I don’t believe so, but the judge sentenced him so harshly because the amount involved was astronomical, exceeding the maximum amount specified by federal sentencing guidelines for fraud ($400 million at the time)[0]. Also, many people lost their life savings and the fraud lasted for nearly 30 years and the judge didn’t feel that Madoff did everything he could to mitigate the harm caused by his actions.
[0](https://www.washingtonpost.com/wp-dyn/content/article/2009/0...)