Federal prosecutors on Friday called Paul Manafort’s tax and bank fraud “serious, longstanding, and bold” but did not recommend a specific punishment for his convictions in Virginia.

Federal guidelines call for President Trump’s onetime campaign chairman to spend 19 to a little more than 24 years in prison, the prosecutors noted Friday in a sentencing memo filed in federal court in Alexandria. They said the range was properly calculated by Manafort’s probation officer.

“Manafort acted for more than a decade as if he were above the law, and deprived the federal government and various financial institutions of millions of dollars,” the special counsel investigating Russian interference in the 2016 election wrote in the memo to Judge T.S. Ellis III. “The sentence here should reflect the seriousness of these crimes.”

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A jury in Ellis’s courtroom found Manafort, 69, guilty of failing to pay taxes on millions of dollars in income and lying to banks to get loans when those funds dried up. He subsequently pleaded guilty in federal court in the District to related conspiracy charges.

Altogether, the special counsel noted, Manafort has admitted breaking the law from 2005 through 2018, committing crimes that stemmed from his lobbying work for a pro-Russian political party and politician in Ukraine.

“Given the breadth of Manafort’s criminal activity, the government has not located a comparable case with the unique array of crimes and aggravating factors,” prosecutors wrote.

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There was also no motivation or explanation to be found in his background and life circumstances, the government said.

“Manafort did not commit these crimes out of necessity or hardship,” prosecutors wrote. “He was well educated, professionally successful, and financially well off.” He carried out the fraud “for no reason other than greed, evidencing his belief that the law does not apply to him.”

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Prosecutors says that while he roped other people into his schemes, including his business partner and fellow Trump campaign staffer Rick Gates, “in every scheme, Manafort was always the principal, and almost always the exclusive beneficiary.” Manafort’s trial in Virginia put a spotlight on his lavish lifestyle that included designer clothing and high-end properties.

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Gates, who testified against Manafort at trial, pleaded guilty in federal court in the District and has yet to be sentenced.

Prosecutors reject Manafort’s age and public image as reasons for lenience, saying that he was still committing crimes last year and arguing that the “national attention” the case has garnered could deter others from committing fraud.

“Tax evasion through the use of offshore entities and bank accounts is among the most lucrative offenses and often the most difficult to investigate,” they wrote. “The sentence should send a clear message that repeated choices to commit serious economic crimes have serious consequences.”

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Manafort’s guilty plea in Washington does not amount to an acceptance of responsibility, the special counsel argued, especially because Judge Amy Berman Jackson in that court district has since concluded that Manafort broke his agreement with the government and lied to investigators. He had promised to cooperate fully with the special counsel investigation and answer all questions truthfully.

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According to prosecutors, Manafort has also failed to hand over financial information to his probation officer as required.

No date for sentencing has been set in Virginia; the government has asked for it to happen soon.

“There are no outstanding issues warranting delay,” Assistant U.S. Attorney Uzo Asonye wrote in an earlier filing, adding that “the government requests that the Court set a new sentencing date as soon as practicable.”

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Manafort’s attorneys have instead requested a hearing to set dates for sentencing and related pleadings.

Jackson concluded last week that Manafort did in fact lie to the special counsel and break his plea agreement.

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On Friday, Jackson released a partially redacted transcript of the sealed hearing at which she explained why she rejected defense attorneys’ arguments that Manafort’s misstatements were the result of confusion or faulty recollection.

“Concessions come in dribs and drabs, only after it’s clear that the Office of Special Counsel already knew the answer,” she said in the hearing. “It’s part of a pattern of requiring the Office of Special Counsel to pull teeth; withholding facts if he can get away with it. And that’s just not consistent with what was contemplated by the plea, and it supports the breach determination.”

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Manafort lied about a $125,000 payment toward a debt he owed a law firm and about another, unrelated Justice Department investigation, the judge found.

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In the released transcript, Jackson discloses that both the payment and the other investigation were related to the Trump campaign. Investigators asked about the payment while tracking the flow of money to Manafort “particularly from vendors associated with the campaign,” she said. The judge said Manafort’s lies in the other investigation came as he tried to take back information about others that he had proffered to prosecutors as a person who worked “at the highest level of the campaign.”

He also lied about his interactions with Konstantin Kilimnik, a longtime aide assessed by the FBI to have ties to Russian intelligence, the judge found.

Jackson called Manafort’s interactions with Kilimnik “a topic at the undisputed core” of the Mueller investigation and said Manafort’s many false statements about Kilimnik made “unpersuasive” the defense’s arguments that his faulty memory had no pattern.

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Kilimnik denied having Russian intelligence connections in a 2017 interview with The Washington Post.

Manafort continues to maintain that he did not intentionally mislead prosecutors, and his attorneys on Friday urged Ellis to read the complete transcripts and motions from Jackson’s courtroom.

“The information redacted from the public versions of these documents is critical to the consideration of the issues raised during that litigation,” they wrote.

Because Manafort was found to have failed to cooperate truthfully, the government is no longer required to recommend he get a reduced sentence from Jackson at his March 13 sentencing in the District. The maximum punishment for the two conspiracy crimes to which he pleaded guilty is 10 years, but the judge has said she might make her sentence run consecutive to what Ellis imposes.

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