<table><tr><th>From:</th><th>jeffrey E. &lt;jeevacation@gmail.com&gt;</th></tr><tr><td>Sent:</td><td>Saturday, May 5, 2018 6:28 PM</td></tr><tr><td>To:</td><td>Jide Zeitlin</td></tr><tr><td>Subject:</td><td>Re:</td></tr></table>

understood. not sure if the co is sanctioned.?=C2* i have tried to research for you sanctions and the case law.=C24> not much. . if you had a meeting with the appropri=te division of treasury, im sure you can structure around it. = trust swap. option, . for ex can a fi=ancial institution trade in the debt of the co.? public debt ,=private debt. ? are adr equivalents covered. . etc </=iv>

On Sat, May 5, 2018 at =:55 PM Jide Zeitlin <████████ <mailto:████████> > 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. <jeevacation@gmail.com <mailto:jeevacation@gmai=.com> > wrote:

https://www.rferl.org/a/us-treasury-provides-way-three-rus=ian-companies-gaz-rusal-en-plus-avoid-us-sanctions-mnuchin/29203690.html</>=>

<https://www.rferl.org/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.

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=C2

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