In a memo unsealed Saturday Robert Mueller accused former Trump employee Paul Manafort of a series of crimes.

The accusations range from commonplace tax fraud and obstruction of justice to federal laws like the Foreign Agents Registration Act and argues that Manafort knowingly broke the law throughout. The memo finds a number of aggravating factors and no mitigating factors in Manafort’s conduct both at the time and in his appearances before the Special Prosecutor’s Office. Mueller specifically calls out Manafort for lying to the FBI, the Special Prosecutor’s Office and the grand jury. Mueller also notes that Manafort’s criminal behavior continued during his release per the plea deal and included witness and evidence tampering.

This is the second memo the Special Prosecutor’s Office has released in the sentencing of Paul Manafort, which is scheduled to occur March 13. The previous memo from February 15 calculated Manafort’s penalties under federal sentencing guidelines to be anywhere from 235-293 months (roughly 19-24 years) of imprisonment, a fine of $50,000-$24 million, restitution of $24 million dollars, forfeiture of $4 million and an additional five years of supervised release. Mueller did not mention any specific terms of sentencing his office is requesting in the new memo but did note that he believes Manafort is a grave risk of recidivism.