FR EA

Contract analysis

Clause-by-clause risk read on any document of the firm. Pick a contract, or open any document from a matter.

Contract analysis / ofac-supplemental-request-annotated.docx
ofac-supplemental-request-annotated.docx
1016-00007 · 5 clauses
High · 0 Medium · 4 Standard · 1
1. Wire Transfer Details Standard
⚑ Commercial term
1. Wire Transfer Details For each of the five (5) U.S. dollar wire transfers referenced in the VSD — specifically, those payments processed through Ridgeline National Bank, N.A. in Houston, Texas, originating from the account of Caspian Star Commodities DMCC at Emirates Gulf Commercial Bank, Dubai, United Arab Emirates — please provide the following: (a) The complete SWIFT message (MT103 or equivalent) for each wire
2. Beneficial Ownership Diligence Medium
⚑ Liability cap to check against exposure
2. Beneficial Ownership Diligence Please provide a detailed description of DTI's beneficial ownership diligence procedures as they existed at the following two points in time: (a) As of the date of Caspian Star Commodities DMCC's initial onboarding as a counterparty of DTI (reported in the VSD as July 8, 2021); and (b) As of the date of the October 2022 re-screening of Caspian Star Commodities DMCC referenced in the
3. Prior and Subsequent Transactions Medium
⚑ Liability cap to check against exposure
3. Prior and Subsequent Transactions Please confirm whether DTI or any other direct or indirect subsidiary of DEH conducted any transactions — including but not limited to purchases, sales, brokerage arrangements, agency transactions, financing, or other commercial dealings — with Caspian Star Commodities DMCC or any other entity owned or controlled by, or otherwise associated with, Timur R. Kadyrov (SDN Entry ID 472
4. Remedial Measures Update Medium
⚑ Liability cap to check against exposure
4. Remedial Measures Update Please provide an update on the current status of the compliance enhancements described in Section IV.7 of the VSD. This update should include evidence of implementation of each measure referenced therein, including but not limited to the following: (a) Confirmation of the upgrade to DTI's sanctions screening tool, including the identity of the upgraded platform, the date of implementation
5. Corporate Structure Medium
⚑ Confidentiality undertaking
5. Corporate Structure Please provide a current organizational chart for DEH showing all direct and indirect subsidiaries of DEH, including DTI, with the jurisdiction of incorporation or organization for each entity. Within this organizational chart or in an accompanying schedule, please identify: (a) Any DEH subsidiary (direct or indirect) that engages in commodities trading, whether as a principal, agent, broker, o