From: "jeffrey E." <I

From: "jeffrey E." <I To: Jide Zeldin <1 Subject: Re: Date: Sat, 12 May 2018 00:33:12 +0000 No surprise On Fri, May 11, 2018 at 7:34 PM Jide Zeitlin < > wrote: Good lunch today in Zug re sanctions solution. Interest piqued. On May 5, 2018, at 7:28 PM, jeffrey E. <1 > wrote: understood. not sure if the co is sanctioned.? i have tried to research for you sanctions and the case law. not much. . if you had a meeting with the appropriate division of treasury, im sure you can structure around it.. trust swap. option, . for ex can a financial institution trade in the debt of the co.? public debt , private debt. ? are adr equivalents covered. . etc On Sat, May 5, 2018 at 1:55 PM Jide Zeitlin < > wrote: Yes. Just hung up with our mutual friend having discussed this topic. He agrees with your view that a full divestiture may be required. The challenge is structuring the option in such away that it does not make me appear to be a strawman-- legally or simply in terms of political perception given the mid-terms. On May 5, 2018, at 13:44, jeffrey E. < > wrote: https://www.rferl.org/a/us-treasury-provides-way-three-russian-com anies-gaz-rusal-en-plus-avoid-us- sanctions-mnuchin/29203690.html he divests of all. take a note interest to mirror return minus . option to buy back in 5 years if sanctions have been lifted . otherwise 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. please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA01060906 please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved please note The information contained in this communication is confidential, may be attorney-client privileged, may constitute inside information, and is intended only for the use of the addressee. It is the property of JEE Unauthorized use, disclosure or copying of this communication or any part thereof is strictly prohibited and may be unlawful. If you have received this communication in error, please notify us immediately by return e-mail or by e-mail to and destroy this communication and all copies thereof, including all attachments. copyright -all rights reserved EFTA01060907