EFTA00818037.pdf
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From: "Jeffrey E." <[email protected]>
To: Jide Zeitlin
Subject: Re:
Date: Sat, 05 May 2018 18:28:14 +0000
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. <jeevacation®gmail.com> wrote:
https://www.rferl.org/a/us-treasury-provides-way-three-russian-companies-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.
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EFTA00818037
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EFTA00818038
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EFTA00818037
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