“A hardened adherence to committing crimes”: Mueller pulls no punches in Manafort sentencing memo

Manafort is currently in jail, awaiting sentencing.
Manafort is currently in jail, awaiting sentencing.
Image: AP Photo/Susan Walsh
We may earn a commission from links on this page.

In the sentencing memo for former national security advisor Michael Flynn, special counsel Robert Mueller recommended little to no jail time, noting that Flynn had offered useful information to the special counsel. Mueller recommended substantial jail time for former Trump associate Michael Cohen, given the serious nature of his crimes, but commented in his memo that Cohen had been a remorseful and cooperative defendant.

Former Trump campaign chairman Paul Manafort, however, is a different story.

In a 25-page sentencing memo made public on Saturday, Mueller doesn’t suggest how many years Manafort should spend in prison. But he paints a stark portrait of an unrepentant criminal who unabashedly perpetrated crimes, profited from crimes, and continued to orchestrate crimes even while being investigated for crimes he’d already done.

Manafort will be sentenced twice next month: first on March 8, for the eight counts of financial fraud a Virginia federal court found him guilty of in August, and on March 13 for two criminal counts he pled guilty to in a Washington, DC district court. In total, he could face more than two decades in prison, tantamount to a life sentence—Manafort turns 70 on April 1.

As a matter of course, the special counsel’s office doesn’t make prison time recommendations. But Mueller’s memo makes clear that the special counsel sees no reason judge Amy Berman Jackson should hold back.

Some highlights from the memo:

Manafort’s record of criminal conduct goes way back—and, remarkably, continued even after his indictment.

“Manafort committed an array of felonies for over a decade, up through the fall of 2018. Manafort chose repeatedly and knowingly to violate the law—whether the laws proscribed garden-variety crimes such as tax fraud, money laundering, obstruction of justice, and bank fraud, or more esoteric laws that he nevertheless was intimately familiar with, such as the Foreign Agents Registration Act (FARA). His criminal actions were bold, some of which were committed while under a spotlight due to his work as the campaign chairman and, later, while he was on bail from this Court. And the crimes he engaged in while on bail were not minor; they went to the heart of the criminal justice system, namely, tampering with witnesses so he would not be held accountable for his crimes.”

He told Mueller’s team he would cooperate, and then kept on lying.

“Even after he purportedly agreed to cooperate with the government in September 2018, Manafort, as this court found, lied to the Federal Bureau of Investigation (FBI), this office, and the grand jury. His deceit, which is a fundamental component of the crimes of conviction and relevant conduct, extended to tax preparers, bookkeepers, banks, the Treasury Department, the Department of Justice National Security Division, the FBI, the Special Counsel’s Office, the grand jury, his own legal counsel, Members of Congress, and members of the executive branch of the United States government. In sum, upon release from jail, Manafort presents a grave risk of recidivism.”

No special circumstances suggest he should get a break.

“Nothing about Manafort’s upbringing, schooling, legal education, or family and financial circumstances mitigates his criminality.”

He’s not sorry.

“Manafort’s conduct after he pleaded guilty is pertinent to sentencing. It reflects a hardened adherence to committing crimes and lack of remorse.”

His case should set an example.

“The sentence in this case must take into account the gravity of this conduct, and serve both to specifically deter Manafort and generally deter those who would commit a similar series of crimes.”