Goldman Sachs is negotiating with federal prosecutors to pay a fine of as much as $2 billion, and have a subsidiary plead guilty to settle claims about its role in a scheme to loot billions from a sovereign wealth fund in Malaysia, according to two people with knowledge of the matter.

The case stems from a scheme to siphon off more than $2.7 billion of the $6.5 billion raised for the 1Malaysia Development Berhad, known as 1MDB. Federal authorities have that said Jho Low, a flamboyant Malaysian financier, was the principal architect of the plot to bribe public officials that has led to the guilty plea of a former Goldman partner and criminal charges against another of the bank’s executives.

The investigation is focused on violations of money laundering and foreign bribery laws. The settlement could include a guilty plea from Goldman’s subsidiary in Asia, the people said, asking not to be identified because the talks were continuing. The bank may agree to include an outside monitor to review its compliance procedures, a provision that has become common when banks resolve criminal investigations.

A separate fine paid to the government of Malaysia and other regulatory agencies could raise the total financial penalty to more than $2 billion, according to three people familiar with the talks. It’s possible the settlement could be completed by the end of January.