Sam Bankman-Fried (SBF), the founder of FTX and Alameda Research, has reportedly come under legal scrutiny for comments made in 2018 that promised investors “no risk” returns.

According to reports, the trading firm, which assisted SBF’s now-bankrupt FTX Group in creating liquidity, was delivering slide decks to potential investors in 2018 that included offers for loans with “no downside” and high returns with “no risk.”

According to the report, the 2018 Alameda deck included investment opportunities with a 15% annualized fixed rate loan, as well as higher rates for investors willing to put down more with the firm.

According to the deck:

“These loans have no downside — we guarantee full payment the principal and interest, enforceable under U.S. law and established by all parties’ legal counsel. We are extremely confident we will pay this amount. In the unlikely case where we lose more than 2% over a month we will give all investors the opportunity to recall their funds.”

Tyler Gellasch, president and CEO of the nonprofit market integrity organization Healthy Markets, stated that Alameda’s claim could raise “major legal red flags.”

He pointed out that entrepreneurs seeking investors are required to disclose risk, and that the language in the slide deck was “bound to give rise to criminal and civil investigations.”

SBF, who stepped down as CEO of FTX on November 11 following the exchange’s Chapter 11 bankruptcy filing, bemoaned the language of the 2018 investor pitch.