Prosecutors are asking for a sentence of 40-50 years for former CEO of bankrupt cryptocurrency exchange FTX and convicted fraudster Sam Bankman-Fried. He faces up to 110 years behind bars under the law.

The 116-page Government’s Sentencing Memorandum, submitted to Judge Lewis Kaplan on March 15, recounts Bankman-Fried’s activities in detail, focusing on five points: Bankman-Fried’s scheme to make illegal political contributions, his attempt to bribe Chinese government officials, his banking misconduct, his attempts to deflect blame and various obstructions of justice.

Bankman-Fried was not charged with illegal political contributions because the government of The Bahamas did not extradite him on that charge. Nor was he charged with bribing Chinese officials. The memorandum also stated:

“The defendant has failed to take genuine responsibility for his role in the collapse of FTX and the loss of customer funds.”

Bankman-Fried’s sentence should be subject to several enhancements due to the severity of his crimes, the document continued. It repeatedly compared Bankman-Fried to Bernie Madoff, the New York financier who ran the largest known Ponzi scheme in history, as well as other financial criminals. It also included four pages of accounts by victims of Bankman-Fried’s fraud of the turmoil caused by the losses the collapse of FTX caused them.

Related: Sam Bankman-Fried’s brother: ‘His life would be wasted in prison’

On Nov. 2, Bankman-Fried was found guilty of seven charges: two counts of wire fraud, two counts of wire fraud conspiracy, one count of securities fraud, one count of commodities fraud conspiracy and one count of money laundering conspiracy. His legal counsel asked the court for a maximum sentence of six and a half years. He had pleaded not guilty to all the charges.

A sentence of 40-50 years “will permit the defendant to return to liberty after society can be assured that he will not have the opportunity to turn back to fraud and deceit” but still “reflect the seriousness of the defendant’s crimes,” the prosecutors said. They also ask for an $11 billion judgment against him.

Judge Kaplan of the District Court of Southern New York is not required to adhere to the government’s recommendations in the memorandum. Sentencing is set for March 28.

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