From: jeffrey E. <[email protected]> Sent: Saturday, May 12, 2018 12:33 AM To: Jide Zeitlin Subject: Re: No surprise =div>On Fri, May 11, 2018 at 7:34 PM Jide Zeitlin < > wrote: Good lunch today in Zug re sanctions solution. Interest piqued. adiv> On May 5, 2018, at 7:28 PM, jeffrey E. <[email protected] <mailtoleevacation@gm=il.com» wrote: understood. not sure if the co is sanctioned.? =i have tried to research for you sanctions and the case law. n=t much. . if you had a meeting with the appropriate division o= treasury, im sure you can structure around it.. =rust swap. option, . for ex can a financial institution trade=in the debt of the co.? public debt , private debt. ? 40=A0 are adr equivalents covered. . etc On Sat, May 5, 2018 at 1:SS PM Jide Zeitlin < > wrote: Yes. Just hung up with our mutual friend having discussed this topic. =e agrees with your view that a full divestiture may be required. The challenge is structuring the option in such away that it does not =ake me appear to be a strawman--legally or simply in terms of political pe=ception given the mid-terms. On May 5, 2018, at 13:44, jeffrey E. <[email protected] <mailto:jeevacation@gmai=.com> > wrote: https://www.rferl.org/a/us-treasury-provides-way-three-rusrian-companies-gaz-rusal- en-plus-avoid-us-sanctions-mnuchin/29203690.html</=> chttps://www.rfertorg/a/us-treasury-provides-way-three-russ=an-companies-gaz-rusal- en-plus-avoid-us-sanctions-mnuchin/29203690.html> he divests of all. take a note interest to mirror return minus . opti=n to buy back in 5 years if sanctions have been lifted . other=ise another 3 then another 2... treasury would need to opine=on intial transaction. . the lack of control shoudl give treasury comfort. must not run afoul of financing rules. EFTA_R1_01921514 EFTA02669053