Terrible spot to be in , but best thing to consider is "gifting" the shares via transfer to someone on the USA side with a brokerage account if it is possible. At worst, they'll be able to sell with a true capital gain recognition of the full price of the sale, and be taxed on it accordingly. The slight unfortunateness of this tactic is the "holder/seller" account will have these as a zero dollar cost basis.
Highly doubt a CTO is ever going to get lifted, the custodians are purely looking to get these companies fit to trade/merge on the USA side. Would be a terrible fate if this prints millions & those under CTO can only take a writeoff. JMHO, GLTA