contributions back to the two corporations. The defendant makes clear to senior management that their success in his companies depends on their participation in the scheme. The defendant’s motive is ideological – all the recipients represent causes in which he believes. The aggregate value involved in the defendant’s conduct is $50,000. The conduct would be charged in two counts: one felony violation of Section 30118 charged under § 30109(d)(1)(A)(i), and fifty violations of Section 30122 aggregated together as one felony offense charged under § 30109(d)(1)(D)(i). Total offense level: 20 Base Offense Level under § 2C1.8(a): 8 Enhancements for aggregate value of offense between $40,000 and $95,000 under § 2B1.1(b)(1)(D): 6 Enhancements for number of illegal transactions under § 2C1.8(b)(4) (Fifty-two offenses – two § 30118 corporate contribution offenses and fifty § 30122 conduit offenses): 2 Enhancement for intimidation and threats under § 2C1.8(b)(5): 4 Recommended Sentence: (1) Incarceration: 33 to 41 months in Zone D (2) Fine: Because the nature of the conduct would result in convictions under both the criminal penalty applicable to conduit violations of FECA (§ 30109(d)(1)(D)), and the criminal penalty applicable to non-conduit violations of FECA (§ 30109(d)(1)(A)), the statutory 189

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