Epstein File EFTA01354646: Memorandum and RICO (DS10)

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💨IMPACT LEVEL 1 — MEH

Epstein File EFTA01354646: Memorandum and RICO (DS10)

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This memorandum addresses restrictions on transferability of interests under a partnership agreement and references a settlement involving Raymond James with multiple jurisdictions including Puerto Rico, the Virgin Islands, and the District of Columbia regarding allegations of failure to supervise. The document discusses both fund structure and regulatory enforcement actions.

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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