[ORDER SOLUTION] calculating monetary fines

COMPUSTARTUP, a public company, has been found guilty of defrauding shareholders. The base fine has been computed at a Level 30 offense (See HERE to determine amount). Aggravating factors include information that suggests the Senior Vice President of Accounting knew about the corruption and turned a blind eye. Despite this, it was the CEO — who had no knowledge of the fraud — who alerted the SEC and the company, aside from the perpetrators’ initial untrue statements to the grand jury, has willingly cooperated. The net worth of the company is approximately $28 million. Establish the total fine that you recommend using the three-step process under the FSGO. Show your computations for the fine that you recommend and explain how you arrived at your culpability score. What if the CEO had been involved, and he or she has already been convicted on SEC fraud before? How would that change your culpability score? How can companies take proactive steps to minimize culpability scores?