Lawyers representing Ryan Salame have requested the former co-CEO of FTX Digital Markets be sentenced to no more than 18 months in prison.

In a May 14 filing with the United States District Court for the Southern District of New York, Salame’s legal team argued that in addition to the “substantial restitution and forfeiture obligations” offered by the former FTX executive, a sentence of no more than 18 months in prison was “appropriate.” Salame pleaded guilty to conspiracy to operate an unlicensed money-transmitting business and engaging in campaign finance fraud in September 2023 and is scheduled to be sentenced by Judge Lewis Kaplan on May 28.

“[Salame] had absolutely no knowledge that the four people at the center of Alameda and FTX had conspired to lie and steal from their customers,” his lawyers claimed in the May 14 sentencing memo. “Ryan stole from no one. He did not lie to customers. And he was duped, as was everyone else, into believing that the companies were legitimate, solvent, and wildly profitable.”

The filing added:

“As Caroline Ellison testified at Bankman-Fried’s trial, even as the FTX exchange was collapsing on November 6, 2022, she and Bankman-Fried conspired to keep Ryan in the dark about their fraud, misleading him just as they had misled the rest of the world.”
Source: Courtlistener

Salame reported FTX’s fraudulent activities to the Securities Commission of the Bahamas on Nov. 9, 2022 — just two days before former FTX CEO Sam “SBF” Bankman-Fried stepped down and the exchange filed for bankruptcy. Bankman-Fried was later extradited to the U.S. from the Bahamas and convicted of seven felony counts. A judge sentenced him to 25 years in prison in March.

According to Salame’s lawyers, an 18-month sentence was appropriate for the former FTX executive as he occupied the “lowest rung of the conspiracies to which he pleaded guilty” and was unlikely to commit similar crimes. Unlike in Bankman-Fried’s case, which seemingly served as a deterrent to individuals in the crypto space, Salame has “truly accepted responsibility” for his actions.

Related: FTX victims describe ‘irreparable harm’ ahead of Sam Bankman-Fried’s sentencing

The former executive will likely be the second figure connected to FTX and Alameda Research to be sentenced after Bankman-Fried. Former Alameda CEO Caroline Ellison, FTX co-founder Gary Wang and former FTX engineering director Nishad Singh all pleaded guilty to charges and testified in SBF’s criminal trial, but it was unclear at the time of publication whether they would serve time in prison.

Following his guilty plea in 2023, Salame has remained free on a $1 million bond. As part of his deal with prosecutors, he will have to pay roughly $6 million in penalties to the U.S. government and $6 million to FTX debtors and surrender two properties and a business. His lawyers said this would leave him with “no remaining assets.”

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