Contract analysis

I. PURPOSE This memorandum sets forth our recommendations for enhancements to the sanctions compliance program of Dunmore Energy Holdings Ltd. ("DEH") and its wholly owned subsidiary, Dunmore Trading International Ltd. ("DTI"), a private company limited by shares registered in England and Wales (Companies House No. 12849371), with its registered address at 25 Finsbury Square, London EC2A 1PQ, United Kingdom. These re

II. BACKGROUND The Caspian Star Counterparty Relationship Caspian Star Commodities DMCC was onboarded as a DTI counterparty on July 8, 2021, by DTI's London-based compliance team, with support from Ashworth & Kline LLP (10 Aldermanbury, London EC2V 7HR, United Kingdom), DTI's then-outside trade compliance counsel (Lead Partner: Nigel Ashworth). The onboarding was conducted in connection with DTI's anticipated purchas

III. RECOMMENDATIONS We set forth below six categories of recommended compliance enhancements, each designed to address one or more of the root causes identified in our investigation and to strengthen DEH's and DTI's sanctions compliance posture on a going-forward basis. For each recommendation, we identify the specific deficiency it addresses, the proposed implementation approach, and the target completion date. A.

IV. IMPLEMENTATION SUMMARY The following table summarizes the six categories of recommendations, their target completion dates, and their status as of the date of this memorandum:

V. IMPLEMENTATION TRACKING To ensure the timely and effective execution of these recommendations, we recommend the following implementation tracking procedures: We recommend that Derek Huang, as DEH's Chief Compliance Officer, maintain a master implementation tracker documenting the status of each recommendation, key milestones, responsible persons, and any deviations from the target completion dates set forth herein

VI. CONCLUSION The compliance enhancement measures outlined in this memorandum are specifically designed to address the root causes and contributing factors that led to the apparent violations involving the five LSFO sale transactions between DTI and Caspian Star Commodities DMCC. The transactions at issue represent an aggregate value of $4,726,500 across Invoices CS-DTI-0091 through CS-DTI-0115, executed between Sep