A 2011 memo made public Wednesday by Wikileaks revealed new details of how former President Bill Clinton made tens of millions of dollars for himself and his wife, then Secretary of State Hillary Clinton, through an opaque, ethically messy amalgam of philanthropic, business and personal activities.

The memo was written by Bill Clinton’s longtime aide, Doug Band, and is among tens of thousands of emails apparently stolen from Hillary Clinton’s campaign chief, John Podesta, in what U.S. officials believe is part of a massive Russian-backed attempt to disrupt the U.S. election.

The Band memo came in response to an investigation undertaken by a law firm, Simpson Thatcher, into the activities of the Clinton Foundation at the behest of its board. The board was concerned that some of the activities undertaken by Band and others on behalf of the President could threaten the Foundation’s IRS status as a charity, according to Band’s memo. Chelsea Clinton had also reported concerns to Podesta and other Clinton advisors that Band and his recently-launched consulting firm, Teneo, were using her father’s name without his knowledge to contact British lawmakers for clients, including Dow Chemical.

In the 12-page memo, Band describes how he and several colleagues spent much of the years after Bill Clinton’s presidency working to fund the Clinton Foundation, which has raised nearly $2 billion from individuals, corporations and governments for charities focusing on climate change, economic development, health, women and girls issues and other causes. Band claims in the memo that from 2006 to 2011, he and a colleague, Justin Cooper, raised $46 million for the Foundation through the Clinton Global Initiative, an annual networking conference that is one of the Foundation’s big sources of income.

But the Foundation work was just a part of what Bill Clinton did during his wife’s time as a Senator and Secretary of State, and it wasn’t always clear where the former president’s non-profit activities ended and his for-profit ones began. Five months before he wrote the memo, Band joined forces with a recently retired State Department envoy, Declan Kelly, to form Teneo, which Band said provided merchant and investment banking services, corporate restructuring, public relations and communications services and strategic advising services to 20 clients, including Coca-Cola, Dow Chemical, UBS, Barclays and BHP Billiton, among others. Over that period, Band says in the memo, Teneo raised $8 million for the Clinton Foundation.

And Band was also organizing personal income directly for Clinton. Under the heading, “For-Profit Activity of President Clinton (i.e. Bill Clinton, Inc.),” Band wrote, “We have dedicated our selves to helping the President secure and engage in for-profit activities—including speeches, books, and advisory service engagements… In support of the President’s for-profit activity, we also have solicited and obtained, as appropriate, in-kind services for the President and his family—for personal travel, hospitality, vacation and the like. Neither Justin nor I are separately compensated for these activities (e.g., we do not receive a fee for, or percentage of, the more than $50 million in for-profit activity we have personally helped to secure for President Clinton to date or the $66 million in future contracts, should he choose to continue with those engagements).”

Band mentions four such “arrangements” without naming them. Bill Clinton was paid nearly $18 million to be “honorary chancellor” of a for-profit college, Laureate International Universities, according to reports and the family’s tax returns. A Dubai-based firm, GEMS Education, paid Bill Clinton more than $560,000 in 2015, according to the tax returns. Band also lists a variety of speaking fees, previously disclosed by the Clintons, including hundreds of thousands of dollars each from UBS, Ericsson, BHP and Barclays. In 2011 alone, according to the Clinton’s tax returns, Bill Clinton earned $13,454,000 in speaking fees.

No evidence has been found to support allegations of a quid pro quo of official acts by Hillary Clinton as senator or Secretary of State in exchange for the money received by the Clintons or the Clinton Foundation. However the messiness and opacity of the relationship between Clinton’s personal, business and philanthropic undertakings detailed in the memo raises new questions about Bill Clinton’s activity. In the email to which Band’s draft memo was attached, Band tells Podesta he has removed the “lasry section all together.” Marc Lasry is a hedge fund manager and Clinton donor who funded an unsuccessful investment vehicle launched by Chelsea Clinton’s husband Marc Mezvinsky.

Other questions arise in the penultimate paragraph of the memo, entitled “Other Matters.” Without providing details, Band writes that since the end of Bill Clinton’s presidency he and Cooper had served as the primary contact and point of management for President Clinton’s activities, including political, business and Foundation matters, speeches, books, and family/personal needs, including “securing in-kind private airplane travel, in-kind vacation stays, and supporting family business and personal needs.”

Calls and emails to Band, Teneo and the Clinton Foundation were not immediately returned. The Hillary Clinton campaign declined to confirm that the memo, or other emails released by Wikileaks, are in fact undoctored documents stolen from Podesta’s personal email account. However a campaign spokesperson, Glen Caplin, tweeted on Wednesday that Wikileaks was advancing a “clear political agenda” by “dribbling out” Podesta’s emails. “If Podesta dump was about high-minded transparency @wikileaks would release all at once,” Carlin tweeted.

Podesta has said he is cooperating with the FBI in an investigation of the hack. The Clinton Foundation has said it will stop accepting foreign and corporate donations if Hillary Clinton is elected president.