WALLWALL #78
Sam Ikkurty
Posted April 12, 2026
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
COMMODITY FUTURES TRADING
COMMISSION
Plaintiff
v.
JAFIA LLC, SAM IKKURTY A/K/A
SREENIVAS I RAO, AND
RAVISHANKAR AVADHANAM,
Defendants,
IKKURTY CAPITAL, LLC D/B/A ROSE
CITY INCOME FUND I, ROSE CITY
INCOME FUND II LP, SENECA
VENTURES, LLC,
Relief Defendants.
Case No. 1:22-cv-02465
Expert Report
of Charles R. Soha, CFE
Respectfully submitted this 25th day of July 2023
/s/_______________________________________________________________
NORTHERN DISTRICT OF ILLINOIS
COMMODITY FUTURES TRADING
COMMISSION
Plaintiff
v.
JAFIA LLC, SAM IKKURTY A/K/A
SREENIVAS I RAO, AND
RAVISHANKAR AVADHANAM,
Defendants,
IKKURTY CAPITAL, LLC D/B/A ROSE
CITY INCOME FUND I, ROSE CITY
INCOME FUND II LP, SENECA
VENTURES, LLC,
Relief Defendants.
Case No. 1:22-cv-02465
Expert Report
of Charles R. Soha, CFE
Respectfully submitted this 25th day of July 2023
/s/_______________________________________________________________
I. INTRODUCTION
1. I, Charles Soha, am a Managing Director at StoneTurn Group, LLP (“StoneTurn”).
StoneTurn is a global advisory firm that assists companies, their counsel and government agencies
on regulatory, risk and compliance issues, investigations, and business disputes.
2. I am a Certified Fraud Examiner, a credential which I have held in good standing since
2008. I have 16 years of experience in combined data analysis, risk assurance, and dispute
consulting experience. Prior to joining StoneTurn, I was a Vice President of Data Analytics at
State Street Bank and Trust (“State Street”) for 4 years. Prior to State Street, I worked at Deloitte
LLP (“Deloitte”) for approximately 10 years as a data analytics specialist.
3. At StoneTurn, State Street, and Deloitte, I assisted a large range of clients including large
multinational companies and privately held enterprises. I have led numerous matters in the
investment management industry. My work has entailed damage calculations, incident response,
and conducting flow of funds analyses. Attachment A to this report contains my curriculum vitae
(“CV”), which provides additional details about my experience and qualifications.
II. BACKGROUND
4. On May 10, 2022, the Commodity Futures Trading Commission (“CFTC”) filed a
complaint against Sam Ikkurty, Jafia LLC, Ravishankar Avadhanam, Ikkurty Captial LLC, Rose
City Income Fund II LP, and Seneca Ventures LLC (Defendants and Relief Defendants,
collectively, the “Defendants”) alleging, among other things, that the Defendants offered
investment products to private individuals that offered no returns. The CFTC’s allegation appears
to be based on Defendants’ bank statements not showing any cash inflows from crypto-asset
exchange entities: “In fact, the Rose City and Seneca Ventures' bank accounts reveal that the funds
never generated any returns”.1 The complaint also alleges that Defendants withdrew investor funds
that far exceeded any expected management fees: “Finally, Defendants lkkurty and Avadhanam
paid themselves in excess of the 2% management fee represented in the Agreement. Two percent
1 Doc 9 - MEMORANDUM of law by Commodity Futures Trading Commission in support of motion for ex parte
statutory.PDF (Case: 1:22-cv-02465 Document #: 9 Filed: 05/10/22 Page 21 of 33 PageID #:65)
1. I, Charles Soha, am a Managing Director at StoneTurn Group, LLP (“StoneTurn”).
StoneTurn is a global advisory firm that assists companies, their counsel and government agencies
on regulatory, risk and compliance issues, investigations, and business disputes.
2. I am a Certified Fraud Examiner, a credential which I have held in good standing since
2008. I have 16 years of experience in combined data analysis, risk assurance, and dispute
consulting experience. Prior to joining StoneTurn, I was a Vice President of Data Analytics at
State Street Bank and Trust (“State Street”) for 4 years. Prior to State Street, I worked at Deloitte
LLP (“Deloitte”) for approximately 10 years as a data analytics specialist.
3. At StoneTurn, State Street, and Deloitte, I assisted a large range of clients including large
multinational companies and privately held enterprises. I have led numerous matters in the
investment management industry. My work has entailed damage calculations, incident response,
and conducting flow of funds analyses. Attachment A to this report contains my curriculum vitae
(“CV”), which provides additional details about my experience and qualifications.
II. BACKGROUND
4. On May 10, 2022, the Commodity Futures Trading Commission (“CFTC”) filed a
complaint against Sam Ikkurty, Jafia LLC, Ravishankar Avadhanam, Ikkurty Captial LLC, Rose
City Income Fund II LP, and Seneca Ventures LLC (Defendants and Relief Defendants,
collectively, the “Defendants”) alleging, among other things, that the Defendants offered
investment products to private individuals that offered no returns. The CFTC’s allegation appears
to be based on Defendants’ bank statements not showing any cash inflows from crypto-asset
exchange entities: “In fact, the Rose City and Seneca Ventures' bank accounts reveal that the funds
never generated any returns”.1 The complaint also alleges that Defendants withdrew investor funds
that far exceeded any expected management fees: “Finally, Defendants lkkurty and Avadhanam
paid themselves in excess of the 2% management fee represented in the Agreement. Two percent
1 Doc 9 - MEMORANDUM of law by Commodity Futures Trading Commission in support of motion for ex parte
statutory.PDF (Case: 1:22-cv-02465 Document #: 9 Filed: 05/10/22 Page 21 of 33 PageID #:65)
of $44 million is $880,000, however, Defendants Ikkurty and Avadhanam transferred tens of
millions of dollars into accounts they own and control”.2 Shortly after filing the complaint, a Court-
appointed Receiver froze and took possession of substantially all of Defendants’ cash assets.
5. Jafia, LLC (“Jafia”) was established in 2006 by Sam Ikkurty to serve as the General Partner
of Rose City Income Fund (a/k/a Ikkurty Capital) and Rose City Income Fund II. Seneca Ventures
was established in 2021 by Sam Ikkurty to collect smaller individual investments and pool them
into a single investor account, held by Seneca Ventures, in Rose City Income Fund II. In Fund I,
investors generally sent funds to accounts held by Ikkurty Capital LLC, which then purchased
crypto-assets from Coinbase. In Fund II, larger investors generally sent money directly to Rose
City Income Fund, and smaller investors sent funds to Seneca Ventures. Seneca Ventures then
transferred funds to Rose City Income Fund II. Fund II in turn purchased crypto-assets from Genie
Technologies.
6. In late 2021, Jafia LLC began purchasing Fund I positions from its investors. Certain
investors received cash payments from Jafia in exchange for their investments. Other investors
elected to receive a note from Jafia in the form of either a crypto savings note, or a carbon offset
bond, for the value of their Fund I investment. Generally, these notes offered 15% annual interest
on the principal value paid monthly over a term of 3 to 4 years, with the principal value of the note
payable to the noteholder in 2024 or 2025. Jafia also sold crypto savings notes and carbon offset
bonds directly to investors.
III. ENGAGEMENT
7. In May 2022, StoneTurn was retained by Seward & Kissel LLP (“Seward & Kissel”) and
Sam Ikkurty, Jafia LLC, Ikkurty Capital, LLC d/b/a Rose City Income Fund I, Rose City Income
Fund II LP, and Seneca Ventures, LLC in connection with a review of the flow of funds related to
this litigation matter. Our3 work entailed assisting their efforts to comply with the Court’s order,
2 Doc 9 - MEMORANDUM of law by Commodity Futures Trading Commission in support of motion for ex parte
statutory.PDF (Case: 1:22-cv-02465 Document #: 9 Filed: 05/10/22 Page 21 of 33 PageID #:65)
3 As used herein, other than references to my education and experience, “I” and “We” shall mean either I
personally or StoneTurn personnel under my supervision. Also, “My”, “Our”, and “Us” shall also refer to
actions taken by me personally or by StoneTurn personnel working under my supervision.
millions of dollars into accounts they own and control”.2 Shortly after filing the complaint, a Court-
appointed Receiver froze and took possession of substantially all of Defendants’ cash assets.
5. Jafia, LLC (“Jafia”) was established in 2006 by Sam Ikkurty to serve as the General Partner
of Rose City Income Fund (a/k/a Ikkurty Capital) and Rose City Income Fund II. Seneca Ventures
was established in 2021 by Sam Ikkurty to collect smaller individual investments and pool them
into a single investor account, held by Seneca Ventures, in Rose City Income Fund II. In Fund I,
investors generally sent funds to accounts held by Ikkurty Capital LLC, which then purchased
crypto-assets from Coinbase. In Fund II, larger investors generally sent money directly to Rose
City Income Fund, and smaller investors sent funds to Seneca Ventures. Seneca Ventures then
transferred funds to Rose City Income Fund II. Fund II in turn purchased crypto-assets from Genie
Technologies.
6. In late 2021, Jafia LLC began purchasing Fund I positions from its investors. Certain
investors received cash payments from Jafia in exchange for their investments. Other investors
elected to receive a note from Jafia in the form of either a crypto savings note, or a carbon offset
bond, for the value of their Fund I investment. Generally, these notes offered 15% annual interest
on the principal value paid monthly over a term of 3 to 4 years, with the principal value of the note
payable to the noteholder in 2024 or 2025. Jafia also sold crypto savings notes and carbon offset
bonds directly to investors.
III. ENGAGEMENT
7. In May 2022, StoneTurn was retained by Seward & Kissel LLP (“Seward & Kissel”) and
Sam Ikkurty, Jafia LLC, Ikkurty Capital, LLC d/b/a Rose City Income Fund I, Rose City Income
Fund II LP, and Seneca Ventures, LLC in connection with a review of the flow of funds related to
this litigation matter. Our3 work entailed assisting their efforts to comply with the Court’s order,
2 Doc 9 - MEMORANDUM of law by Commodity Futures Trading Commission in support of motion for ex parte
statutory.PDF (Case: 1:22-cv-02465 Document #: 9 Filed: 05/10/22 Page 21 of 33 PageID #:65)
3 As used herein, other than references to my education and experience, “I” and “We” shall mean either I
personally or StoneTurn personnel under my supervision. Also, “My”, “Our”, and “Us” shall also refer to
actions taken by me personally or by StoneTurn personnel working under my supervision.
which mandates the Defendants to provide the Receiver “with a full detailed accounting of all
funds, records, and assets, including the assets inside and outside of the United States that are held
by each Defendant and Relief Defendant, for their benefit, or under their direct or indirect control,
whether jointly or singly.”
8. In June 2023, StoneTurn was engaged by Norton Rose Fulbright LLP (“Norton Rose”),
who assumed representation of Defendants, and continued its flow of funds analysis related to this
litigation matter.
9. StoneTurn is being compensated for my time at an hourly rate of $525. StoneTurn is being
compensated at hourly rates between $195 to $650 for other team members. These rates apply
throughout the engagement, including testimony, if any. StoneTurn’s fees are not contingent on
the outcome of this matter.
10. This report summarizes my current findings given the information available to date. I may
consider any additional materials, if produced, and modify or supplement this analysis as
necessary.
IV. INFORMATION CONSIDERED AND RELATED ASSUMPTIONS
11. I considered documents from a variety of sources during my work, as represented in
Attachment B. This includes various financial data and other information provided by Seward &
Kissel, financial information provided by the court-appointed Receiver, and other information
provided by Norton Rose.
12. I made the following assumptions while conducting my analysis:
a. The listing of bank accounts disclosed in Ikkurty’s declaration, Receiver frozen
asset list, and discussions with counsel is complete;
b. Any bank statements received were complete and accurate; and
funds, records, and assets, including the assets inside and outside of the United States that are held
by each Defendant and Relief Defendant, for their benefit, or under their direct or indirect control,
whether jointly or singly.”
8. In June 2023, StoneTurn was engaged by Norton Rose Fulbright LLP (“Norton Rose”),
who assumed representation of Defendants, and continued its flow of funds analysis related to this
litigation matter.
9. StoneTurn is being compensated for my time at an hourly rate of $525. StoneTurn is being
compensated at hourly rates between $195 to $650 for other team members. These rates apply
throughout the engagement, including testimony, if any. StoneTurn’s fees are not contingent on
the outcome of this matter.
10. This report summarizes my current findings given the information available to date. I may
consider any additional materials, if produced, and modify or supplement this analysis as
necessary.
IV. INFORMATION CONSIDERED AND RELATED ASSUMPTIONS
11. I considered documents from a variety of sources during my work, as represented in
Attachment B. This includes various financial data and other information provided by Seward &
Kissel, financial information provided by the court-appointed Receiver, and other information
provided by Norton Rose.
12. I made the following assumptions while conducting my analysis:
a. The listing of bank accounts disclosed in Ikkurty’s declaration, Receiver frozen
asset list, and discussions with counsel is complete;
b. Any bank statements received were complete and accurate; and
c. The valuations of Fund I and Fund II assets as reported by the Fund I administrator,
Tower Fund Services, and the Fund II administrator, Intertrust Corporate Fund
Services are accurate.
V. PROCEDURES
13. In order to conduct the flow of funds analysis, StoneTurn gathered and analyzed various
financial records including bank statements, investor statements and memoranda, and other
financial information. Based on this information, we quantified the inflows and outflows of funds,
including but not limited to, investor contributions and receipts, intercompany transfers, transfers
to/from crypto currency exchanges, payments to vendors and other cash flow activity to assess the
movements of funds and remaining assets.
14. As part of our work, StoneTurn requested and received financial data from the Defendants,
counsel and other third parties, including, but not limited to, bank statements, investor statements
and other information. This information was essential to quantify and analyze the flow of funds
between various parties. In order to analyze the flow of funds, we extracted and analyzed
transaction details from 12 different bank accounts that had over 5,900 transactions noted in over
170 bank statements.
15. In addition, we reviewed and analyzed transactional information from over 2,900 investor
statements to understand the flow of funds. We then analyzed and identified the various sources
and recipients of funds, and classified these parties into categories, such as investors, vendors,
investments, or Defendant-controlled entities, to prepare a flow of funds analyses for counsel and,
ultimately, the court-appointed Receiver.
VI. SUMMARY OF EXPERT OPINION
16. I have the following observations based on the analysis described in the subsequent section
and attachments:
Tower Fund Services, and the Fund II administrator, Intertrust Corporate Fund
Services are accurate.
V. PROCEDURES
13. In order to conduct the flow of funds analysis, StoneTurn gathered and analyzed various
financial records including bank statements, investor statements and memoranda, and other
financial information. Based on this information, we quantified the inflows and outflows of funds,
including but not limited to, investor contributions and receipts, intercompany transfers, transfers
to/from crypto currency exchanges, payments to vendors and other cash flow activity to assess the
movements of funds and remaining assets.
14. As part of our work, StoneTurn requested and received financial data from the Defendants,
counsel and other third parties, including, but not limited to, bank statements, investor statements
and other information. This information was essential to quantify and analyze the flow of funds
between various parties. In order to analyze the flow of funds, we extracted and analyzed
transaction details from 12 different bank accounts that had over 5,900 transactions noted in over
170 bank statements.
15. In addition, we reviewed and analyzed transactional information from over 2,900 investor
statements to understand the flow of funds. We then analyzed and identified the various sources
and recipients of funds, and classified these parties into categories, such as investors, vendors,
investments, or Defendant-controlled entities, to prepare a flow of funds analyses for counsel and,
ultimately, the court-appointed Receiver.
VI. SUMMARY OF EXPERT OPINION
16. I have the following observations based on the analysis described in the subsequent section
and attachments:
a. Defendants collected $81.00M from investors and purchased $50.05M in
crypto investments; $30.94M of cash collected from investors was not
invested and retained by Defendants;
b. Investors paid Defendants $36.79M in performance and management fees;
c. Performance and management fees were only paid when investors achieved
new high-performance watermarks in their accounts. The fees did not
exceed the 20% of monthly gains specified in private placement memoranda
or limited partnership agreements;
d. Defendants were current on investor note liabilities up until assets were
frozen into Receivership;
VII. BASIS FOR EXPERT OPINION
Overall Results
17. I observed the $144.68M in cash inflows and $144.92M in cash outflows from Defendants’
accounts, summarized in the table below and within Attachment C. The difference between
calculated cash inflows and outflows is negligible, approximately 0.17%. This difference appears
related to small differences in the time periods for which StoneTurn received each set of
statements.
Entity Type Total Cash Inflows Total Cash Outflows
Investor $80,995,450.21 $(20,551,406.47)
Investment $352,902.00 $(50,054,324.36)
Defendant-Controlled $62,177,214.37 $(59,819,250.57)
Vendor $826,697.01 $(4,461,052.49)
Unknown $323,099.05 $(582,265.68)
Drawn Down by Receiver $- $(9,450,082.52)
Total $144,675,362.64 $(144,918,382.09)
crypto investments; $30.94M of cash collected from investors was not
invested and retained by Defendants;
b. Investors paid Defendants $36.79M in performance and management fees;
c. Performance and management fees were only paid when investors achieved
new high-performance watermarks in their accounts. The fees did not
exceed the 20% of monthly gains specified in private placement memoranda
or limited partnership agreements;
d. Defendants were current on investor note liabilities up until assets were
frozen into Receivership;
VII. BASIS FOR EXPERT OPINION
Overall Results
17. I observed the $144.68M in cash inflows and $144.92M in cash outflows from Defendants’
accounts, summarized in the table below and within Attachment C. The difference between
calculated cash inflows and outflows is negligible, approximately 0.17%. This difference appears
related to small differences in the time periods for which StoneTurn received each set of
statements.
Entity Type Total Cash Inflows Total Cash Outflows
Investor $80,995,450.21 $(20,551,406.47)
Investment $352,902.00 $(50,054,324.36)
Defendant-Controlled $62,177,214.37 $(59,819,250.57)
Vendor $826,697.01 $(4,461,052.49)
Unknown $323,099.05 $(582,265.68)
Drawn Down by Receiver $- $(9,450,082.52)
Total $144,675,362.64 $(144,918,382.09)
Investor Cash Flows
18. The Defendants received approximately $81.00M USD in funds from investors from
October 4, 2017 through May 10, 2022. From January 1, 2018 to May 16, 2022, the Defendants
transferred approximately $20.55M in funds to pay distributions to investors, to purchase certain
investors’ holdings when exiting Fund I, and to make interest payments on crypto-savings notes
and carbon-offset bond investments issued by Jafia.
Crypto-Asset Investment Cash Flows
19. From October 6, 2017, through April 15, 2022, the Defendants transferred approximately
$50.05M in funds to entities to purchase crypto-asset investments. There do not appear to be
significant cash inflows to Defendants from sources other than investor participants. I observed
cash inflows of approximately $352k from a cryptocurrency exchange to an account held by
Ikkurty Capital between January 26, 2018, and November 2, 2020.
Payments to Vendors
20. From January 2, 2018 through August 16, 2022, the Defendants paid vendors
approximately $4.46M, which primarily relates to bank fees, legal fees, fund administration costs,
and to pay Jafia LLC’s payroll vendors. A payment of $815,000 related to a real estate transaction
was returned to Jafia for a cancelled agreement.
Transfers between Defendant-Controlled Accounts
21. From January 29, 2018, through May 13, 2022, the Defendants transferred funds within
the accounts they controlled (i.e., inter-account transfers). During this period, the Defendants
deposited funds of $62.18M and withdrew fund of $59.82M within these controlled accounts.
These transfers primarily related to transfers of investor funds collected by Seneca Ventures into
18. The Defendants received approximately $81.00M USD in funds from investors from
October 4, 2017 through May 10, 2022. From January 1, 2018 to May 16, 2022, the Defendants
transferred approximately $20.55M in funds to pay distributions to investors, to purchase certain
investors’ holdings when exiting Fund I, and to make interest payments on crypto-savings notes
and carbon-offset bond investments issued by Jafia.
Crypto-Asset Investment Cash Flows
19. From October 6, 2017, through April 15, 2022, the Defendants transferred approximately
$50.05M in funds to entities to purchase crypto-asset investments. There do not appear to be
significant cash inflows to Defendants from sources other than investor participants. I observed
cash inflows of approximately $352k from a cryptocurrency exchange to an account held by
Ikkurty Capital between January 26, 2018, and November 2, 2020.
Payments to Vendors
20. From January 2, 2018 through August 16, 2022, the Defendants paid vendors
approximately $4.46M, which primarily relates to bank fees, legal fees, fund administration costs,
and to pay Jafia LLC’s payroll vendors. A payment of $815,000 related to a real estate transaction
was returned to Jafia for a cancelled agreement.
Transfers between Defendant-Controlled Accounts
21. From January 29, 2018, through May 13, 2022, the Defendants transferred funds within
the accounts they controlled (i.e., inter-account transfers). During this period, the Defendants
deposited funds of $62.18M and withdrew fund of $59.82M within these controlled accounts.
These transfers primarily related to transfers of investor funds collected by Seneca Ventures into
Fund II, and withdrawals for performance fees processed by Intertrust Corporate Services for Fund
II. A full breakdown is provided in Attachment D.
Other Cash Flows
22. Due to the lack of information noted on the bank statement information provided, I
classified approximately $582k in outgoing transfers and $323k in cash inflows as “Unknown” .
For these transactions, there we no wire memos with identifiable counterparties, check image
supporting detail, or deposit slip information. In addition, we noted that the court-appointed
Receiver withdrew approximately $9.45M of funds in August and September 2022.
Flow of Funds Analysis Summary
23. I calculated that $81.00M was collected from investors and $50.05M was used for
investments. It appears that the Defendants received and did not invest up to $30.94M of investor
funds. These funds appear to have been used to pay investors and vendors, purchase additional
fund assets into Jafia LLCs investment account, or hold in cash in the existing bank accounts. As
noted above, nearly all the remaining cash held has since been withdrawn by the court-appointed
Receiver.
Investors Statements – Management and Performance Fees
24. StoneTurn reviewed investor statements maintained and prepared by third party fund
administrators. This information was used to calculate management and performance fees paid to
Jafia by RCIF Fund I and II investors. The investor statements provided for Fund I or Fund II
reported management and performance fees separately. They are collectively reported as “fees” in
these investor statements. Based on my review of Fund I investor statements prepared by Tower
Fund Services, Jafia received $12.88M in performance fees from Fund I investors through March
of 2022. Based on my review of Fund II investor statements prepared by Intertrust Corporate Fund
II. A full breakdown is provided in Attachment D.
Other Cash Flows
22. Due to the lack of information noted on the bank statement information provided, I
classified approximately $582k in outgoing transfers and $323k in cash inflows as “Unknown” .
For these transactions, there we no wire memos with identifiable counterparties, check image
supporting detail, or deposit slip information. In addition, we noted that the court-appointed
Receiver withdrew approximately $9.45M of funds in August and September 2022.
Flow of Funds Analysis Summary
23. I calculated that $81.00M was collected from investors and $50.05M was used for
investments. It appears that the Defendants received and did not invest up to $30.94M of investor
funds. These funds appear to have been used to pay investors and vendors, purchase additional
fund assets into Jafia LLCs investment account, or hold in cash in the existing bank accounts. As
noted above, nearly all the remaining cash held has since been withdrawn by the court-appointed
Receiver.
Investors Statements – Management and Performance Fees
24. StoneTurn reviewed investor statements maintained and prepared by third party fund
administrators. This information was used to calculate management and performance fees paid to
Jafia by RCIF Fund I and II investors. The investor statements provided for Fund I or Fund II
reported management and performance fees separately. They are collectively reported as “fees” in
these investor statements. Based on my review of Fund I investor statements prepared by Tower
Fund Services, Jafia received $12.88M in performance fees from Fund I investors through March
of 2022. Based on my review of Fund II investor statements prepared by Intertrust Corporate Fund
Service, Jafia LLC received $23.91M in performance fees from Fund II investors through March
of 2022. See Attachment E for additional details. A total of $36.79M of fees, in the form of fund
assets were allocated from investor fund accounts to Jafia’s accounts through March of 2022.
Investors Statements – Performance Calculations
25. It appears that investors paid fees to Jafia from Fund I and Fund II only when there was an
overall positive fund performance. These performance fees never exceeded 20% of the total
monthly fund gains, which appears to be consistent with disclosures and private placement
memoranda provided to investors. Lastly, I noted that, for each investor account, a new high fund
performance watermark for the investor account was achieved in each period where fees were
withdrawn from an investor account pursuant to the relevant fund agreements. See Attachment E
for additional details.
Reported Fund Performance vs. Uninvested Investor Cash
26. I noted that the $36.79M in Attachment E which was investors paid to Jafia from Fund I
and Fund II exceeded the $30.94M of excess funds that were collected from investors and not used
to purchase crypto assets.
Use of Fees by Jafia
27. With regard to the $36.79M in fund assets allocated from investor accounts to Jafia, it
appears that approximately $25.9M (see Attachment D) was withdrawn from cash balances in
Fund I ($1.1M) and Fund II ($24.8M). These funds appear to have been used for Jafia’s payroll
and other vendors, buy-out positions from investors, purchase crypto assets, increase Jafia’s
position in Fund I, and to make interest payments to investors.
of 2022. See Attachment E for additional details. A total of $36.79M of fees, in the form of fund
assets were allocated from investor fund accounts to Jafia’s accounts through March of 2022.
Investors Statements – Performance Calculations
25. It appears that investors paid fees to Jafia from Fund I and Fund II only when there was an
overall positive fund performance. These performance fees never exceeded 20% of the total
monthly fund gains, which appears to be consistent with disclosures and private placement
memoranda provided to investors. Lastly, I noted that, for each investor account, a new high fund
performance watermark for the investor account was achieved in each period where fees were
withdrawn from an investor account pursuant to the relevant fund agreements. See Attachment E
for additional details.
Reported Fund Performance vs. Uninvested Investor Cash
26. I noted that the $36.79M in Attachment E which was investors paid to Jafia from Fund I
and Fund II exceeded the $30.94M of excess funds that were collected from investors and not used
to purchase crypto assets.
Use of Fees by Jafia
27. With regard to the $36.79M in fund assets allocated from investor accounts to Jafia, it
appears that approximately $25.9M (see Attachment D) was withdrawn from cash balances in
Fund I ($1.1M) and Fund II ($24.8M). These funds appear to have been used for Jafia’s payroll
and other vendors, buy-out positions from investors, purchase crypto assets, increase Jafia’s
position in Fund I, and to make interest payments to investors.
28. Sam Ikkurty provided a reconciliation of the performance fees withdrawn by Jafia from
September 2020 through January 2022, which represents $24.6M of the total performance fees
withdrawn. StoneTurn performed an independent reconciliation of this activity and had results
consistent with Ikkurty’s. See Attachment F for additional details.
Note Liabilities to Investors
29. StoneTurn calculated Jafia’s liabilities for crypto-savings notes or carbon off-set bonds
held by investors. See Attachment G for additional details.
30. Based on the schedule of note payments provided by Sam Ikkurty and other payments
identified in the respective investor statements, it appears that note liabilities were approximately
$480,000 per month. These liabilities were being paid in full from December 2021 through May
2022 when Defendants’ assets were frozen into Receivership.
VIII. CONCLUSION
31. Based upon my analysis discussed herein, it appears that any uninvested money collected
by Defendants that was used to pay vendors or other third-party investors was less than
management and performance fees that were collected from and disclosed to investors in their
monthly statements. Management and performance fees were only incurred when investor
accounts achieved new high watermarks in their account valuations. Defendants were current on
paying any investor note liabilities, up until the fund assets were frozen by the court-appointed
Receiver.
September 2020 through January 2022, which represents $24.6M of the total performance fees
withdrawn. StoneTurn performed an independent reconciliation of this activity and had results
consistent with Ikkurty’s. See Attachment F for additional details.
Note Liabilities to Investors
29. StoneTurn calculated Jafia’s liabilities for crypto-savings notes or carbon off-set bonds
held by investors. See Attachment G for additional details.
30. Based on the schedule of note payments provided by Sam Ikkurty and other payments
identified in the respective investor statements, it appears that note liabilities were approximately
$480,000 per month. These liabilities were being paid in full from December 2021 through May
2022 when Defendants’ assets were frozen into Receivership.
VIII. CONCLUSION
31. Based upon my analysis discussed herein, it appears that any uninvested money collected
by Defendants that was used to pay vendors or other third-party investors was less than
management and performance fees that were collected from and disclosed to investors in their
monthly statements. Management and performance fees were only incurred when investor
accounts achieved new high watermarks in their account valuations. Defendants were current on
paying any investor note liabilities, up until the fund assets were frozen by the court-appointed
Receiver.
ATTACHMENT A
StoneTurn.com
Chuck Soha, a Managing Director at StoneTurn, has over 16
years of professional experience in data analytics in a
multitude of risk, litigation/dispute, compliance, and
assurance engagements. He specializes in working with
organizations to build data-driven risk-monitoring solutions
into their various lines of defense. He also assists stakeholders
in building information management and business intelligence
solutions to manage investigations and disputes of any scale.
Prior to joining StoneTurn, Chuck developed the global data analytics team,
methodology, and training program within the internal audit department at a global
systemically important bank (GSIB) headquartered in Boston. He is well versed in the
challenges of integrating analytics and technology into risk, compliance, and audit
functions and provides a practical, tactical, and results-oriented framework for
successful implementation.
Earlier in his career, Chuck spent 10 years at Deloitte in various assurance and dispute
functions both within the US and abroad. He has helped numerous Investment
Management stakeholders and their counsel remediate large-scale incidents involving
the misappropriation of assets and damage computations. He has built digital solutions
to manage several class-action claims administration processes and assisted counsel in
substantiating various fraud and FCPA allegations by examining data. At the end of his
Deloitte tenure, he built out the Audit Analytics function in Deloitte’s Stockholm office.
Education
MS Business Analytics -
Kelley School of Business,
Indiana University
BA Mathematics – Williams
College
Practice Areas
Data Science & Analytics
Litigation Advisory
Compliance & Monitoring
Investigations
Chuck Soha
CFE, PMP
Managing Director
T: +1 617 570 3737
M: +1 413 652 4642
E: [email protected]
Boston
75 State Street
Suite 1710
Boston, MA 02109
Chuck Soha, a Managing Director at StoneTurn, has over 16
years of professional experience in data analytics in a
multitude of risk, litigation/dispute, compliance, and
assurance engagements. He specializes in working with
organizations to build data-driven risk-monitoring solutions
into their various lines of defense. He also assists stakeholders
in building information management and business intelligence
solutions to manage investigations and disputes of any scale.
Prior to joining StoneTurn, Chuck developed the global data analytics team,
methodology, and training program within the internal audit department at a global
systemically important bank (GSIB) headquartered in Boston. He is well versed in the
challenges of integrating analytics and technology into risk, compliance, and audit
functions and provides a practical, tactical, and results-oriented framework for
successful implementation.
Earlier in his career, Chuck spent 10 years at Deloitte in various assurance and dispute
functions both within the US and abroad. He has helped numerous Investment
Management stakeholders and their counsel remediate large-scale incidents involving
the misappropriation of assets and damage computations. He has built digital solutions
to manage several class-action claims administration processes and assisted counsel in
substantiating various fraud and FCPA allegations by examining data. At the end of his
Deloitte tenure, he built out the Audit Analytics function in Deloitte’s Stockholm office.
Education
MS Business Analytics -
Kelley School of Business,
Indiana University
BA Mathematics – Williams
College
Practice Areas
Data Science & Analytics
Litigation Advisory
Compliance & Monitoring
Investigations
Chuck Soha
CFE, PMP
Managing Director
T: +1 617 570 3737
M: +1 413 652 4642
E: [email protected]
Boston
75 State Street
Suite 1710
Boston, MA 02109
Chuck Soha, CFE, PMP Managing Director
StoneTurn.com
He has expertise in data profiling, statistical sampling, and combining data from both structured and unstructured data
sources to detect anomalies and provide business insights. An innovator by nature, he has experience with a wide variety
of both on-premises and cloud-based database, business intelligence, statistics, automation, and simulation technologies
to provide an optimal portfolio of solutions for his clients’ unique business problems.
Chuck holds Certified Fraud Examiner (CFE) and Project Management Professional (PMP) certifications, as well as a
professional certificate in Machine Learning and Artificial Intelligence from MIT. He holds a BA in Mathematics from
Williams College, and a MS in Business Analytics from the Kelley School of Business at Indiana University.
PREVIOUS EXPERIENCE
• State Street Bank & Trust (2017-2021)
• Deloitte LLP (2007-2017)
• K&L Gates (2005-2007)
SELECT PROFESSIONAL EXPERIENCE
• Investigated a potential fraud / check-kiting scheme whereby a small financial institution was accused of
allowing improper bank transfers to occur. Examined millions of bank records and performed forensic analysis to
identify sources and destination of funds and provided a deliverable to the client that allowed them to assess
control/information management gaps and get a better understanding of where certain large transaction flows
were going.
• Supported defense counsel in an SEC personal trading inquiry to investigate whether personal trading by an
investment manager coincided with business trades that individuals were executing on behalf of their firm’s
clients. Gathered thousands of trading records from brokerage statements and identified fact patterns to counsel
to better understand the merits of the SEC inquiry.
• Conducted fuzzy matches on entity names withing registers of hundreds of thousands of related party lists to
categorize and report on the relationships for public record filings. This work was performed for a privately held
investment management firm held by current and former partners of an M&A and restructuring firm, with the
goal of providing transparency around relationships with counterparties, vendors, and investments related to
entities for which the M&A firm conducted bankruptcy work.
• Analyzed hundreds of thousands of accounting records related to a restructuring of a conglomerate of hospitals
and other healthcare facilities in the Middle East. Analyzed historical insurance receivables to produce a fair
value of current receivables as part of the restructuring proceedings.
• Designed and delivered campaign finance contribution and expense forms on behalf of the monitor of a labor
union election campaign. Amalgamated data to provide reports highlighting statistics, categorizations, and
anomalies to facilitate a risk-based review of sample contributions and expenditures.
StoneTurn.com
He has expertise in data profiling, statistical sampling, and combining data from both structured and unstructured data
sources to detect anomalies and provide business insights. An innovator by nature, he has experience with a wide variety
of both on-premises and cloud-based database, business intelligence, statistics, automation, and simulation technologies
to provide an optimal portfolio of solutions for his clients’ unique business problems.
Chuck holds Certified Fraud Examiner (CFE) and Project Management Professional (PMP) certifications, as well as a
professional certificate in Machine Learning and Artificial Intelligence from MIT. He holds a BA in Mathematics from
Williams College, and a MS in Business Analytics from the Kelley School of Business at Indiana University.
PREVIOUS EXPERIENCE
• State Street Bank & Trust (2017-2021)
• Deloitte LLP (2007-2017)
• K&L Gates (2005-2007)
SELECT PROFESSIONAL EXPERIENCE
• Investigated a potential fraud / check-kiting scheme whereby a small financial institution was accused of
allowing improper bank transfers to occur. Examined millions of bank records and performed forensic analysis to
identify sources and destination of funds and provided a deliverable to the client that allowed them to assess
control/information management gaps and get a better understanding of where certain large transaction flows
were going.
• Supported defense counsel in an SEC personal trading inquiry to investigate whether personal trading by an
investment manager coincided with business trades that individuals were executing on behalf of their firm’s
clients. Gathered thousands of trading records from brokerage statements and identified fact patterns to counsel
to better understand the merits of the SEC inquiry.
• Conducted fuzzy matches on entity names withing registers of hundreds of thousands of related party lists to
categorize and report on the relationships for public record filings. This work was performed for a privately held
investment management firm held by current and former partners of an M&A and restructuring firm, with the
goal of providing transparency around relationships with counterparties, vendors, and investments related to
entities for which the M&A firm conducted bankruptcy work.
• Analyzed hundreds of thousands of accounting records related to a restructuring of a conglomerate of hospitals
and other healthcare facilities in the Middle East. Analyzed historical insurance receivables to produce a fair
value of current receivables as part of the restructuring proceedings.
• Designed and delivered campaign finance contribution and expense forms on behalf of the monitor of a labor
union election campaign. Amalgamated data to provide reports highlighting statistics, categorizations, and
anomalies to facilitate a risk-based review of sample contributions and expenditures.
ATTACHMENT B
DOCUMENTS AND INFORMATION CONSIDERED
In the performance of this engagement, I or my staff working under my direction have read certain
documents produced during the litigation. In addition to the materials utilized, my observations
are based upon my (1) education and training and (2) experience with situations of a similar nature.
The following information was considered in the development of this report:
1. The complaint and related exhibits;
2. Bank statements specified in Attachment C;
3. Investors statements produced by Tower Fund Services and Intertrust Corporate Services;
4. Private placement memoranda and limited partnership agreements for Fund I and Fund II
5. Declaration of accounts held by Sam Ikkurty;
6. Frozen Asset Schedule provided by court-appointed Receiver;7
7. Schedules of note payments provided by Sam Ikkurty;
8. Reconciliation of performance fees provided by Sam Ikkurty; and
9. Discussions with counsel and Sam Ikkurty.
In the performance of this engagement, I or my staff working under my direction have read certain
documents produced during the litigation. In addition to the materials utilized, my observations
are based upon my (1) education and training and (2) experience with situations of a similar nature.
The following information was considered in the development of this report:
1. The complaint and related exhibits;
2. Bank statements specified in Attachment C;
3. Investors statements produced by Tower Fund Services and Intertrust Corporate Services;
4. Private placement memoranda and limited partnership agreements for Fund I and Fund II
5. Declaration of accounts held by Sam Ikkurty;
6. Frozen Asset Schedule provided by court-appointed Receiver;7
7. Schedules of note payments provided by Sam Ikkurty;
8. Reconciliation of performance fees provided by Sam Ikkurty; and
9. Discussions with counsel and Sam Ikkurty.
ATTACHMENT C
ATTACHMENT D
Categorical Analysis of Transfers between Defendant-Controlled Accounts
Inflows Outflows
Inflows between same Defendant-
Controlled entity at different financial
institutions (e.g. Jafia at Umpqua to
Jafia at Silvergate)
$6,218,778.47
Outflows between same Defendant-
Controlled entity at different financial
institutions
$(7,298,926.30)
Inflows to Jafia from Fund I & II $25,918,167.24
Outflows to Jafia from Fund I & II $(25,708,703.50)
Inflows to Fund I from MySivana &
Jafia
$11,633,999.00
Outflows to Mysivana from Fund I $(321,151.38)
Inflows to Fund II from Seneca
Ventures
$16,483,304.77
Outflows to Fund II from Seneca
Ventures
$(16,822,011.08)
Inflows to Seneca Ventures from
Fund II & Jafia
$1,120,921.40
Outflows to Seneca Ventures from
Fund II and Jafia
$(1,305,880.10)
Inflows to Jafia, Fund I, Fund II, and
Seneca Ventures from Avadhanam
and S.Ikkurty
$802,043.49
Outflows to Avadhanam and
S.Ikkurty from Jafia, Fund I, and
Fund II, and Seneca Ventures
$(279,647.55)
Outflows - Jafia Pension Benefit
Transfers from Fund I and Jafia
$(232,930.66)
Outflows Jafia - Cash transfers to
Fund I
$(7,850,000.00)
Total $62,177,214.37 $(59,819,250.57)
Inflows Outflows
Inflows between same Defendant-
Controlled entity at different financial
institutions (e.g. Jafia at Umpqua to
Jafia at Silvergate)
$6,218,778.47
Outflows between same Defendant-
Controlled entity at different financial
institutions
$(7,298,926.30)
Inflows to Jafia from Fund I & II $25,918,167.24
Outflows to Jafia from Fund I & II $(25,708,703.50)
Inflows to Fund I from MySivana &
Jafia
$11,633,999.00
Outflows to Mysivana from Fund I $(321,151.38)
Inflows to Fund II from Seneca
Ventures
$16,483,304.77
Outflows to Fund II from Seneca
Ventures
$(16,822,011.08)
Inflows to Seneca Ventures from
Fund II & Jafia
$1,120,921.40
Outflows to Seneca Ventures from
Fund II and Jafia
$(1,305,880.10)
Inflows to Jafia, Fund I, Fund II, and
Seneca Ventures from Avadhanam
and S.Ikkurty
$802,043.49
Outflows to Avadhanam and
S.Ikkurty from Jafia, Fund I, and
Fund II, and Seneca Ventures
$(279,647.55)
Outflows - Jafia Pension Benefit
Transfers from Fund I and Jafia
$(232,930.66)
Outflows Jafia - Cash transfers to
Fund I
$(7,850,000.00)
Total $62,177,214.37 $(59,819,250.57)
ATTACHMENT E
Investor Statement
Period
Monthly Fund I
Gain/Loss - All
Investors Excluding
Jafia LLC Fund I Cumulative Gain/Loss
New Fund I
High
Watermark
Achieved
Monthly Fees
Charged to Fund
I Investors
Fees Charged to Investors
as a Percentage of
Monthly Fund Gain/Loss
202005 21,456.11$ 21,456.11$ Yes -$ 0%
202006 511,063.90$ 532,520.01$ Yes 54,542.71$ 11%
202007 1,290,086.63$ 1,822,606.64$ Yes 207,217.12$ 16%
202008 12,194,342.28$ 14,016,948.92$ Yes 2,445,992.21$ 20%
202009 (7,648,745.05)$ 6,368,203.87$ No -$ 0%
202010 (7,736,071.90)$ (1,367,868.03)$ No -$ 0%
202011 8,486,082.02$ 7,118,213.99$ No 280,656.89$ 3% 1
202012 (1,221,156.29)$ 5,897,057.70$ No -$ 0%
202101 15,031,096.68$ 20,928,154.38$ Yes 1,509,283.55$ 10%
202102 9,337,717.21$ 30,265,871.59$ Yes 1,454,276.71$ 16%
202103 (4,082,244.47)$ 26,183,627.12$ No -$ 0%
202104 3,124,375.94$ 29,308,003.06$ No 5,099.98$ 0.1% 1
202105 (11,161,171.35)$ 18,146,831.71$ No -$ 0%
202106 (8,471,455.17)$ 9,675,376.54$ No -$ 0%
202107 2,968,743.27$ 12,644,119.81$ No -$ 0%
202108 7,356,277.89$ 20,000,397.70$ No -$ 0%
202109 8,818,874.95$ 28,819,272.65$ No 35,432.39$ 0.4% 1
202110 34,558,379.49$ 63,377,652.14$ Yes 6,887,545.54$ 20%
202111 (411,296.69)$ 62,966,355.45$ No -$ 0%
202112 (18,242,077.17)$ 44,724,278.28$ No -$ 0%
202201 (15,276,809.39)$ 29,447,468.89$ No -$ 0%
202202 (241,712.23)$ 29,205,756.66$ No -$ 0%
202203 41,643.73$ 29,247,400.39$ No -$ 0%
Total 12,880,047.10$
Schedule of Fees Charged to Fund I Investors
1
Although performance fees were charged to investors during a period where a new high watermark was not achieved for the entire
fund, participants in fund I who entered after August 2021 achieved individual high watermarks, for which performance fees would
be expected. The same applies to investors who were charged a small amount of fees in other non-high watermark periods for the
same reason.
Period
Monthly Fund I
Gain/Loss - All
Investors Excluding
Jafia LLC Fund I Cumulative Gain/Loss
New Fund I
High
Watermark
Achieved
Monthly Fees
Charged to Fund
I Investors
Fees Charged to Investors
as a Percentage of
Monthly Fund Gain/Loss
202005 21,456.11$ 21,456.11$ Yes -$ 0%
202006 511,063.90$ 532,520.01$ Yes 54,542.71$ 11%
202007 1,290,086.63$ 1,822,606.64$ Yes 207,217.12$ 16%
202008 12,194,342.28$ 14,016,948.92$ Yes 2,445,992.21$ 20%
202009 (7,648,745.05)$ 6,368,203.87$ No -$ 0%
202010 (7,736,071.90)$ (1,367,868.03)$ No -$ 0%
202011 8,486,082.02$ 7,118,213.99$ No 280,656.89$ 3% 1
202012 (1,221,156.29)$ 5,897,057.70$ No -$ 0%
202101 15,031,096.68$ 20,928,154.38$ Yes 1,509,283.55$ 10%
202102 9,337,717.21$ 30,265,871.59$ Yes 1,454,276.71$ 16%
202103 (4,082,244.47)$ 26,183,627.12$ No -$ 0%
202104 3,124,375.94$ 29,308,003.06$ No 5,099.98$ 0.1% 1
202105 (11,161,171.35)$ 18,146,831.71$ No -$ 0%
202106 (8,471,455.17)$ 9,675,376.54$ No -$ 0%
202107 2,968,743.27$ 12,644,119.81$ No -$ 0%
202108 7,356,277.89$ 20,000,397.70$ No -$ 0%
202109 8,818,874.95$ 28,819,272.65$ No 35,432.39$ 0.4% 1
202110 34,558,379.49$ 63,377,652.14$ Yes 6,887,545.54$ 20%
202111 (411,296.69)$ 62,966,355.45$ No -$ 0%
202112 (18,242,077.17)$ 44,724,278.28$ No -$ 0%
202201 (15,276,809.39)$ 29,447,468.89$ No -$ 0%
202202 (241,712.23)$ 29,205,756.66$ No -$ 0%
202203 41,643.73$ 29,247,400.39$ No -$ 0%
Total 12,880,047.10$
Schedule of Fees Charged to Fund I Investors
1
Although performance fees were charged to investors during a period where a new high watermark was not achieved for the entire
fund, participants in fund I who entered after August 2021 achieved individual high watermarks, for which performance fees would
be expected. The same applies to investors who were charged a small amount of fees in other non-high watermark periods for the
same reason.
Investor Statement
Period
Monthly Fund II
Gain/Loss - All
Investors Excluding
Jafia LLC Fund II Cumulative Gain/Loss
New Fund II
High
Watermark
Achieved
Monthly Fees
Charged to Fund
II Investors
Fees Charged to Investors
as a Percentage of
Monthly Fund Gain/Loss
202101 (10,392.07)$ (10,392.07)$ No -$ 0%
202102 4,420,995.46$ 4,410,603.39$ Yes 882,120.67$ 20%
202103 (4,446,000.11)$ (35,396.72)$ No -$ 0%
202104 (866,703.69)$ (902,100.41)$ No -$ 0%
202105 (4,502,681.40)$ (5,404,781.81)$ No -$ 0%
202106 5,382,229.80$ (22,552.01)$ No 484,841.69$ 9% 1
202107 5,304,588.33$ 5,282,036.32$ Yes 625,820.12$ 12%
202108 5,690,557.77$ 10,972,594.09$ Yes 877,912.09$ 15%
202109 40,383,681.44$ 51,356,275.53$ Yes 7,532,690.78$ 19%
202110 60,043,990.86$ 111,400,266.39$ Yes 12,008,798.13$ 20%
202111 7,478,834.77$ 118,879,101.16$ Yes 1,495,766.97$ 20%
202112 (64,512,933.38)$ 54,366,167.78$ No -$ 0%
202201 (50,600,809.29)$ 3,765,358.49$ No -$ 0%
202202 (4,169,226.67)$ (403,868.18)$ No -$ 0%
Total 23,907,950.45$
1
Although performance fees were charged to investors during a period where a new high watermark was not achieved for the entire
fund, participants in fund II who entered after March 2021 achieved individual high watermarks, for which performance fees would
be expected
Schedule of Fees Charged to Fund II Investors
Period
Monthly Fund II
Gain/Loss - All
Investors Excluding
Jafia LLC Fund II Cumulative Gain/Loss
New Fund II
High
Watermark
Achieved
Monthly Fees
Charged to Fund
II Investors
Fees Charged to Investors
as a Percentage of
Monthly Fund Gain/Loss
202101 (10,392.07)$ (10,392.07)$ No -$ 0%
202102 4,420,995.46$ 4,410,603.39$ Yes 882,120.67$ 20%
202103 (4,446,000.11)$ (35,396.72)$ No -$ 0%
202104 (866,703.69)$ (902,100.41)$ No -$ 0%
202105 (4,502,681.40)$ (5,404,781.81)$ No -$ 0%
202106 5,382,229.80$ (22,552.01)$ No 484,841.69$ 9% 1
202107 5,304,588.33$ 5,282,036.32$ Yes 625,820.12$ 12%
202108 5,690,557.77$ 10,972,594.09$ Yes 877,912.09$ 15%
202109 40,383,681.44$ 51,356,275.53$ Yes 7,532,690.78$ 19%
202110 60,043,990.86$ 111,400,266.39$ Yes 12,008,798.13$ 20%
202111 7,478,834.77$ 118,879,101.16$ Yes 1,495,766.97$ 20%
202112 (64,512,933.38)$ 54,366,167.78$ No -$ 0%
202201 (50,600,809.29)$ 3,765,358.49$ No -$ 0%
202202 (4,169,226.67)$ (403,868.18)$ No -$ 0%
Total 23,907,950.45$
1
Although performance fees were charged to investors during a period where a new high watermark was not achieved for the entire
fund, participants in fund II who entered after March 2021 achieved individual high watermarks, for which performance fees would
be expected
Schedule of Fees Charged to Fund II Investors
ATTACHMENT F
Overview:
Transaction Classification - StoneTurn Ikkurty Reconciliation StoneTurn Bank Statement Review StoneTurn Comments
Deposits:
Performance Fees: $24.6M
Crypto Savings Note Deposits: $250k
Miscellaneous Credits: $13k
Total: $24.9M
$24.9M
Vendor Payments $2M $2.7M
The difference in vendor payments are to Clark County Title Company –
StoneTurn inquired about these through Seward & Kissel and were told these
were lease payments for office space for Jafia which were cancelled/returned –
the returned payment was sent to another Jafia account other than at Umpqua
Bank.
Purchase of additional Crypto Assets $8.65M $8.65M
Payments to Investors $3.71M $3.75M StoneTurn observed that most of these transfers were for buyout positions that
Jafia purchased from Fund I investors
Payments to Likely Investors $905k $1.1M
These appear to be small ACH transfers with unnamed counterparties but appear
to be consistent with scheduled crypto savings note interest payments as
indicated in the Ikkurty reconciliation
Transfers to Fund I (Equity Purchases) $5.9M $5.9M
Transfers to Other Jafia Accounts $2M $1.1M Differential largely related to Clark County Title payments returned to another
Jafia account.
On April 26, 2023 Sam Ikkurty provided a reconciliation of fees withdrawn from Fund II into Jafia LLCs bank account between September 2020 and January 2022. Stoneturn Independently reviewed
Ikkurty's reconciliation and noted the following results.
Transaction Classification - StoneTurn Ikkurty Reconciliation StoneTurn Bank Statement Review StoneTurn Comments
Deposits:
Performance Fees: $24.6M
Crypto Savings Note Deposits: $250k
Miscellaneous Credits: $13k
Total: $24.9M
$24.9M
Vendor Payments $2M $2.7M
The difference in vendor payments are to Clark County Title Company –
StoneTurn inquired about these through Seward & Kissel and were told these
were lease payments for office space for Jafia which were cancelled/returned –
the returned payment was sent to another Jafia account other than at Umpqua
Bank.
Purchase of additional Crypto Assets $8.65M $8.65M
Payments to Investors $3.71M $3.75M StoneTurn observed that most of these transfers were for buyout positions that
Jafia purchased from Fund I investors
Payments to Likely Investors $905k $1.1M
These appear to be small ACH transfers with unnamed counterparties but appear
to be consistent with scheduled crypto savings note interest payments as
indicated in the Ikkurty reconciliation
Transfers to Fund I (Equity Purchases) $5.9M $5.9M
Transfers to Other Jafia Accounts $2M $1.1M Differential largely related to Clark County Title payments returned to another
Jafia account.
On April 26, 2023 Sam Ikkurty provided a reconciliation of fees withdrawn from Fund II into Jafia LLCs bank account between September 2020 and January 2022. Stoneturn Independently reviewed
Ikkurty's reconciliation and noted the following results.
ATTACHMENT G
Period Total Note Liabilites Notes
2021-12 154,268.36$
2022-01 484,712.89$
2022-02 726,407.89$
2022-03 502,435.39$ Average Liabilities
2022-04 505,435.39$ 12/21-5/22
2022-05 506,935.39$ 480,032.55$
Schedule of Calculated Note Liabilities
2021-12 154,268.36$
2022-01 484,712.89$
2022-02 726,407.89$
2022-03 502,435.39$ Average Liabilities
2022-04 505,435.39$ 12/21-5/22
2022-05 506,935.39$ 480,032.55$
Schedule of Calculated Note Liabilities
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Posted2026-04-12T15:25:20.000Z
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