAIN TRANSACTIONS IN REPORTABLE SECURITIES WITHIN 20 MINUTES AFTER EXECUTION, IN ALLEGED VIOLATION OF FINRA RULES 7230A(B) AND 2010. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON APRIL 2, 2013, AND ON APRIL 18, 2013, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $47,500. GOLDMANS SACHS & CO. LLC (GSCO) 2011026827001 03/15/2013 FINRA, United States FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM") FAILED: (I) DURING THE PERIOD OF JULY 1 TO SEPTEMBER 30, 2010, TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE ("TRACE") THE CORRECT CONTRA-PARTY'S IDENTIFIER FOR CERTAIN S1 TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES, IN ALLEGED VIOLATION OF FINRA RULE 6730(C), AND (II) DURING THE PERIOD OF APRIL 1 TO JUNE 30, 2011, TO REPORT TO TRACE THE CORRECT TIME OF TRADE EXECUTION FOR CERTAIN P1 TRANSACTIONS IN TRACE-ELIGIBLE AGENCY DEBT SECURITIES, AND TO SHOW THE CORRECT TIME OF EXECUTION ON THE MEMORANDUM OF CERTAIN BROKERAGE ORDERS, IN ALLEGED VIOLATION OF FINRA RULE 6730(C)8 AND SEC RULE 17A-3, RESPECTIVELY. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON MARCH 15, 2013, AND ON APRIL 4, 2013, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $39,000. GOLDMANS SACHS & CO. LLC (GSCO) 2009017007401 03/12/2013 FINRA, United States FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION, ON BEHALF OF THE NASDAQ STOCK MARKET LLC ("NASDAQ"), ALLEGED THAT DURING THE PERIOD OF SEPTEMBER 16-17, 2009, GOLDMAN, SACHS & CO. (THE "FIRM") ENTERED 10 ORDERS INTO THE NASDAQ/SINGLEBOOK SYSTEM THAT FAILED TO CORRECTLY INDICATE WHETHER THE ORDERS WERE A BUY, SHORT SALE, OR LONG SALE, IN ALLEGED VIOLATION OF NASDAQ RULE 4755, AND THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO CERTAIN APPLICABLE SECURITIES LAWS AND REGULATIONS, AND/OR THE RULES OF NASDAQ, IN ALLEGED VIOLATION OF NASDAQ RULES 3010 AND 2110. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE, FINE AND UNDERTAKING AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC"), WHICH WAS ACCEPTED BY FINRA ON BEHALF OF NASDAQ ON MARCH 12, 2013, AND ON APRIL 11, 2013, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $17,500. IN THE UNDERTAKING, THE FIRM CONSENTED TO REVISE AND IMPLEMENT APPLICABLE WRITTEN SUPERVISORY PROCEDURES AND, WITHIN 90 BUSINESS DAYS OF THE ACCEPTANCE OF THE AWC, TO PROVIDE A REPRESENTATION TO FINRA THAT THE APPLICABLE WRITTEN SUPERVISORY PROCEDURES HAVE BEEN REVISED AND IMPLEMENTED. GOLDMANS SACHS & CO. LLC (GSCO) 2009017007402 03/15/2013 FINRA, United States FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM"): (I) DURING THE PERIOD OF SEPTEMBER 16-17, 2009, TRANSMITTED TO THE ORDER AUDIT TRAIL SYSTEM (OATS) 13 REPORTS THAT CONTAINED CERTAIN INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA, IN ALLEGED VIOLATION OF FINRA RULE 7450, AND (II) DURING THE PERIOD OF JULY 13-14, 2010, ERRONEOUSLY SUBMITTED A DUPLICATE NON-TAPE REPORT WITH THE .RX MODIFIER TO THE FINRA/NASDAQ TRADE REPORTING FACILITY, IN ALLEGED VIOLATION OF FINRA RULE 7230A. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON MARCH 15, 2013, AND ON APRIL 4, 2013, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $20,000. GOLDMANS SACHS & CO. LLC (GSCO) 13-9273 02/15/2013 THE CHICAGO BOARD OF TRADE, United States THE CHICAGO BOARD OF TRADE ("CBT") ALLEGED THAT DURING A REVIEW OF GOLDMAN, SACHS & CO. (THE "FIRM") POSITION REPORTING DURING DECEMBER 2012, THE FIRM FAILED TO ACCURATELY SUBMIT CERTAIN LONG POSITIONS ELIGIBLE FOR DELIVERY, IN ALLEGED VIOLATION OF CBT RULE 807. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM CONSENTED TO THE IMPOSITION OF A FINE BY CBT IN THE AMOUNT OF $2,500, WHICH WAS PAID BY SUBMISSION OF A CHECK ON FEBRUARY 13, 2013. GOLDMANS SACHS & CO. LLC (GSCO) 2018059146503 04/22/2022 NASDAQ BX, INC., United States ON APRIL 4, 2023, NASDAQ BX, INC. ("BX") ACCEPTED A LETTER OF ACCEPTANCE, WAIVER, AND CONSENT ("AWC") SUBMITTED BY GOLDMANS SACHS & CO. LLC ("GSCO"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED BX'S FINDINGS. FINRA AND 11 EXCHANGES FOUND, AMONG OTHER THINGS, THAT GSCO INCORRECTLY MARKED 59,981,252 SHORT SALE ORDERS AS LONG OVER A 3-YEAR PERIOD FROM OCTOBER 2015 TO APRIL 2018. THE MISMARKED ORDERS WERE CAUSED BY GSCO'S IMPLEMENTATION OF AN UPGRADE TO RELEVANT AUTOMATED TRADING SOFTWARE THAT WAS INTENDED TO SIMPLIFY CERTAIN ORDER FLOW. ACCORDING TO THE AWC, THESE MISMARKED ORDERS VIOLATED RULE 200(G) OF THE EXCHANGE ACT. THE FINDINGS DIFFER AMONG THE DIFFERENT EXCHANGES AND FINRA, BUT ALSO GENERALLY ALLEGE TRADE REPORTING AND RECORDKEEPING VIOLATIONS AS DESCRIBED IN THE AWC (NO. 2018059146503). THE FIRM CORRECTED THE CODING AND LOGIC ISSUES CAUSING THE MISMARKED ORDERS UPON NOTIFICATION OF THE SAME, HAS ENHANCED ITS ORDER MARKING SURVEILLANCE REPORT, AND ALSO ADDED AN ADDITIONAL CONTROL DESIGNED TO DETECT AND PREVENT THE ROUTING OF INACCURATELY MARKED SHORT SALE ORDERS. PURSUANT TO THE AWC, GSCO AGREED TO PAY A TOTAL MONETARY FINE IN THE AMOUNT OF $3,000,000. THE ALLOCATION AMOUNT PAYABLE TO BX IS $70,900, WHICH WILL BE AUTO-DEBITED. THE REMAINDER OF THE FINE WILL BE ALLOCATED TO CBOE BYX EXCHANGE, INC., CBOE BZX EXCHANGE, INC., CBOE EDGA EXCHANGE, INC., CBOE EDGX EXCHANGE, INC., INVESTORS EXCHANGE LLC, THE NASDAQ STOCK MARKET LLC, NASDAQ PHLX LLC, NEW YORK STOCK EXCHANGE LLC, NYSE AMERICAN LLC, NYSE ARCA, INC. AND THE FINANCIAL INDUSTRY REGULATORY AUTHORITY FOR SIMILAR VIOLATIONS. GOLDMANS SACHS & CO. LLC (GSCO) 2011026096702 10/24/2014 FINRA, United States FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF MARKET REGULATION ALLEGED THAT GOLDMAN, SACHS & CO. (THE "FIRM"): (A) BASED UPON CERTAIN ITEMS FROM THE 2011 TRADING AND MARKET MAKING SURVEILLANCE EXAMINATION OF THE FIRM WHICH EXAMINED TRADE DATES OCTOBER 5, 2011 AND OCTOBER 6, 2011, FAILED TO REPORT CERTAIN APPARENT CUSTOMER ORDER EVENTS TO THE ORDER AUDIT TRAIL SYSTEM (OATS); PROVIDE A RECORD OF CERTAIN ORDER ROUTE REPORTS SUBMITTED TO OATS; AND ACCURATELY APPEND THE SHORT SALE INDICATOR TO CERTAIN FINRA/NASDAQ TRADE REPORTING FACILITY (TRF) REPORTS, IN ALLEGED VIOLATION OF FINRA RULES 7450, 7440 AND 6182, RESPECTIVELY; AND DOCUMENT "STOPPED STOCK" INFORMATION ON CERTAIN CUSTOMER ORDER MEMORANDA, PROVIDE CERTAIN COMPLETE AND/OR ACCURATE CUSTOMER ORDER MEMORANDA, AND ACCURATELY MARK CERTAIN SELL TRANSACTIONS ON THE FIRM'S TRADING LEDGER, IN ALLEGED VIOLATION OF SECTION 17 OF THE SECURITIES EXCHANGE ACT OF 1934, AS AMENDED, AND RULE 17(A)-3 THEREUNDER, AS WELL AS NASD RULE 3110; AND (B) BASED UPON CERTAIN ITEMS FROM THE 2012 TRADING AND MARKET MAKING SURVEILLANCE EXAMINATION OF THE FIRM WHICH EXAMINED TRADE DATES OCTOBER 11, 2012 AND OCTOBER 12, 2012, INCORRECTLY REPORTED THE NUMBER OF SHARES EXECUTED AT THE MARKET CENTER AS AWAY EXECUTED SHARES IN CERTAIN INSTANCES IN THE FIRM'S RULE 605 OF REGULATION NMS REPORT, AND TRANSMITTED CERTAIN REPORTS THAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA TO OATS, IN ALLEGED VIOLATION OF RULE 605 OF REGULATION NMS AND FINRA RULE 7450, RESPECTIVELY. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE AND FINE AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON OCTOBER 24, 2014, AND ON NOVEMBER 13, 2014, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $55,000. GOLDMAN SACHS EXECUTION & CLEARING, L.P. (GSEC) 2014042582101 12/01/2017 FINRA, United States FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") DEPARTMENT OF ENFORCEMENT ALLEGED THAT GOLDMAN SACHS EXECUTION AND CLEARING, L.P. ("GSEC"), A FORMER AFFILIATE OF GOLDMAN SACHS & CO. LLC (THE "FIRM"), DUE TO CERTAIN FLAWS IN ITS PROSPECTUS-DELIVERY SYSTEM, FAILED TO DELIVER CERTAIN ETF PROSPECTUSES THAT IT INTENDED TO DELIVER IN THE PERIOD BETWEEN JUNE 2008 AND OCTOBER 2014. AS A CONSEQUENCE OF GSEC'S ALLEGED FAILURE TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES IN CONNECTION WITH ETF PROSPECTUS DELIVERY THAT WERE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH SECTION 5(B)(2) OF THE SECURITIES ACT OF 1933, THE FIRM ALLEGEDLY VIOLATED NASD RULES 3010 (A) AND (B) AND 2110 AND FINRA RULE 2010. IN ADDITION, AS A RESULT OF GSEC'S ALLEGED FAILURE TO ESTABLISH, MAINTAIN AND ENFORCE SUPERVISORY CONTROL POLICIES AND PROCEDURES THAT ADEQUATELY TESTED AND VERIFIED THAT ITS SUPERVISORY PROCEDURES CONCERNING ETF PROSPECTUS DELIVERY WERE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS, THE FIRM ALLEGEDLY VIOLATED NASD RULES 3012 AND 2110 AND FINRA RULE 2010. (FINRA RULE 2010 REPLACED NASD RULE 2110 EFFECTIVE DECEMBER 15, 2008.) ON JUNE 12, 2017, GSEC AND THE FIRM CONSUMMATED A MERGER OF GSEC WITH AND INTO THE FIRM (THE "MERGER"), WITH THE FIRM SURVIVING THE MERGER AND ASSUMING ANY REMAINING GSEC ASSETS, LIABILITIES AND OPERATIONS. ON JUNE 13, 2017, GSEC FILED A UNIFORM REQUEST WITHDRAWAL FROM BROKER-DEALER REGISTRATION (FORM BDW) WITH THE SECURITIES AND EXCHANGE COMMISSION, WHICH BECAME EFFECTIVE ON AUGUST 11, 2017. WITHOUT ADMITTING OR DENYING THE RULE VIOLATIONS, ALLEGATIONS OR FINDINGS, THE FIRM CONSENTED TO A CENSURE, A FINE AND AN UNDERTAKING, AND ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WHICH WAS ACCEPTED BY FINRA ON DECEMBER 1, 2017, AND ON DECEMBER 14, 2017, THE FIRM SUBMITTED A WIRE IN PAYMENT OF A FINE IN THE AMOUNT OF $700,000. GOLDMAN SACHS & CO. LLC 2023-404B-016 06/22/2023 ICE CLEAR CREDIT LLC, United States ICE CLEAR CREDIT LLC ("ICC") IMPOSED A PENALTY OF $153,000 ON GOLDMAN SACHS & CO. LLC ("GSCO") FOR FAILURE TO SUBMIT DAILY PRICING INFORMATION OF INDEX AND SINGLE NAME PRODUCTS. AFTER REVIEWING GSCO'S RESPONSE TO THE FINDING, INCLUDING CORRECTIVE MEASURES TO MINIMIZE RISK OF FUTURE REOCCURRENCES, ICC APPLIED WAIVERS AVAILABLE ONCE ANNUALLY TO THE PREVIOUSLY IMPOSED PENALTY. GOLDMAN SACHS INTERNATIONAL 2023-404B-017 06/22/2023 ICE CLEAR CREDIT LLC, United States ICE CLEAR CREDIT LLC ("ICC") IMPOSED A PENALTY OF $183,000 ON GOLDMAN SACHS INTERNATIONAL ("GSI") FOR FAILURE TO SUBMIT DAILY PRICING INFORMATION OF INDEX AND SINGLE NAME PRODUCTS. AFTER REVIEWING GSI'S RESPONSE TO THE FINDING, INCLUDING CORRECTIVE MEASURES TO MINIMIZE RISK OF FUTURE REOCCURRENCES, ICC APPLIED WAIVERS AVAILABLE ONCE ANNUALLY TO THE PREVIOUSLY IMPOSED PENALTY. GOLDMAN SACHS & CO. LLC RSRH-23-6886 07/21/2023 CME GROUP INC., United States ON JULY 5, 2023, THE MARKET REGULATION DEPARTMENT OF THE CME GROUP INC. ("CME") COMPLETED A REVIEW OF BLOCK TRADES REPORTED BY GOLDMAN SACHS & CO. LLC ("GSCO") DURING THE PERIOD JANUARY 2022 THROUGH APRIL 2023, AND FOUND THAT IN CERTAIN INSTANCES GSCO REPORTED TRADES WITH INACCURATE INFORMATION, IN VIOLATION OF CME RULE 526 AND MARKET REGULATION ADVISORY NOTICE RA2204-5, SECTION 7. CME IMPOSED A SUMMARY FINE IN THE AMOUNT OF $5,000, WHICH GSCO PAID BY SUBMISSION OF A WIRE ON JULY 24, 2023. GOLDMAN SACHS & CO. LLC NYMEX CASE-23-1655 08/17/2023 CME GROUP INC., United States ON JULY 27, 2023, THE MARKET REGULATION DEPARTMENT OF THE CME GROUP INC. ("CME") NOTIFIED GOLDMAN SACHS & CO. LLC ("GSCO" OR "THE FIRM") THAT CME HAD IDENTIFIED REPORTING INFRACTIONS WITH THE FIRM'S TRANSFER TRADE REPORTING IN VIOLATION OF CME RULE 853.A.6. CME IMPOSED A SUMMARY FINE IN THE AMOUNT OF $1,000, WHICH GSCO PAID BY SUBMISSION OF A WIRE ON AUGUST 17, 2023. GOLDMAN SACHS & CO. LLC 2020068197401 08/30/2023 FINRA, United States ON AUGUST 16, 2023, THE FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA") ACCEPTED A LETTER OF ACCEPTANCE, WAIVER, AND CONSENT ("AWC") SUBMITTED BY GOLDMAN SACHS & CO. LLC ("GSCO" OR "THE FIRM"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED FINRA'S FINDINGS. FINRA FOUND THAT BETWEEN JULY 2018 AND SEPTEMBER 2021, GSCO FAILED TO REPORT, OR INACCURATELY REPORTED, OVER-THE-COUNTER ("OTC") OPTIONS POSITIONS TO THE LARGE OPTIONS POSITIONS REPORTING ("LOPR") SYSTEM. THE FINDINGS STATED THE FIRM'S SYSTEMS FAILED TO RECOGNIZE THAT THE ACCOUNTS OF CERTAIN CUSTOMERS WERE UNDER COMMON CONTROL OR ACTED IN CONCERT. FINRA ADDITIONALLY FOUND THAT GSCO FAILED TO MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA RULE 2360(B)(5), WHICH IS A VIOLATION OF FINRA RULES 3110 AND 2010. PURSUANT TO THE AWC, GSCO WAS CENSURED AND AGREED TO PAY A MONETARY FINE IN THE AMOUNTOF $425,000, WHICH WAS PAID IN FULL VIA WIRE ON AUGUST 30, 2023. GOLDMAN SACHS & CO. LLC URE-95-03/STAR NO. 20200664843 08/30/2023 CBOE BZX EXCHANGE, INC., United States ON AUGUST 15, 2023, CBOE BZX EXCHANGE ("CBOE BZX" OR THE "EXCHANGE") ACCEPTED A LETTER OF CONSENT ("LOC") SUBMITTED BY GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED CBOE BZX'S FINDINGS. CBOE BZX FOUND THAT FROM OCTOBER 2018 THROUGH FEBRUARY 2021, GSCO FAILED TO REPORT OR INCORRECTLY REPORTED CERTAIN OPTIONS POSITIONS TO THE LARGE OPTIONS POSITION REPORT ("LOPR") AND THUS VIOLATED BZX RULE 18.10(A). THE EXCHANGE DETERMINED THAT BZX RULE 5.1 WAS VIOLATED AS A RESULT OF THE FIRM'S FAILURE TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES AND SUPERVISORY SYSTEMS REASONABLY DESIGNED TO PREVENT AND DETECT VIOLATIONS OF THE FIRM'S LOPR REPORTING OBLIGATIONS. PURSUANT TO THE LOC, GSCO WAS CENSURED AND AGREED TO PAY A MONETARY FINE IN THE AMOUNT OF $125,000, WHICH WAS PAID IN FULL VIA WIRE ON AUGUST 30, 2023. GOLDMAN SACHS & CO. LLC 2022-009 10/09/2023 ICE FUTURES U.S., United States ON SEPTEMBER 20, 2023, A SUBCOMMITTEE OF THE ICE FUTURES U.S. BUSINESS CONDUCT COMMITTEE ("IFUS") DETERMINED THAT GOLDMAN SACHS & CO. LLC ("GSCO") MAY HAVE VIOLATED EXCHANGE RULES 6.15(A) AND 4.01(B) BY INACCURATELY REPORTING LARGE TRADER POSITIONS IN MULTIPLE INSTANCES BETWEEN NOVEMBER 2021 AND NOVEMBER 2022, AND FAILING TO IMPLEMENT SUPERVISORY SYSTEMS, POLICIES, AND PROCEDURES DESIGNED TO ENSURE COMPLIANCE WITH EXCHANGE RULES. PURSUANT TO AN OFFER OF SETTLEMENT, IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE VIOLATIONS, GSCO AGREED TO PAY A MONETARY FINE OF $70,000. THE FINE WAS PAID BY SUBMISSION OF A WIRE ON OCTOBER 9, 2023. GOLDMAN SACHS INTERNATIONAL 2022-009 10/09/2023 ICE FUTURES U.S., United States ON SEPTEMBER 20, 2023, A SUBCOMMITTEE OF THE ICE FUTURES U.S. BUSINESS CONDUCT COMMITTEE ("IFUS") DETERMINED THAT GOLDMAN SACHS INTERNATIONAL ("GSI") MAY HAVE VIOLATED EXCHANGE RULES 6.15(A), 2.12 AND 4.01(B) BY INACCURATELY REPORTING LARGE TRADER POSITIONS BETWEEN NOVEMBER 2021 AND NOVEMBER 2022, OPEN INTEREST BETWEEN APRIL 2021 AND DECEMBER 2022 AND FAILING TO IMPLEMENT SUPERVISORY SYSTEMS, POLICIES, AND PROCEDURES DESIGNED TO ENSURE COMPLIANCE WITH EXCHANGE RULES. PURSUANT TO AN OFFER OF SETTLEMENT, IN WHICH GSI NEITHER ADMITTED NOR DENIED THE VIOLATIONS, GSI AGREED TO PAY A MONETARY FINE OF $105,000. THE FINE WAS PAID BY SUBMISSION OF A WIRE ON OCTOBER 9, 2023. GOLDMAN SACHS & CO. LLC 2019061945001 09/22/2023 FINANCIAL INDUSTRY REGULATORY AUTHORITY, United States ON SEPTEMBER 22, 2023, THE FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA") ACCEPTED A LETTER OF ACCEPTANCE, WAIVER, AND CONSENT ("AWC") SUBMITTED BY GOLDMAN SACHS & CO. LLC ("GSCO" OR "THE FIRM") IN WHICH GSCO NEITHER ADMITTED NOR DENIED FINRA'S FINDINGS BUT CONSENTED TO THE SANCTIONS AND TO THE FINDINGS THAT FROM NOVEMBER 2012 THROUGH MARCH 2022, IT SUBMITTED ALMOST 25,000 ELECTRONIC BLUE SHEETS ("EBS") TO FINRA THAT INACCURATELY REPORTED ONE OR MORE OF 39 SEPARATE TYPES OF TRANSACTION INFORMATION AND MISREPORTED AT LEAST 97 MILLION TRANSACTIONS. AS A RESULT, THE FIRM VIOLATED FINRA RULES 8211, 8213, AND 2010. IN ADDITION, FINRA FOUND THE FIRM'S FAILURE TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA AND THE SECURITIES AND EXCHANGE COMMISSION ("SEC") EBS REQUIREMENTS WAS IN VIOLATION OF FINRA RULES 3110, 2010 AND NASD RULE 3010. GSCO CURRENTLY HAS AN ONGOING REMEDIATION PROGRAM TO IMPROVE ITS EBS SYSTEM AND ADDRESS THE DISCOVERED DEFICIENCIES. PURSUANT TO THE AWC, GSCO WAS CENSURED, IS REQUIRED TO CERTIFY TO FINRA WITHIN 90 DAYS THAT IT HAS REMEDIATED THE ISSUES IDENTIFIED IN THE AWC AND IMPLEMENTED A SUPVERSORY SYSTEM RESONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE RELEVANT RULES, AND AGREED TO PAY A MONETARY FINE OF $6,000,000. THE FINE WAS PAID ON OCTOBER 3, 2023. GOLDMAN SACHS & CO. LLC 23-CH-2312 10/13/2023 CME GROUP INC., United States ON OCTOBER 12, 2023, THE CLEARING HOUSE RISK COMMITTEE OF THE CME GROUP INC. ("CME") DETERMINED THAT GOLDMAN SACHS & CO . LLC ("GSCO") VIOLATED CBOT RULE 930. E.3 FOR NOT MAINTAINING ACCURATE WRITTEN RECORDS FOR CERTAIN PERFORMANCE BOND CALLS IN 2022. PURSUANT TO AN OFFER OF SETTLEMENT, IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE RULE VIOLATION UPON WHICH THE PENALTY IS BASED, CME FINED THE FIRM $150,000 AND AGREED TO WAIVE THE FINE IF NO SIMILAR VIOLATION IS FOUND DURING THE NEXT RISK BASED EXAMINATION. GOLDMAN SACHS & CO. LLC 2019063499505 02/06/2024 FINANCIAL INDUSTRY REGULATORY AUTHORITY GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), SUBMITTED LETTERS OF CONSENT AND LETTERS OF ACCEPTANCE, WAIVER, AND CONSENT (COLLECTIVELY, "LETTERS"), WHICH WERE ACCEPTED TO ENTER SETTLEMENTS WITH FINRA AND 13 EXCHANGES. GSCO NEITHER ADMITTED NOR DENIED THE FINDINGS IN THE LETTERS, AND CONSENTED TO THE SANCTIONS AND ENTRY OF FINDINGS THAT ITS SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE TRADING ACTIVITY. SPECIFICALLY, FINRA AND THE 13 EXCHANGES FOUND THAT GSCO FAILED TO INCLUDE WARRANTS, RIGHTS, UNITS, AND CERTAIN OVER-THE-COUNTER ("OTC") EQUITY SECURITIES IN CERTAIN SURVEILLANCE REPORTS DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE PROPRIETARY AND CUSTOMER TRADING. THESE SECURITIES WERE EXCLUDED FOR EXTENDED PERIODS RANGING FROM APPROXIMATELY TWO YEARS TO MORE THAN 12 YEARS, BETWEEN 2009 AND 2023. THE FIRM'S SUPERVISORY SYSTEM DID NOT REQUIRE A REVIEW OF ITS AUTOMATED SURVEILLANCE REPORTS, AND AS A RESULT, GSCO FAILED TO DETECT THESE DEFICIENCIES. GSCO COMPLETED REMEDIATION FOR ALL SURVEILLANCE REPORTS, AND ALSO IMPLEMENTED REVIEWS TO IDENTIFY IF ANY SECURITY WAS INADVERTENTLY EXCLUDED FROM NEW OR MODIFIED SURVEILLANCE REPORTS. THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC. THE FINES WERE ALL PAID IN FULL AS OF MARCH 21, 2024. GOLDMAN SACHS & CO. LLC STAR NO. 20190634995-01/ FILE NO. URE-98-05 01/25/2024 CBOE BZX EXCHANGE, INC. GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), SUBMITTED LETTERS OF CONSENT AND LETTERS OF ACCEPTANCE, WAIVER, AND CONSENT (COLLECTIVELY, "LETTERS"), WHICH WERE ACCEPTED TO ENTER SETTLEMENTS WITH FINRA AND 13 EXCHANGES. GSCO NEITHER ADMITTED NOR DENIED THE FINDINGS IN THE LETTERS, AND CONSENTED TO THE SANCTIONS AND ENTRY OF FINDINGS THAT ITS SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE TRADING ACTIVITY. SPECIFICALLY, FINRA AND THE 13 EXCHANGES FOUND THAT GSCO FAILED TO INCLUDE WARRANTS, RIGHTS, UNITS, AND CERTAIN OVER-THE-COUNTER ("OTC") EQUITY SECURITIES IN CERTAIN SURVEILLANCE REPORTS DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE PROPRIETARY AND CUSTOMER TRADING. THESE SECURITIES WERE EXCLUDED FOR EXTENDED PERIODS RANGING FROM APPROXIMATELY TWO YEARS TO MORE THAN 12 YEARS, BETWEEN 2009 AND 2023. THE FIRM'S SUPERVISORY SYSTEM DID NOT REQUIRE A REVIEW OF ITS AUTOMATED SURVEILLANCE REPORTS, AND AS A RESULT, GSCO FAILED TO DETECT THESE DEFICIENCIES. GSCO COMPLETED REMEDIATION FOR ALL SURVEILLANCE REPORTS, AND ALSO IMPLEMENTED REVIEWS TO IDENTIFY IF ANY SECURITY WAS INADVERTENTLY EXCLUDED FROM NEW OR MODIFIED SURVEILLANCE REPORTS. THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC. THE FINES WERE ALL PAID IN FULL AS OF MARCH 21, 2024. GOLDMAN SACHS & CO. LLC STAR NO. 201906349955-02/FILE NO. URE-98-06 01/25/2024 CBOE BYX EXCHANGE, INC. GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), SUBMITTED LETTERS OF CONSENT AND LETTERS OF ACCEPTANCE, WAIVER, AND CONSENT (COLLECTIVELY, "LETTERS"), WHICH WERE ACCEPTED TO ENTER SETTLEMENTS WITH FINRA AND 13 EXCHANGES. GSCO NEITHER ADMITTED NOR DENIED THE FINDINGS IN THE LETTERS, AND CONSENTED TO THE SANCTIONS AND ENTRY OF FINDINGS THAT ITS SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE TRADING ACTIVITY. SPECIFICALLY, FINRA AND THE 13 EXCHANGES FOUND THAT GSCO FAILED TO INCLUDE WARRANTS, RIGHTS, UNITS, AND CERTAIN OVER-THE-COUNTER ("OTC") EQUITY SECURITIES IN CERTAIN SURVEILLANCE REPORTS DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE PROPRIETARY AND CUSTOMER TRADING. THESE SECURITIES WERE EXCLUDED FOR EXTENDED PERIODS RANGING FROM APPROXIMATELY TWO YEARS TO MORE THAN 12 YEARS, BETWEEN 2009 AND 2023. THE FIRM'S SUPERVISORY SYSTEM DID NOT REQUIRE A REVIEW OF ITS AUTOMATED SURVEILLANCE REPORTS, AND AS A RESULT, GSCO FAILED TO DETECT THESE DEFICIENCIES. GSCO COMPLETED REMEDIATION FOR ALL SURVEILLANCE REPORTS, AND ALSO IMPLEMENTED REVIEWS TO IDENTIFY IF ANY SECURITY WAS INADVERTENTLY EXCLUDED FROM NEW OR MODIFIED SURVEILLANCE REPORTS. THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC. THE FINES WERE ALL PAID IN FULL AS OF MARCH 21, 2024. GOLDMAN SACHS & CO. LLC STAR NO. 20190634995-04/FILE NO. URE-98-08 01/25/2024 CBOE EDGA EXCHANGE, INC. GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), SUBMITTED LETTERS OF CONSENT AND LETTERS OF ACCEPTANCE, WAIVER, AND CONSENT (COLLECTIVELY, "LETTERS"), WHICH WERE ACCEPTED TO ENTER SETTLEMENTS WITH FINRA AND 13 EXCHANGES. GSCO NEITHER ADMITTED NOR DENIED THE FINDINGS IN THE LETTERS, AND CONSENTED TO THE SANCTIONS AND ENTRY OF FINDINGS THAT ITS SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE TRADING ACTIVITY. SPECIFICALLY, FINRA AND THE 13 EXCHANGES FOUND THAT GSCO FAILED TO INCLUDE WARRANTS, RIGHTS, UNITS, AND CERTAIN OVER-THE-COUNTER ("OTC") EQUITY SECURITIES IN CERTAIN SURVEILLANCE REPORTS DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE PROPRIETARY AND CUSTOMER TRADING. THESE SECURITIES WERE EXCLUDED FOR EXTENDED PERIODS RANGING FROM APPROXIMATELY TWO YEARS TO MORE THAN 12 YEARS, BETWEEN 2009 AND 2023. THE FIRM'S SUPERVISORY SYSTEM DID NOT REQUIRE A REVIEW OF ITS AUTOMATED SURVEILLANCE REPORTS, AND AS A RESULT, GSCO FAILED TO DETECT THESE DEFICIENCIES. GSCO COMPLETED REMEDIATION FOR ALL SURVEILLANCE REPORTS, AND ALSO IMPLEMENTED REVIEWS TO IDENTIFY IF ANY SECURITY WAS INADVERTENTLY EXCLUDED FROM NEW OR MODIFIED SURVEILLANCE REPORTS. THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC. THE FINES WERE ALL PAID IN FULL AS OF MARCH 21, 2024. GOLDMAN SACHS & CO. LLC STAR NO. 20190634995-03/FILE NO. URE-98-07 01/24/2024 CBOE EDGX EXCHANGE, INC. GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), SUBMITTED LETTERS OF CONSENT AND LETTERS OF ACCEPTANCE, WAIVER, AND CONSENT (COLLECTIVELY, "LETTERS"), WHICH WERE ACCEPTED TO ENTER SETTLEMENTS WITH FINRA AND 13 EXCHANGES. GSCO NEITHER ADMITTED NOR DENIED THE FINDINGS IN THE LETTERS, AND CONSENTED TO THE SANCTIONS AND ENTRY OF FINDINGS THAT ITS SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE TRADING ACTIVITY. SPECIFICALLY, FINRA AND THE 13 EXCHANGES FOUND THAT GSCO FAILED TO INCLUDE WARRANTS, RIGHTS, UNITS, AND CERTAIN OVER-THE-COUNTER ("OTC") EQUITY SECURITIES IN CERTAIN SURVEILLANCE REPORTS DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE PROPRIETARY AND CUSTOMER TRADING. THESE SECURITIES WERE EXCLUDED FOR EXTENDED PERIODS RANGING FROM APPROXIMATELY TWO YEARS TO MORE THAN 12 YEARS, BETWEEN 2009 AND 2023. THE FIRM'S SUPERVISORY SYSTEM DID NOT REQUIRE A REVIEW OF ITS AUTOMATED SURVEILLANCE REPORTS, AND AS A RESULT, GSCO FAILED TO DETECT THESE DEFICIENCIES. GSCO COMPLETED REMEDIATION FOR ALL SURVEILLANCE REPORTS, AND ALSO IMPLEMENTED REVIEWS TO IDENTIFY IF ANY SECURITY WAS INADVERTENTLY EXCLUDED FROM NEW OR MODIFIED SURVEILLANCE REPORTS. THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC. THE FINES WERE ALL PAID IN FULL AS OF MARCH 21, 2024. GOLDMAN SACHS & CO. LLC 2019063499506 02/06/2024 INVESTORS' EXCHANGE LLC GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), SUBMITTED LETTERS OF CONSENT AND LETTERS OF ACCEPTANCE, WAIVER, AND CONSENT (COLLECTIVELY, "LETTERS"), WHICH WERE ACCEPTED TO ENTER SETTLEMENTS WITH FINRA AND 13 EXCHANGES. GSCO NEITHER ADMITTED NOR DENIED THE FINDINGS IN THE LETTERS, AND CONSENTED TO THE SANCTIONS AND ENTRY OF FINDINGS THAT ITS SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE TRADING ACTIVITY. SPECIFICALLY, FINRA AND THE 13 EXCHANGES FOUND THAT GSCO FAILED TO INCLUDE WARRANTS, RIGHTS, UNITS, AND CERTAIN OVER-THE-COUNTER ("OTC") EQUITY SECURITIES IN CERTAIN SURVEILLANCE REPORTS DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE PROPRIETARY AND CUSTOMER TRADING. THESE SECURITIES WERE EXCLUDED FOR EXTENDED PERIODS RANGING FROM APPROXIMATELY TWO YEARS TO MORE THAN 12 YEARS, BETWEEN 2009 AND 2023. THE FIRM'S SUPERVISORY SYSTEM DID NOT REQUIRE A REVIEW OF ITS AUTOMATED SURVEILLANCE REPORTS, AND AS A RESULT, GSCO FAILED TO DETECT THESE DEFICIENCIES. GSCO COMPLETED REMEDIATION FOR ALL SURVEILLANCE REPORTS, AND ALSO IMPLEMENTED REVIEWS TO IDENTIFY IF ANY SECURITY WAS INADVERTENTLY EXCLUDED FROM NEW OR MODIFIED SURVEILLANCE REPORTS. THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC. THE FINES WERE ALL PAID IN FULL AS OF MARCH 21, 2024. GOLDMAN SACHS & CO. LLC 2019063499507 02/06/2024 NASDAQ STOCK MARKET GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), SUBMITTED LETTERS OF CONSENT AND LETTERS OF ACCEPTANCE, WAIVER, AND CONSENT (COLLECTIVELY, "LETTERS"), WHICH WERE ACCEPTED TO ENTER SETTLEMENTS WITH FINRA AND 13 EXCHANGES. GSCO NEITHER ADMITTED NOR DENIED THE FINDINGS IN THE LETTERS, AND CONSENTED TO THE SANCTIONS AND ENTRY OF FINDINGS THAT ITS SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE TRADING ACTIVITY. SPECIFICALLY, FINRA AND THE 13 EXCHANGES FOUND THAT GSCO FAILED TO INCLUDE WARRANTS, RIGHTS, UNITS, AND CERTAIN OVER-THE-COUNTER ("OTC") EQUITY SECURITIES IN CERTAIN SURVEILLANCE REPORTS DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE PROPRIETARY AND CUSTOMER TRADING. THESE SECURITIES WERE EXCLUDED FOR EXTENDED PERIODS RANGING FROM APPROXIMATELY TWO YEARS TO MORE THAN 12 YEARS, BETWEEN 2009 AND 2023. THE FIRM'S SUPERVISORY SYSTEM DID NOT REQUIRE A REVIEW OF ITS AUTOMATED SURVEILLANCE REPORTS, AND AS A RESULT, GSCO FAILED TO DETECT THESE DEFICIENCIES. GSCO COMPLETED REMEDIATION FOR ALL SURVEILLANCE REPORTS, AND ALSO IMPLEMENTED REVIEWS TO IDENTIFY IF ANY SECURITY WAS INADVERTENTLY EXCLUDED FROM NEW OR MODIFIED SURVEILLANCE REPORTS. THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC. THE FINES WERE ALL PAID IN FULL AS OF MARCH 21, 2024. GOLDMAN SACHS & CO. LLC 2019063499508 02/06/2024 NASDAQ BX, INC. GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), SUBMITTED LETTERS OF CONSENT AND LETTERS OF ACCEPTANCE, WAIVER, AND CONSENT (COLLECTIVELY, "LETTERS"), WHICH WERE ACCEPTED TO ENTER SETTLEMENTS WITH FINRA AND 13 EXCHANGES. GSCO NEITHER ADMITTED NOR DENIED THE FINDINGS IN THE LETTERS, AND CONSENTED TO THE SANCTIONS AND ENTRY OF FINDINGS THAT ITS SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE TRADING ACTIVITY. SPECIFICALLY, FINRA AND THE 13 EXCHANGES FOUND THAT GSCO FAILED TO INCLUDE WARRANTS, RIGHTS, UNITS, AND CERTAIN OVER-THE-COUNTER ("OTC") EQUITY SECURITIES IN CERTAIN SURVEILLANCE REPORTS DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE PROPRIETARY AND CUSTOMER TRADING. THESE SECURITIES WERE EXCLUDED FOR EXTENDED PERIODS RANGING FROM APPROXIMATELY TWO YEARS TO MORE THAN 12 YEARS, BETWEEN 2009 AND 2023. THE FIRM'S SUPERVISORY SYSTEM DID NOT REQUIRE A REVIEW OF ITS AUTOMATED SURVEILLANCE REPORTS, AND AS A RESULT, GSCO FAILED TO DETECT THESE DEFICIENCIES. GSCO COMPLETED REMEDIATION FOR ALL SURVEILLANCE REPORTS, AND ALSO IMPLEMENTED REVIEWS TO IDENTIFY IF ANY SECURITY WAS INADVERTENTLY EXCLUDED FROM NEW OR MODIFIED SURVEILLANCE REPORTS. THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC. THE FINES WERE ALL PAID IN FULL AS OF MARCH 21, 2024. GOLDMAN SACHS & CO. LLC 2019063499509 02/06/2024 NASDAQ PHLX LLC GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), SUBMITTED LETTERS OF CONSENT AND LETTERS OF ACCEPTANCE, WAIVER, AND CONSENT (COLLECTIVELY, "LETTERS"), WHICH WERE ACCEPTED TO ENTER SETTLEMENTS WITH FINRA AND 13 EXCHANGES. GSCO NEITHER ADMITTED NOR DENIED THE FINDINGS IN THE LETTERS, AND CONSENTED TO THE SANCTIONS AND ENTRY OF FINDINGS THAT ITS SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE TRADING ACTIVITY. SPECIFICALLY, FINRA AND THE 13 EXCHANGES FOUND THAT GSCO FAILED TO INCLUDE WARRANTS, RIGHTS, UNITS, AND CERTAIN OVER-THE-COUNTER ("OTC") EQUITY SECURITIES IN CERTAIN SURVEILLANCE REPORTS DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE PROPRIETARY AND CUSTOMER TRADING. THESE SECURITIES WERE EXCLUDED FOR EXTENDED PERIODS RANGING FROM APPROXIMATELY TWO YEARS TO MORE THAN 12 YEARS, BETWEEN 2009 AND 2023. THE FIRM'S SUPERVISORY SYSTEM DID NOT REQUIRE A REVIEW OF ITS AUTOMATED SURVEILLANCE REPORTS, AND AS A RESULT, GSCO FAILED TO DETECT THESE DEFICIENCIES. GSCO COMPLETED REMEDIATION FOR ALL SURVEILLANCE REPORTS, AND ALSO IMPLEMENTED REVIEWS TO IDENTIFY IF ANY SECURITY WAS INADVERTENTLY EXCLUDED FROM NEW OR MODIFIED SURVEILLANCE REPORTS. THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC. THE FINES WERE ALL PAID IN FULL AS OF MARCH 21, 2024. GOLDMAN SACHS & CO. LLC 2019063499510 02/05/2024 NEW YORK STOCK EXCHANGE GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), SUBMITTED LETTERS OF CONSENT AND LETTERS OF ACCEPTANCE, WAIVER, AND CONSENT (COLLECTIVELY, "LETTERS"), WHICH WERE ACCEPTED TO ENTER SETTLEMENTS WITH FINRA AND 13 EXCHANGES. GSCO NEITHER ADMITTED NOR DENIED THE FINDINGS IN THE LETTERS, AND CONSENTED TO THE SANCTIONS AND ENTRY OF FINDINGS THAT ITS SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE TRADING ACTIVITY. SPECIFICALLY, FINRA AND THE 13 EXCHANGES FOUND THAT GSCO FAILED TO INCLUDE WARRANTS, RIGHTS, UNITS, AND CERTAIN OVER-THE-COUNTER ("OTC") EQUITY SECURITIES IN CERTAIN SURVEILLANCE REPORTS DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE PROPRIETARY AND CUSTOMER TRADING. THESE SECURITIES WERE EXCLUDED FOR EXTENDED PERIODS RANGING FROM APPROXIMATELY TWO YEARS TO MORE THAN 12 YEARS, BETWEEN 2009 AND 2023. THE FIRM'S SUPERVISORY SYSTEM DID NOT REQUIRE A REVIEW OF ITS AUTOMATED SURVEILLANCE REPORTS, AND AS A RESULT, GSCO FAILED TO DETECT THESE DEFICIENCIES. GSCO COMPLETED REMEDIATION FOR ALL SURVEILLANCE REPORTS, AND ALSO IMPLEMENTED REVIEWS TO IDENTIFY IF ANY SECURITY WAS INADVERTENTLY EXCLUDED FROM NEW OR MODIFIED SURVEILLANCE REPORTS. THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC. THE FINES WERE ALL PAID IN FULL AS OF MARCH 21, 2024. GOLDMAN SACHS & CO. LLC 2019063499511 02/05/2024 NYSE AMERICAN LLC GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), SUBMITTED LETTERS OF CONSENT AND LETTERS OF ACCEPTANCE, WAIVER, AND CONSENT (COLLECTIVELY, "LETTERS"), WHICH WERE ACCEPTED TO ENTER SETTLEMENTS WITH FINRA AND 13 EXCHANGES. GSCO NEITHER ADMITTED NOR DENIED THE FINDINGS IN THE LETTERS, AND CONSENTED TO THE SANCTIONS AND ENTRY OF FINDINGS THAT ITS SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE TRADING ACTIVITY. SPECIFICALLY, FINRA AND THE 13 EXCHANGES FOUND THAT GSCO FAILED TO INCLUDE WARRANTS, RIGHTS, UNITS, AND CERTAIN OVER-THE-COUNTER ("OTC") EQUITY SECURITIES IN CERTAIN SURVEILLANCE REPORTS DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE PROPRIETARY AND CUSTOMER TRADING. THESE SECURITIES WERE EXCLUDED FOR EXTENDED PERIODS RANGING FROM APPROXIMATELY TWO YEARS TO MORE THAN 12 YEARS, BETWEEN 2009 AND 2023. THE FIRM'S SUPERVISORY SYSTEM DID NOT REQUIRE A REVIEW OF ITS AUTOMATED SURVEILLANCE REPORTS, AND AS A RESULT, GSCO FAILED TO DETECT THESE DEFICIENCIES. GSCO COMPLETED REMEDIATION FOR ALL SURVEILLANCE REPORTS, AND ALSO IMPLEMENTED REVIEWS TO IDENTIFY IF ANY SECURITY WAS INADVERTENTLY EXCLUDED FROM NEW OR MODIFIED SURVEILLANCE REPORTS. THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC. THE FINES WERE ALL PAID IN FULL AS OF MARCH 21, 2024. GOLDMAN SACHS & CO. LLC 2019063499512 02/05/2024 NYSE ARCA GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), SUBMITTED LETTERS OF CONSENT AND LETTERS OF ACCEPTANCE, WAIVER, AND CONSENT (COLLECTIVELY, "LETTERS"), WHICH WERE ACCEPTED TO ENTER SETTLEMENTS WITH FINRA AND 13 EXCHANGES. GSCO NEITHER ADMITTED NOR DENIED THE FINDINGS IN THE LETTERS, AND CONSENTED TO THE SANCTIONS AND ENTRY OF FINDINGS THAT ITS SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE TRADING ACTIVITY. SPECIFICALLY, FINRA AND THE 13 EXCHANGES FOUND THAT GSCO FAILED TO INCLUDE WARRANTS, RIGHTS, UNITS, AND CERTAIN OVER-THE-COUNTER ("OTC") EQUITY SECURITIES IN CERTAIN SURVEILLANCE REPORTS DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE PROPRIETARY AND CUSTOMER TRADING. THESE SECURITIES WERE EXCLUDED FOR EXTENDED PERIODS RANGING FROM APPROXIMATELY TWO YEARS TO MORE THAN 12 YEARS, BETWEEN 2009 AND 2023. THE FIRM'S SUPERVISORY SYSTEM DID NOT REQUIRE A REVIEW OF ITS AUTOMATED SURVEILLANCE REPORTS, AND AS A RESULT, GSCO FAILED TO DETECT THESE DEFICIENCIES. GSCO COMPLETED REMEDIATION FOR ALL SURVEILLANCE REPORTS, AND ALSO IMPLEMENTED REVIEWS TO IDENTIFY IF ANY SECURITY WAS INADVERTENTLY EXCLUDED FROM NEW OR MODIFIED SURVEILLANCE REPORTS. THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC. THE FINES WERE ALL PAID IN FULL AS OF MARCH 21, 2024. GOLDMAN SACHS & CO. LLC 2019063499513 02/05/2024 NYSE CHICAGO, INC. GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), SUBMITTED LETTERS OF CONSENT AND LETTERS OF ACCEPTANCE, WAIVER, AND CONSENT (COLLECTIVELY, "LETTERS"), WHICH WERE ACCEPTED TO ENTER SETTLEMENTS WITH FINRA AND 13 EXCHANGES. GSCO NEITHER ADMITTED NOR DENIED THE FINDINGS IN THE LETTERS, AND CONSENTED TO THE SANCTIONS AND ENTRY OF FINDINGS THAT ITS SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE TRADING ACTIVITY. SPECIFICALLY, FINRA AND THE 13 EXCHANGES FOUND THAT GSCO FAILED TO INCLUDE WARRANTS, RIGHTS, UNITS, AND CERTAIN OVER-THE-COUNTER ("OTC") EQUITY SECURITIES IN CERTAIN SURVEILLANCE REPORTS DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE PROPRIETARY AND CUSTOMER TRADING. THESE SECURITIES WERE EXCLUDED FOR EXTENDED PERIODS RANGING FROM APPROXIMATELY TWO YEARS TO MORE THAN 12 YEARS, BETWEEN 2009 AND 2023. THE FIRM'S SUPERVISORY SYSTEM DID NOT REQUIRE A REVIEW OF ITS AUTOMATED SURVEILLANCE REPORTS, AND AS A RESULT, GSCO FAILED TO DETECT THESE DEFICIENCIES. GSCO COMPLETED REMEDIATION FOR ALL SURVEILLANCE REPORTS, AND ALSO IMPLEMENTED REVIEWS TO IDENTIFY IF ANY SECURITY WAS INADVERTENTLY EXCLUDED FROM NEW OR MODIFIED SURVEILLANCE REPORTS. THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC. THE FINES WERE ALL PAID IN FULL AS OF MARCH 21, 2024. GOLDMAN SACHS & CO. LLC 2019063499514 02/05/2024 NYSE NATIONAL, INC. GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), SUBMITTED LETTERS OF CONSENT AND LETTERS OF ACCEPTANCE, WAIVER, AND CONSENT (COLLECTIVELY, "LETTERS"), WHICH WERE ACCEPTED TO ENTER SETTLEMENTS WITH FINRA AND 13 EXCHANGES. GSCO NEITHER ADMITTED NOR DENIED THE FINDINGS IN THE LETTERS, AND CONSENTED TO THE SANCTIONS AND ENTRY OF FINDINGS THAT ITS SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE TRADING ACTIVITY. SPECIFICALLY, FINRA AND THE 13 EXCHANGES FOUND THAT GSCO FAILED TO INCLUDE WARRANTS, RIGHTS, UNITS, AND CERTAIN OVER-THE-COUNTER ("OTC") EQUITY SECURITIES IN CERTAIN SURVEILLANCE REPORTS DESIGNED TO IDENTIFY POTENTIALLY MANIPULATIVE PROPRIETARY AND CUSTOMER TRADING. THESE SECURITIES WERE EXCLUDED FOR EXTENDED PERIODS RANGING FROM APPROXIMATELY TWO YEARS TO MORE THAN 12 YEARS, BETWEEN 2009 AND 2023. THE FIRM'S SUPERVISORY SYSTEM DID NOT REQUIRE A REVIEW OF ITS AUTOMATED SURVEILLANCE REPORTS, AND AS A RESULT, GSCO FAILED TO DETECT THESE DEFICIENCIES. GSCO COMPLETED REMEDIATION FOR ALL SURVEILLANCE REPORTS, AND ALSO IMPLEMENTED REVIEWS TO IDENTIFY IF ANY SECURITY WAS INADVERTENTLY EXCLUDED FROM NEW OR MODIFIED SURVEILLANCE REPORTS. THE FIRM WAS CENSURED AND FINED A TOTAL AMOUNT OF $512,500 BY FINRA AND THE 13 EXCHANGES, ALLOCATED AS FOLLOWS: $37,000 BY FINRA; $47,000 BY CBOE BYX EXCHANGE, INC.; $47,000 BY CBOE BZX EXCHANGE, INC.; $47,000 BY CBOE EDGA EXCHANGE, INC.; $47,000 BY CBOE EDGX EXCHANGE, INC.; $20,000 BY INVESTORS EXCHANGE LLC; $37,000 BY THE NASDAQ STOCK MARKET LLC; $37,000 BY NASDAQ BX, INC.; $37,000 BY NASDAQ PHLX LLC; $37,000 BY THE NEW YORK STOCK EXCHANGE LLC; $37,000 BY NYSE AMERICAN; $37,000 BY NYSE ARCA, INC.; $37,000 BY NYSE CHICAGO, INC.; AND $8,500 BY NYSE NATIONAL, INC. THE FINES WERE ALL PAID IN FULL AS OF MARCH 21, 2024. GOLDMAN SACHS INTERNATIONAL 2022-033 02/21/2024 ICE FUTURES U.S. ON FEBRUARY 21, 2024, A SUBCOMMITTEE OF THE ICE FUTURES U.S. BUSINESS CONDUCT COMMITTEE ("IFUS") DETERMINED THAT GOLDMAN SACHS & CO. LLC ("GSCO") MAY HAVE VIOLATED EXCHANGE RULE 4.02(C) ON JULY 29, 2022, WHEN AN EMPLOYEE, UPON RECEIPT OF SIMULTANEOUS BUY AND SELL ORDERS IN THE SAME FUTURES CONTRACT, FAILED TO INQUIRE ABOUT THE OWNERSHIP TO CONFIRM WHETHER THEY BELONGED TO THE SAME PRINCIPAL, AND ENTERED THE ORDERS RESULTING IN A WASH TRADE. IN ACCORDANCE WITH THE TERMS OF SETTLEMENT, IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE ALLEGED RULE VIOLATION, GSCO AGREED TO PAY A MONETARY PENALTY OF $10,000. THE FINE WAS PAID IN FULL ON FEBRUARY 26, 2024. GOLDMAN SACHS & CO. LLC (GSCO) 2023-025 04/30/2024 ICE FUTURES U.S., INC. ON APRIL 30, 2024, THE MARKET REGULATION DEPARTMENT OF ICE FUTURES U.S., INC. ("IFUS") FOUND THAT GOLDMAN SACHS & CO. LLC ('GSCO") FAILED TO MEET THE REQUIREMENTS OF EXCHANGE RULES 4.19 (C)(II)(2), AND 4.19(E), BY FAILING TO PRESERVE THE REQUIRED ORDER MESSAGE DATA. IFUS IMPOSED A SUMMARY FINE OF $15,000, WHICH GSCO PAID BY SUBMISSION OF A WIRE ON MAY 8,2024. GOLDMAN SACHS INTERNATIONAL N/A 04/29/2024 BLOOMBERG SEF ON APRIL 29, 2024, BLOOMBERG SEF LLC ("BSEF") DETERMINED THAT GOLDMAN SACHS INTERNATIONAL ('GSI"), VIOLATED BSEF RULE 516 BY FAILING TO NOTIFY BSEF OF AN ERROR TRADE AND BY FAILING TO USE BSEF'S OFFSET AND CORRECT FUNCTIONALITY AS THIS WAS GSI'S SECOND VIOLATION WITHIN A 12-MONTH PERIOD, BSEF IMPOSED A FINE OF $1,250, WHICH GSI PAID BY SUBMISSION OF A WIRE ON MAY 20, 2024. GOLDMAN SACHS INTERNATIONAL N/A 03/25/2024 TW SEF LLC ON MARCH 25, 2024, TW SEF LLC ("TWSEF") DETERMINED GOLDMAN SACHS INTERNATIONAL ("GSI"), VIOLATED TWSEF RULE 1005, BY FAILING TO NOTFIY TWSEF OF AN ERROR TRADE. AS THIS WAS GSI'S SECOND VIOLATION WITHIN A 12-MONTH PERIOD, TWSEF IMPOSED A FINE OF $1,250 WHICH GSI PAID BY SUBMISSION OF A WIRE ON APRIL 24, 2024. GOLDMAN SACHS & CO. LLC CME SUMMARY FINE 05/16/2024 CME GROUP INC. ON MAY 16, 2024, THE MARKET REGULATION DEPARTMENT OF THE CME GROUP INC. ("CME") NOTIFIED GOLDMAN SACHS & CO. LLC ("GSCO" OR "THE FIRM") THAT CME RECENTLY CONDUCTED A SUSPENSE ACCOUNT EXAM FOR TRADE DATES OCTOBER 1, 2023 THROUGH DECEMEBER 31, 2023, WHERE CME IDENTIFIED POTENTIAL VIOLATIONS OF RULE 536.C REGARDING BUNCHED ORDERS AND ORDERS ELGIBILE FOR POST EXECUTION ALLOCATION, FOR USING A GENERAL SUSPENSE ACCOUNT AND NOT OBTAINING SPECIFIC ACCOUNT DESIGNATIONS UNTIL AFTER ORDER ENTRY FOR SIX ORDERS. CME IMPOSED A SUMMARY FINE IN THE AMOUNT OF $1000, WHICH GSCO PAID BY SUBMISSION OF A WIRE ON JUNE 12, 2024. GOLDMAN SACHS INTERNATIONAL (GSI) 2021-404B-005 04/05/2021 ICE CLEAR CREDIT LLC, United States ON APRIL 5, 2021, ICE CLEAR CREDIT LLC ALLEGED THAT DURING MARCH 2021, IN ONE INSTANCE, GOLDMAN SACHS INTERNATIONAL VIOLATED ICE CLEAR CREDIT RULE 404(B), BY FAILING TO SUBMIT EIGHTY-ONE SINGLE NAME PRICES ON A TIMELY BASIS. ON APRIL 5, 2021, ICE CLEAR CREDIT LLC IMPOSED A FINE OF $40,000 AGAINST GOLDMAN SACHS INTERNATIONAL, WHICH GOLDMAN SACHS INTERNATIONAL PAID BY INVOICE IN JUNE 2021. GOLDMAN SACHS & CO. LLC (GSCO) 2021-404B-004 04/05/2021 ICE CLEAR CREDIT LLC, United States ON APRIL 5, 2021, ICE CLEAR CREDIT LLC ALLEGED THAT DURING MARCH 2021, IN ONE INSTANCE, GOLDMAN SACHS & CO. LLC ("GSCO") VIOLATED ICE CLEAR CREDIT RULE 404(B), BY FAILING TO SUBMIT FORTY-FIVE SINGLE NAME PRICES ON A TIMELY BASIS. ON APRIL 5, 2021, ICE CLEAR CREDIT LLC IMPOSED A FINE OF $20,000 AGAINST GSCO, WHICH GSCO PAID BY INVOICE IN JUNE 2021. GOLDMAN SACHS INTERNATIONAL (GSI) N/A 07/29/2024 BLOOMBERG SEF LLC, UNITED STATES ON JULY 29, 2024, BLOOMBERG SEF LLC ("BSEF") DETERMINED THAT GOLDMAN SACHS INTERNATIONAL ("GSI") VIOLATED BSEF RULE 531.A(D) BY SUBMITTING BLOCK TRADES TO BSEF MORE THAN 10 MINUTES AFTER THE TIME THE PARTICIPANTS AGREED TO THE TERMS OF THE BLOCK TRADES. AS THIS WAS GSI'S SECOND VIOLATION WITHIN A 12-MONTH PERIOD, BSEF IMPOSED A FINE OF $1,250, WHICH GSI PAID BY SUBMISSION OF A WIRE ON AUGUST 14, 2024. GOLDMAN SACHS INTERNATIONAL (GSI) N/A 07/29/2024 BLOOMBERG SEF LLC, UNITED STATES ON JULY 29, 2024, BLOOMBERG SEF LLC ("BSEF") DETERMINED THAT GOLDMAN SACHS INTERNATIONAL ("GSI") VIOLATED BSEF RULE 516 BY FAILING TO NOTIFY BSEF OF AN ERROR TRADE AND BY FAILING TO USE BSEF'S OFFSET AND CORRECT FUNCTIONALITY. AS THIS WAS GSI'S SECOND VIOLATION WITHIN A 12-MONTH PERIOD, BSEF INITIALLY IMPOSED A FINE OF $1,250, WHICH GSI PAID BY SUBMISSION OF A WIRE ON AUGUST 14, 2024. ON AUGUST 14, 2024, BSEF SENT A REVISED FINE NOTICE TO REFLECT A $500 PENALTY INCREASE FROM THE ORIGINAL INVOICE ON THE BASIS THAT THIS WAS THE SECOND SUMMARY FINE IN A 12-MONTH PERIOD FOR THE SAME RULE VIOLATION. GSI PAID THE REVISED TOTAL FINE AMOUNT WITHIN THE REQUIRED DEADLINE. GOLDMAN SACHS & CO. LLC (GSCO) FILE NO. URE-257-06 08/14/2024 CBOE BYX EXCHANGE, INC. ON AUGUST 14, 2024, CBOE BYX EXCHANGE, INC. ("CBOE BYX" OR THE "EXCHANGE") ACCEPTED A LETTER OF CONSENT ("LOC") SUBMITTED BY GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE VIOLATIONS BUT CONSENTED TO THE SANCTIONS. IN CONNECTION WITH A DECEMBER 15, 2022 ORDER, CBOE BYX FOUND THAT GSCO FAILED TO IMPLEMENT REASONABLY DESIGNED PRE-ORDER CONTROLS TO PREVENT ERRONEOUSLY PRICED LIMIT ORDERS FROM BEING ENTERED ON THE EXCHANGE. AS A RESULT, THE EXCHANGE DETERMINED THAT GSCO VIOLATED SEC RULE 15C3-5 AND BYX RULE 3.2. PURSUANT TO THE LOC, GSCO WAS CENSURED AND AGREED TO PAY A MONETARY FINE OF $7,500. GOLDMAN SACHS & CO. LLC (GSCO) FILE NO. URE-257-07 08/14/2024 CBOE EDGX EXCHANGE, INC. ON AUGUST 14, 2024, CBOE EDGX EXCHANGE, INC. ("CBOE EDGX" OR THE "EXCHANGE") ACCEPTED A LETTER OF CONSENT ("LOC") SUBMITTED BY GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM"), IN WHICH GSCO NEITHER ADMITTED NOR DENIED THE VIOLATIONS BUT CONSENTED TO THE SANCTIONS. IN CONNECTION WITH A DECEMBER 15, 2022 ORDER, CBOE EDGX FOUND THAT GSCO FAILED TO IMPLEMENT REASONABLY DESIGNED PRE-ORDER CONTROLS TO PREVENT ERRONEOUSLY PRICED LIMIT ORDERS FROM BEING ENTERED ON THE EXCHANGE. AS A RESULT, THE EXCHANGE DETERMINED THAT GSCO VIOLATED SEC RULE 15C3-5 AND EDGX RULE 3.2. PURSUANT TO THE LOC, GSCO WAS CENSURED AND AGREED TO PAY A MONETARY FINE OF $7,500. Goldman Sachs & Co. LLC DQA-24-1536 10/30/2024 CME Group Inc. ON OCTOBER 30, 2024, CME GROUP MARKET REGULATION ("CME") CONCLUDED ITS 2024 ELECTRONIC TRADING RECORDKEEPING EXAMINATION OF GOLDMAN SACHS & CO. LLC ("GSCO") FOR TRADE DATES APRIL 1THROUGH JUNE 30, 2024. DURING THE REVIEW, CME FOUND ISSUES CONCERNING CERTAIN OPERATOR IDS THAT WERE ACTIVE AND REQUIRED TO BE REGISTERED IN THE EXCHANGE FEE SYSTEM BUT WERE NOT REGISTERED UNTIL AFTER THE REVIEW PERIOD, IN VIOLATION OF CME RULE 576 ("IDENTIFICATION OF GLOBEX TERMINAL OPERATORS"). GSCO REGISTERED THE OPERATOR IDS DURING THE EXAMINATION. CME IMPOSED A $4,000 SUMMARY FINE ON GSCO FOR FAILURE TO COMPLY WITH CME RULE 576. GSCO PAID THE FINE ON NOVEMBER 12, 2024. Goldman Sachs & Co. LLC (GSCO) 2022074103602 05/12/2025 Investors Exchange LLC (IEX) Goldman Sachs & Co. LLC ("GSCO" or the "Firm") settled parallel matters with the Financial Industry Regulatory Authority (FINRA) and Investors Exchange LLC (IEX). Without admitting or denying the findings, the Firm consented to the sanctions and findings by IEX that due to a configuration error, from October 22, 2021 to November 16, 2021, GSCO input over 16 million orders into IEX's system with inaccurate capacity, made and kept order memoranda for those orders that reflected inaccurate capacity, and had related supervisory failures, in violation of the Securities Exchange Act of 1934 and IEX Rules. For these violations, GSCO was censured and fined $1,450,000, of which $95,000 is payable to IEX and the remaining amount to FINRA. The Firm has processed its payment to IEX via wire. Goldman Sachs & Co. LLC (GSCO) 2022074103601 05/13/2025 Financial Industry Regulatory Authority (FINRA) Goldman Sachs & Co. LLC ("GSCO" or the "Firm") settled parallel matters with the Financial Industry Regulatory Authority (FINRA) and Investors Exchange LLC (IEX). Without admitting or denying the findings, the Firm consented to the sanctions and findings by FINRA that (1) GSCO failed to accurately report data for 36.6 billion equity order events to the consolidated audit trail (CAT) Central Repository between June 2020 and June 2023, and had related supervisory failures, in violation of FINRA Rules; and (2) due to a configuration error, from October 22, 2021 to November 16, 2021, GSCO made over 90 million inaccurate order memoranda, inaccurately reported over 6.8 million trades and overreported over 98,000 trades to a trade reporting facility, and issued over 372,000 inaccurate trade confirmations, and had related supervisory failures, in violation of the Securities Exchange Act of 1934 and FINRA Rules. For these violations, GSCO was censured and fined $1,450,000, of which $1,355,000 is payable to FINRA and the remaining amount to IEX. The Firm has processed its payment to FINRA via wire. Goldman Sachs International (GSI) N/A 07/02/2025 Bloomberg SEF LLC On July 2, 2025, Bloomberg SEF LLC ("BSEF") determined that Goldman Sachs International ("GSI") violated BSEF Rule 516 by failing to correct an error trade executed on the BSEF platform in accordance with the requirements under Rule 516. Specifically, GSI utilized BSEF to correct an error trade not originally executed on BSEF. BSEF imposed a fine of $2,000.00, which GSI paid by submission of a wire on July 21, 2025. N N Y Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org 02/27/2023 Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org Please see historical filings made on applicant's Form BD (FINRA CRD #361 and SEC Filing Nos. 801-1604 and 8-129). Applicant's disciplinary history may be also found at https://brokercheck.finra.org GOLDMAN SACHS (SINGAPORE) PTE. SO/AB/EFD2/2022-23/7083 09/18/2023 SECURITIES AND EXCHANGE BOARD OF INDIA, The Republic of India GOLDMAN SACHS (SINGAPORE) PTE. ("GSSP") SUBMITTED A SETTLEMENT PROPOSAL TO THE SECURITIES AND EXCHANGE BOARD OF INDIA ("SEBI") ON MARCH 27, 2023 IN ORDER TO RESOLVE ALLEGATIONS OF DISCREPANCIES IN THE MONTHLY REPORTING OF OFFSHORE DERIVATIVE INSTRUMENTS BETWEEN MARCH 2022 AND JANUARY 2023 IN DEFAULT OF REGULATION 21 OF THE SEBI REGULATIONS. THE SETTLEMENT ORDER WAS PASSED BY SEBI AND WENT INTO IMMEDIATE EFFECT ON SEPTEMBER 18, 2023. WITHOUT ADMITTING OR DENYING FAULT, GSSP AGREED TO A SETTLEMENT AMOUNT OF RUPEES 26,44,500 (APPROXIMATELY USD 31,771.05), WHICH WAS PAID ON AUGUST 23, 2023. GOLDMAN SACHS (INDIA) ALTERNATIVE INVESTMENT MANAGEMENT PVT. LTD. CA No 6134/ 2023 09/21/2023 RESERVE BANK OF INDIA, The Republic of India ON SEPTEMBER 11, 2023, THE RESERVE BANK OF INDIA ("RBI") ISSUED A COMPOUNDING ORDER AGAINST GOLDMAN SACHS (INDIA) ALTERNATIVE INVESTMENT MANAGEMENT PVT. LTD. ("GS AIF IM" OR "ENTITY") BASED ON THEIR DETERMINATION THAT GS AIF IM RECEIVED FOREIGN DIRECT INVESTMENT WITHOUT APPROVAL IN CONTRAVENTION OF REGULATION 16(B) (TABLE SERIAL NO. F.10) OF THE FOREIGN EXCHANGE MANAGEMENT (TRANSFER OR ISSUE OF SECURITY BY A PERSON RESIDENT OUTSIDE INDIA) REGULATIONS, 2017. ON DECEMBER 1, 2022, THE DEPARTMENT OF ECONOMIC AFFAIRS, GOVERNMENT OF INDIA, GRANTED POST-FACTO APPROVAL TO GS AIF IM SUBJECT TO COMPOUNDING WITH THE RBI. PURSUANT TO THE COMPOUNDING ORDER, GS AIF IM ADMITTED TO THE VIOLATION AND AGREED TO PAY RUPEES 16,75,000 (APPROXIMATELY USD 20,125.14) WHICH WAS PAID ON SEPTEMBER 21, 2023. Y GOLDMAN SACHS & CO. LLC RE: VIOLATION OF RULE 401(I) - FAILURE TO SUBMIT TIMELY MARGIN PAYMENTS ICE CLEAR CREDIT MATTER NO. 2023-401I-001 03/13/2023 ICE CLEAR CREDIT LLC 353 NORTH CLARK STREET, SUITE 3100, CHICAGO, IL 60654 ON MARCH 13, 2023, ICE CLEAR CREDIT LLC ("ICC") ALLEGED THAT A GOLDMAN SACHS & CO. LLC ("GSCO") MARGIN CALL PAYMENT WAS RECEIVED SIX MINUTES AFTER THE REQUIRED DEADLINE RESULTING IN A TECHNICAL DEFAULT IN VIOLATION OF ICE CLEAR CREDIT RULE 401(i). GSCO IS IN THE PROCESS OF RESPONDING TO THE ALLEGATIONS AND DETAILING THE CIRCUMSTANCES RELATING TO THE SUBJECT MARGIN PAYMENT. THE MATTER IS PENDING SUBJECT TO REVIEW BY ICC. GOLDMAN SACHS & CO. LLC (GSCO) 2023-401I-001 03/13/2023 ICE CLEAR CREDIT LLC, United States ON MARCH 13, 2023, ICE CLEAR CREDIT LLC ("ICC") ALLEGED THAT A GOLDMAN SACHS & CO. LLC ("GSCO") MARGIN CALL PAYMENT WAS RECEIVED SIX MINUTES AFTER THE REQUIRED DEADLINE RESULTING IN A TECHNICAL DEFAULT IN VIOLATION OF ICE CLEAR CREDIT RULE 401(I). GSCO IS IN THE PROCESS OF RESPONDING TO THE ALLEGATIONS AND DETAILING THE CIRCUMSTANCES RELATING TO THE SUBJECT MARGIN PAYMENT. THE MATTER IS PENDING SUBJECT TO REVIEW BY ICC. GOLDMAN SACHS & CO. LLC STAR No. 20190634995; File Nos. URE-98-05, -06, -07, -08 06/27/2023 FINANCIAL INDUSTRY REGULATORY AUTHORITY, United States ON JUNE 27, 2023, GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM") RECEIVED A NOTICE ISSUED BY THE DEPARTMENT OF ENFORCEMENT ("ENFORCEMENT") AT THE FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA"), WHO IS HANDLING THIS MATTER ON BEHALF OF CBOE BZX EXCHANGE, INC. ("BZX"), CBOE BYX EXCHANGE, INC. ("BYX"), CBOE EDGX EXCHANGE, INC. ("EDGX"), AND CBOE EDGA EXCHANGE, INC. ("EDGA") (COLLECTIVELY, THE "EXCHANGES"). ENFORCEMENT ALLEGES THAT BETWEEN FEBRUARY 2019 AND APRIL 14, 2023, GSCO VIOLATED BZX, BYX, EDGX, AND EDGA RULES 5.1. ON JUNE 27, 2023, GOLDMAN SACHS & CO. LLC ("GSCO" OR THE "FIRM") RECEIVED A NOTICE ISSUED BY THE DEPARTMENT OF ENFORCEMENT ("ENFORCEMENT") AT THE FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA"), WHO IS HANDLING THIS MATTER ON BEHALF OF CBOE BZX EXCHANGE, INC. ("BZX"), CBOE BYX EXCHANGE, INC. ("BYX"), CBOE EDGX EXCHANGE, INC. ("EDGX"), AND CBOE EDGA EXCHANGE, INC. ("EDGA") (COLLECTIVELY, THE "EXCHANGES"). ENFORCEMENT ALLEGES THAT BETWEEN FEBRUARY 2019 AND APRIL 14, 2023, GSCO VIOLATED BZX, BYX, EDGX, AND EDGA RULES 5.1. N N /s/ Ken Cawley 1-312-655-5995 Managing Director 08/26/2025