Contract analysis

I. Wire Transfer Details (Response to OFAC Request No. 1) OFAC's first request sought complete details regarding the five U.S. dollar-denominated wire transfers associated with the transactions reported in the VSD, including copies of all SWIFT messages, identification of all originating, intermediary, and receiving financial institutions, and confirmation of whether any U.S.-located financial institutions processed

II. Beneficial Ownership Diligence (Response to OFAC Request No. 2) OFAC's second request sought a detailed description of the beneficial ownership due diligence procedures that DTI applied to Caspian Star at the time of onboarding and at any subsequent review points, including an explanation of why those procedures did not identify Timur R. Kadyrov as a beneficial owner of Caspian Star. A. Overview Enclosed at Tab 2

III. Prior Transactions (Response to OFAC Request No. 3) OFAC's third request sought confirmation as to whether DEH, DTI, or any other DEH subsidiary had conducted any transactions with Caspian Star or any other entity associated with Timur R. Kadyrov outside of the five transactions reported in the VSD, and, if so, complete details regarding any such transactions. A. Certification Enclosed at Tab 3 is a signed certi

IV. Remedial Measures Update (Response to OFAC Request No. 4) OFAC's fourth request sought an update on the status of the remedial compliance measures referenced in Section IV.7 of the original VSD, together with supporting evidence of implementation. A. Overview Enclosed at Tab 4 is a detailed remediation status report addressing each compliance enhancement referenced in Section IV.7 of the original VSD. The remedia

V. Corporate Structure (Response to OFAC Request No. 5) OFAC's fifth request sought a current organizational chart for DEH showing all direct and indirect subsidiaries, together with information regarding which subsidiaries maintain accounts at U.S. financial institutions and whether any such subsidiaries conducted transactions with Caspian Star or any entity associated with Timur R. Kadyrov. A. Organizational Chart