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💨IMPACT LEVEL 1 — MEH

Epstein File EFTA02261175: RICO and Construction (DS11)

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This document describes Atorus International Investment Management, LLC, with offices located in Dorado, Puerto Rico, and references Act 20/22 tax decrees and Puerto Rico domicile. The document identifies Bob Fowler as Head of Quantitative Research & Strategies and discusses portfolio construction strategy and investment management approaches.

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Currently we have our offices in Dorado Puerto **Rico**, where we obtained the favorable Act 20/22 tax decrees, hence the PR domicile.
Excerpt 2
Fowler Head of Quantitative Research & Strategies Atorus International Investment Management, LLC Dorado, Puerto **Rico** 00646 The information contained in
Excerpt 3
The idea is making, for now, the portfolio **construction** unintelligent by design. More dispersion will lead to even lower vol then currently.

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