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⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA00584588: Sessions, John Sarbanes and Sarbanes (DS9)

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A document describing internal control improvements and compliance measures related to Sarbanes-Oxley, including negotiation of fund terms with investment teams and outside counsel.

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execution process with investment team and outside counsel including negotiation of fund terms Strengthened internal controls to ensure compliance with **Sarbanes**-Oxley
Excerpt 2
accounting and tax consequences associated with various transactions and financial instruments Trained and educated staff through formal and informal **sessions**

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