Contract analysis

I. Executive Summary The purpose of this memorandum is to provide a comprehensive analysis of the trading activity of Natasha Sorokin, former Senior Trader at Dunmore Trading International Ltd. ("DTI"), the Dubai-based trading subsidiary of Dunmore Energy Holdings Ltd. ("DEH" or "Dunmore"), and to summarize the results of our review of her personal communications relevant to the investigation being conducted in conne

II. Background on Natasha Sorokin A. Employment History and Role at DTI Natasha Sorokin served as a Senior Trader at Dunmore Trading International Ltd., the principal commodity trading subsidiary of Dunmore Energy Holdings Ltd. DTI is based at Level 14, Gate Building 3, Dubai International Financial Centre, P.O. Box 506774, Dubai, United Arab Emirates, and holds Dubai International Financial Centre License No. CL-482

III. Trading Activity Analysis A. Overview of Sorokin's Trading Book During the period of conduct at issue — approximately March 2020 through April 2022 — Natasha Sorokin managed DTI's largest crude oil trading book focused on Russian-origin and Caspian-basin crude oil. Sorokin's trading book encompassed both physical and financial crude oil trades, including swaps, forward contracts, and spot transactions, with a co

IV. Personal Communications Review A. Scope of Communications Reviewed The personal communications review for Natasha Sorokin encompassed materials from the following four sources: (i) DTI Corporate Email Account (Strathmore Data Systems): Sorokin's corporate email account on DTI's Strathmore Data Systems email server, which was preserved pursuant to the litigation hold notice issued on April 20, 2022, and from which

V. Payment Flow Analysis Relevant to Sorokin The payment flow analysis conducted by Ridgeline Advisory Group LLC under the direction of Dr. Margaret Liu has identified a pattern of payments routed through intermediary accounts at Crescent Commercial Bank PJSC, Dubai, that were structured to obscure the ultimate beneficial ownership of the recipient entities and, specifically, to conceal the flow of funds to and from

VI. Applicable Legal Framework (Summary) This section provides a brief summary of the legal framework applicable to Sorokin's conduct. A comprehensive analysis of the applicable sanctions and export control frameworks is set forth in Conrad Reeves's Memorandum re: Applicable Sanctions Framework — OFAC Programs, E.O. 14024, Directive 2, dated April 27, 2022. OFAC-Administered Sanctions Programs. The primary sanctions

VII. Assessment of Sorokin's Culpability A. Factors Suggesting Knowledge and Intent The following factors, considered in their totality, support the conclusion that Sorokin possessed the knowledge and intent necessary to establish willful violation of the IEEPA-enforced sanctions prohibitions:

1. Pre-Existing Personal Relationship with Sergei Volkov. Sorokin's personal relationship with Volkov predated her employment at DTI. This long-standing relationship provided Sorokin with familiarity with Volkov's business activities and connections, including his relationship with Volkhov Industrial Group. The pre-existing relationship also suggests that Sorokin's decision to bring the Petronova trading relationship

2. Encrypted Messaging Content. The recovered encrypted messaging communications constitute the strongest evidence of Sorokin's knowledge and intent. The messages contain direct discussions of Volkhov connections, references to "Arkady" (Arkady Volkhov), and explicit discussions of structuring trades and payments to avoid compliance detection. This evidence, if credited, would establish that Sorokin knowingly partici

3. Sole Point of Contact for Volkov. Sorokin served as the sole DTI point of contact for Sergei Volkov on all 9 tainted transactions. This exclusive relationship gave Sorokin unique access to information about Petronova's operations and its connections to Volkhov, and it ensured that no other DTI personnel would independently develop knowledge of those connections through direct contact with Volkov.

4. Payment Routing Instructions. Sorokin provided specific instructions to Controller Rajesh Malhotra regarding payment routing for Petronova trades through intermediary accounts at Crescent Commercial Bank, and she communicated directly with the bank's relationship manager regarding account details. These actions go beyond the normal responsibilities of a trader and indicate active involvement in the payment structu

5. Deletion of Encrypted Messages. Sorokin deleted encrypted messages from her personal mobile device prior to surrendering the device pursuant to the litigation hold notice. The timing of the deletion — approximately two days after being placed on administrative leave — strongly suggests consciousness of guilt and an effort to destroy incriminating evidence.

6. Language Skills and Market Expertise. Sorokin's status as a Russian-American dual national, fluent in Russian and with extensive experience in Russian commodity markets, suggests a level of familiarity with Russian industrial entities — including Volkhov Industrial Group — that would make ignorance of the Volkhov connection implausible. B. Factors Potentially Mitigating Culpability The following factors may, to so

1. Supervision and Authorization by Derek Hargrave. Sorokin operated under Derek Hargrave's supervision and authorization. Hargrave, as P