Epstein File EFTA01394160: Memorandum and RICO (DS10)

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💨IMPACT LEVEL 1 — MEH

Epstein File EFTA01394160: Memorandum and RICO (DS10)

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This is a confidential private placement memorandum discussing partnership interest transferability restrictions and partnership agreement terms. The document also references Raymond James' settlement with multiple jurisdictions including Puerto Rico, the Virgin Islands, and the District of Columbia regarding allegations of failure to supervise, indicating potential compliance or regulatory issues related to the fund's operations.

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memorandum RICO virgin

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Excerpt 1

As described elsewhere in this **Memorandum**, the transferability of the Interests will be further restricted by the terms of the Partnership Agreement.

Excerpt 2

("Raymond James") settled with most of the states, Puerto **Rico**, the Virgin Islands, and the District of Columbia allegations that they failed to supervise