The document discusses regulatory compliance and anti-money laundering measures for investors in the Access Fund managed by Glendower GP. It outlines the requirements for investors to verify their source of funds and comply with OFAC regulations. The document also addresses the non-applicability of the AIFM Directive to the General Partner and Investment Manager, and ERISA considerations for U.S. pension plans investing in the Access Fund.
doj/DataSet10/EFTA01393326.pdf
{"document_type":"correspondence","key_locations":["European Economic Area"],"document_subtype":"memorandum","key_organizations":["Aspen Grove Capital, LLC","Glendower GP","Access Fund","U.S. Treasury Department's Office of Foreign Assets Control"],"reference_numbers":["DB-SDNY-0098843","SDNY_GM_00245027","EFTA01393326"]}