The bounded finding
The emails document real sanctions-structuring work, not merely a name in an address book. They also document only an exploratory private proposal. The eventual Treasury delisting used a separately documented restructuring, and no displayed record connects Epstein's proposal to that outcome.5
How Deripaska entered the thread
On May 4, Jide Zeitlin thanked Epstein for his thoughts concerning Deripaska. Epstein forwarded that message to Steve Bannon with the note “keeping you in the loop.”1
What that proves—and does not
It proves Bannon received this Deripaska-referencing message. The located forward does not prove Bannon received every later technical proposal or participated in designing it.
The proposed structure
Epstein proposed full divestiture paired with an economic interest and an option to buy back after five years if sanctions were lifted. He wrote that Treasury would need to approve the initial transaction and that loss of control might provide Treasury comfort.2
Zeitlin replied that a full divestiture might be required but worried that an option could make him appear to be a “strawman,” legally or politically. Epstein then considered a trust swap, an option, company debt, and ADR equivalents, and suggested a meeting with the appropriate Treasury division.23
The high-water mark
On May 11, Zeitlin reported a “good lunch” in Zug concerning a sanctions solution and said interest was piqued.4 That establishes an exploratory meeting and interest. The email does not identify every participant, show a mandate from Deripaska, or record contact with Treasury.
The deal that actually happened
On January 27, 2019, Treasury removed En+, Rusal, and EuroSibEnergo from the sanctions list after they reduced Deripaska's ownership, severed his control, changed board governance, and accepted continuing auditing and reporting. Treasury kept Deripaska himself sanctioned.5
Some concepts overlap at a high level—reduced ownership and control—but resemblance is not causation. The public Treasury account does not credit Epstein or Zeitlin, and the displayed emails do not show their proposal entering the official process.
Deripaska was the named subject; Epstein proposed specific structures; Zeitlin raised strawman risk; a Zug lunch generated interest; Bannon received the initial Deripaska-referencing message.
Not establishedThat Bannon received the complete later chain, that Deripaska authorized or received the proposal, that Treasury considered it, that it violated sanctions law, or that it caused the actual delisting.
Receipts 001–005
The proposal and the separate outcome
Claim map
What each record carries
- Receipt 001
- The May 4 Deripaska reference and Epstein's decision to send that message to Bannon.
- Receipts 002–003
- Epstein's proposed structure, Zeitlin's stated concern, and the financial instruments under consideration.
- Receipt 004
- The later Zug lunch and reported interest, without identifying the interested party.
- Receipt 005
- The terms and date of the actual Treasury delisting.
- Not established
- Transmission to Deripaska or Treasury, illegality, execution, causation, or Bannon's receipt of the full later chain.
Last updated: August 23, 2026.