Contract analysis

I. SUMMARY OF APPARENT VIOLATIONS Between September 12, 2022 and January 23, 2023, DTI, a physical commodities trading subsidiary of DEH, executed five (5) fuel oil sale transactions involving low-sulfur fuel oil ("LSFO"), 380 CST grade, with Caspian Star Commodities DMCC ("Caspian Star"), a company organized under the laws of the Dubai Multi Commodities Centre ("DMCC") in the United Arab Emirates. The aggregate tran

II. PARTIES A. Reporting Parties Dunmore Energy Holdings Ltd. ("DEH") DEH is an exempted company limited by shares organized under the laws of the Cayman Islands. DEH's registered address is 4th Floor, Harbour Place, 103 South Church Street, George Town, Grand Cayman KY1-1002, Cayman Islands. DEH holds a U.S. Employer Identification Number (EIN: 98-1347562) and maintains its principal U.S. office at 1200 Travis Stree

III. DETAILED NARRATIVE OF FACTS A. Counterparty Onboarding Caspian Star was first onboarded as a counterparty of DTI on July 8, 2021. The onboarding process was conducted in accordance with DTI's then-applicable counterparty due diligence procedures and included both KYC verification and sanctions screening. The KYC review and sanctions screening were performed between July 8 and July 12, 2021 by DTI's London-based

1. Timing Gap in Public Information: A gap of approximately 14 months existed between Mr. Kadyrov's designation as an SDN (March 18, 2022) and OFAC's public identification of Caspian Star as an entity owned or controlled by Mr. Kadyrov through the SDN List supplemental update (May 12, 2023). During this 14-month period, no publicly available source — including the SDN List, the DMCC corporate registry, or widely used

2. Screening Platform Data Limitations: The HCS ScreenPro beneficial ownership data feed, which DTI relied upon for automated counterparty screening, did not incorporate the Kadyrov-Caspian Star ownership link at any point prior to OFAC's May 2023 supplemental update. The platform's beneficial ownership module relied on data sourced from public corporate registries and commercial data providers, which reflected Mr. M

3. Delayed Re-Screening Cycle: The annual re-screening of Caspian Star, which was scheduled for completion by July 8, 2022 under DTI's Compliance Policy, was not completed until October 2022 due to compliance staffing shortages. While this delay constituted a departure from DTI's internal policy, the delayed re-screening would not have yielded a different result even if conducted on time. The sanctions risk associate

IV. MITIGATING FACTORS DEH and DTI respectfully submit that the following mitigating factors are relevant to OFAC's evaluation of the appropriate enforcement response in this matter, consistent with the factors set forth in OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. Part 501, Appendix A:

1. Voluntary Self-Disclosure. This disclosure is made voluntarily pursuant to 31 C.F.R. § 501.806 and prior to any indication that OFAC has independently identified the subject transactions or initiated any inquiry, investigation, or enforcement action with respect thereto. DEH is submitting this VSD of its own volition and before receiving any request for information, administrative subpoena, or other governmental i

2. No Actual Knowledge. Neither DEH nor DTI had actual knowledge of Mr. Kadyrov's beneficial ownership of Caspian Star at the time of the subject transactions. The ownership link between Mr. Kadyrov and Caspian Star was concealed through a network of nominee shareholders and was not reflected in Caspian Star's corporate records, in the DMCC registry, or in widely available commercial databases. The Kadyrov-Caspian St

3. Inadvertent Conduct. The five transactions at issue were routine physical commodity trades in low-sulfur fuel oil executed in the ordinary course of DTI's business operations. There is no evidence, and no reason to believe, that any officer, director, employee, or agent of DEH or DTI intended to evade or circumvent U.S. sanctions. There are no indicia of willful sanctions evasion, including no evidence of efforts

4. Prompt Remediation. Upon discovering the Kadyrov-Caspian Star ownership link on June 2, 2023, DTI acted swiftly and decisively. Within three business days — on June 5, 2023 — DTI blocked Caspian Star as a counterparty in all trading and compliance systems and froze all pending transactions. At the time of the block, no transactions were pending, as the last transaction had been completed on January 23, 2023. No fu

5. No Direct Benefit to SDN. All payments for the subject transactions were made to Caspian Star's corporate account at Emirates Gulf Commercial Bank in Dubai, UAE. No evidence has been identified during the internal investigation indicating that Mr. Kadyrov personally received, directed, or benefited from the funds paid by DTI in connection with these transactions. While DEH acknowledges that Caspian Star, as an ent

6. Existing Compliance Program. At the time of the subject transactions, DEH and DTI maintained a sanctions compliance program that included the following elements: (a) automated sanctions screening of counterparties using the HCS ScreenPro platform; (b) annual re-screening of all active counterparties against applicable sanctions lists; (c) designated compliance personnel, including Chief Compliance Officer Derek Hu

7. Comprehensive Remedial Enhancements. Since the discovery of the apparent violations, DEH has implemented significant and comprehensive remedial measures to strengthen its sanctions compliance program and to prevent the recurrence of similar violations. These measures include: (a) Upgraded Screening Platform: DTI has upgraded to HCS ScreenPro Version 5.0, which includes an enhanced beneficial ownership screening mo

8. Full Cooperation. DEH and DTI are committed to cooperating fully and transparently with OFAC's review of this matter. DEH and DTI will promptly produce all relevant documentation responsive to any request from OFAC and will respond promptly to any supplemental information requests. DEH and DTI will make their officers, employees, and agents available for interviews as OFAC may require, and will provide any additio

V. SUPPORTING DOCUMENTATION The following supporting documentation is enclosed with this voluntary self-disclosure as appendices: Appendix A: DTI Counterparty Onboarding File for Caspian Star Commodities DMCC (July 2021), including the KYC questionnaire completed by Caspian Star, corporate registry extracts from the DMCC, copies of Mr. Mammadov's UAE resident visa, two trade references from unrelated commodities trad

VI. CONCLUSION DEH and DTI deeply regret these apparent violations and take seriously their obligations under the sanctions programs administered by OFAC. The apparent violations were inadvertent and resulted from circumstances in which the beneficial ownership link between a designated SDN and a DTI counterparty was not publicly discoverable through the screening tools and data sources reasonably available to DTI du