Sterling will be on probation for 36 months and agreed to pay restitution in the amount of $27,239,000 to non insider victim-shareholders. Sterling also agreed to follow the law, pay the mandatory special assessment of $400, cooperate with and report to the United States Department of Justice, Criminal Division, Fraud Section, implement an ongoing compliance and ethics program, and separately pay Restitution Fund administration costs. Sterling paid the restitution amount to the Clerk of Court on August 15, 2023. The Court approved the Restitution Order on July 21, 2023, and on October 20, 2023, appointed the Special Master (who will administer and distribute the restitution money).