Contract analysis

I. Executive Summary The purpose of this memorandum is to analyze approximately $12.4 million in oilfield drilling equipment and components exported by Dunmore Trading International Ltd. ("DTI") through Caspian Logistik GmbH ("Caspian Logistik"), a Hamburg-registered logistics company, between approximately August 2020 and January 2022. Over this eighteen-month period, DTI facilitated seven discrete shipments of cont

II. Background A. Dunmore Trading International Ltd. — Overview Dunmore Trading International Ltd. ("DTI") is a limited company organized and registered under the laws of the Dubai International Financial Centre ("DIFC"), holding DIFC License No. CL-4827. DTI's principal office is located at Level 14, Gate Building 3, Dubai International Financial Centre, P.O. Box 506774, Dubai, United Arab Emirates. DTI was establis

III. Applicable Legal Framework A. Export Administration Regulations (EAR) The Export Administration Regulations, codified at 15 C.F.R. Parts 730–774, govern the export, re-export, and transfer (in-country) of dual-use items — that is, items that have both commercial and potential military or proliferation-related applications — from the United States, as well as items subject to U.S. jurisdiction that are located ou

IV. Scope of Equipment Exports A. Overview of Shipments Between August 2020 and January 2022, DTI facilitated the export of oilfield drilling equipment and components in seven discrete shipments with a total aggregate value of approximately $12.4 million. All seven shipments were routed through Caspian Logistik GmbH in Hamburg, which served as the logistics intermediary responsible for freight forwarding, consolidati

V. End-User Certificate Analysis A. Structure of the End-User Certifications Each of the seven identified shipments was accompanied by an end-user certificate ("EUC") purportedly signed by an authorized representative of the stated end user. The EUCs were presented to DTI as documentary evidence of the identity, location, and intended use of the equipment, and served as the primary — and, as discussed below, the esse

1. Unfamiliar or unverifiable end users with no prior commercial relationship. The three stated end users — "Central Asia Energy Services," "Caspian Drilling Solutions Ltd.," and "Ural Technical Supplies" — had no prior commercial relationship with DTI and did not appear in DTI's customer records before the first equipment shipment in August 2020. A compliance program with adequate customer onboarding procedures woul

2. End-user addresses that did not correspond to verifiable business premises. As discussed above, the address listed for "Central Asia Energy Services" corresponded to a shared commercial office space with no permanent occupant, and the address listed for "Caspian Drilling Solutions Ltd." did not match the registered address of the similarly named Azerbaijani entity. Basic due diligence — such as a corporate registr