Total Offense Level: 8 Base Offense Level under § 2C1.8(a): 8 Enhancement under § 2B1.1 for value not exceeding $6,500: 0 Enhancement for number of illegal transactions under § 2C1.8(b)(4) (two conduit contributions of $2,000 each): 0 Recommended Sentence: (1) Incarceration: 0 to 6 months in Zone A. (2) Fine: A minimum fine of $1,000 and a statutory maximum fine of $100,000, calculated as follows: (a) Guideline fine: The maximum fine for a Class A misdemeanor under 18 U.S.C. § 3571(b)(5) is $100,000. However, the applicable guideline fine under U.S.S.G. § 5E1.2(c)(3) for an offense level of 8 would be a minimum of $2,000 and a maximum of $20,000. A fine above $20,000 for this offense would require an upward departure under § 5K2.0. (b) FECA mandatory fine: Not applicable. The offense of conviction involves two violations of 5 2 U.S.C. § 30122, totaling $4,000. Since the violations do not exceed $25,000, this is a misdemeanor that is subject to the penalty provisions of 52 U.S.C. § 30109(d)(1)(A)(ii) and 18 U.S.C. § 3571(b)(5). Because this is a misdemeanor, the mandatory minimum and the discretionary maximum fining provisions applicable to felony conduit violations under 52 U.S.C. § 30109(d)(1)(D)(i) do not apply. 186

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