Goldman Sachs files 2025 living will, outlining orderly wind-down plan
Goldman’s June 30 living will maps the legal entities, liquidity and critical services that would have to keep clients moving if the firm hit severe stress.
Goldman Sachs filed its 2025 Global Resolution Plan public section dated June 30, 2025, setting out how The Goldman Sachs Group, Inc. could be resolved in an orderly way if the firm ever came under severe distress. The filing sits under section 165(d) of the Dodd-Frank Wall Street Reform and Consumer Protection Act, the post-crisis rule that requires large, complex financial firms to show regulators how they could be unwound without threatening financial stability.
The document is more than a regulatory compliance exercise. It is a window into Goldman’s legal structure and the way the firm separates booking models, liquidity management, critical operations and client-facing services across entities and geographies. In a stress scenario, that architecture is meant to keep core functions running while markets absorb the failure without chaos. For bankers, traders and support teams, the filing shows why some activities sit in specific legal entities and why compliance and operations are central to a global investment bank that still has to serve clients under pressure.
That internal map matters because it reveals how Goldman thinks about separability. The resolution plan lays out where risk is housed, how key businesses are supported, and what has to stay connected if the firm is forced into a wind-down. It also shows that Goldman is not just a collection of revenue-producing desks at 200 West Street in New York. It is a tightly regulated network of legal entities, support systems and technology infrastructure that must remain functional enough to protect client continuity and market stability.
The filing also sits inside a formal supervisory cycle that has become part of the annual rhythm for the biggest banks. Goldman received a resolution plan feedback letter on June 20, 2024 for its 2023 plan. A May 21, 2026 feedback letter from the Federal Reserve Board and the Federal Deposit Insurance Corporation said the agencies had received Goldman’s 2025 plan on or before July 1, 2025, the Dodd-Frank deadline. The agencies also released public sections of resolution plans for several other large banking organizations, including Bank of America, JPMorgan Chase, Citigroup and Wells Fargo.
Goldman’s long paper trail shows how embedded this process has become. The firm has filed public resolution plans in 2013, 2016, 2019, 2021, 2023 and now 2025. What once looked like a post-crisis paperwork burden has become a recurring test of whether Goldman can explain its own structure clearly enough to convince regulators that its most important functions, and the clients tied to them, could survive an orderly unwind.
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