Contract analysis

I. Executive Summary The purpose of this memorandum is to analyze the beneficial ownership structure of Petronova Trading FZE ("Petronova"), a Dubai-based commodity trading company registered as a Free Zone Establishment with the Jebel Ali Free Zone Authority ("JAFZA"). Petronova is managed by Sergei Volkov, a Russian national and current UAE resident. This memorandum assesses Petronova's ties to Volkhov Industrial G

II. Background A. The DOJ Inquiry and Dunmore's Trading Desk On April 19, 2022, the Department of Justice National Security Division, through its Counterintelligence and Export Control Section ("CES"), opened a formal inquiry into Dunmore Energy Holdings Ltd. concerning potential violations of U.S. sanctions laws administered by the Office of Foreign Assets Control ("OFAC") and export control regulations. The inquiry

III. Sources Reviewed In preparing this memorandum, I have reviewed the following sources of information, documents, and data:

1. Corporate Registry Filings: Jebel Ali Free Zone Authority (JAFZA) corporate registry filings for Petronova Trading FZE, including the entity's certificate of registration, memorandum of association, and shareholder declaration forms, obtained through local counsel, Al-Farooq & Partners, in Dubai, UAE.

2. UAE Ministry of Economy Records: UAE Ministry of Economy commercial license records and associated filings for Petronova Trading FZE, to the extent publicly available and obtainable through local counsel inquiries.

3. Petronova Organizational Documents: Petronova's JAFZA trade license and memorandum of association on file with the Jebel Ali Free Zone Authority, including amendments and renewals.

4. Russian Corporate Registry Extracts: Extracts from the EGRUL (Unified State Register of Legal Entities) for Volkhov Industrial Group JSC, Volkhov Energy Trading LLC, Volkhov Consulting Services LLC, and related entities in the VIG corporate family, obtained through Russian corporate registry search services.

5. DTI Counterparty Due Diligence Files: Dunmore Trading International Ltd.'s internal counterparty due diligence files for Petronova Trading FZE, collected from DTI's Dubai offices during the initial document preservation and collection process.

6. KYC Documentation: DTI's Know-Your-Customer ("KYC") documentation on file for Petronova Trading FZE, including passport copies of Sergei Volkov, the entity questionnaire completed at the time of onboarding, and any related compliance screening records.

7. Banking Records: Wire transfer records and payment instructions involving Petronova Trading FZE at Crescent Commercial Bank PJSC, Dubai, UAE. The banking relationship was managed by Khalid Mansour, a relationship manager at the bank. These records were obtained pursuant to DTI's banking relationship with Crescent Commercial Bank and Mr. Mansour's cooperation with document requests made through local counsel.

8. Email and Electronic Communications: Email and other electronic communications between Natasha Sorokin (Senior Trader, DTI) and Sergei Volkov (Managing Director, Petronova), as well as communications involving other relevant individuals, recovered and processed through the document review platform managed by Nexagen Analytics Inc. (Project No. NX-DEH-2204). These materials were collected from DTI's email servers a

9. Interview Memoranda: Memoranda memorializing the following witness interviews conducted by members of the Calderwood & Harkness investigation team: • Omar Al-Rashidi, Head of Middle East Operations, DTI — interviewed June 14, 2022; • Natasha Sorokin, Senior Trader, DTI — interviewed June 2, 2022; and • Derek Hargrave, President, DTI — interviewed May 25, 2022.

10. Forensic Financial Analysis: Preliminary forensic tracing results prepared by Ridgeline Advisory Group LLC, under the direction of Dr. Margaret Liu, CPA, CFE, Engagement No. RAG-2022-0319. Ridgeline was retained by Calderwood & Harkness LLP to conduct forensic financial analysis and tracing of fund flows associated with the suspect transactions, including an analysis of payments flowing through Petronova's accoun

11. Open-Source intelligence (OSINT): Research conducted by the Calderwood & Harkness investigation team utilizing publicly available corporate registries, press reports (including Russian-language trade publications and news outlets), commercial sanctions databases, and beneficial ownership databases.

12. OFAC SDN List and SSI List: OFAC Specially Designated Nationals and blocked Persons List entries and related identifying information for Volkhov Industrial Group JSC, Arkady Volkhov, and associated persons and entities, as published by OFAC and updated through the date of this memorandum.

IV. Beneficial Ownership Analysis A. Petronova's Formal Corporate Structure Under its JAFZA registration, Petronova Trading FZE is structured as a single-shareholder Free Zone Establishment ("FZE"). The FZE is a common legal form in the UAE's free zone jurisdictions, designed to permit a single natural or legal person to own 100% of a commercial enterprise within the free zone without the requirement of a local UAE n

1. Familial and Personal Connections Open-source research conducted by the Calderwood & Harkness investigation team has revealed that "Sergei Volkov" appears to be a name variant or closely associated party of individuals within the broader Volkhov family network. While the surname "Volkov" differs from "Volkhov," the similarity is notable, and variations and abbreviations of Russian surnames are not uncommon in tran

2. Financial Connections The financial evidence constitutes one of the most significant categories of proof linking Petronova to Volkhov Industrial Group JSC. Ridgeline Advisory Group LLC's preliminary forensic analysis, conducted under the direction of Dr. Margaret Liu, CPA, CFE, has traced fund flows demonstrating a pattern of payments received by Petronova from DTI being subsequently transferred to accounts at ban

3. Operational Connections Beyond the financial linkages, the investigation has uncovered evidence of operational integration between Petronova and Volkhov Industrial Group JSC that further supports the conclusion that Petronova functions as a VIG-controlled entity rather than an independent commercial enterprise. DTI internal emails recovered during the Nexagen Analytics e-discovery review reveal that trade confirma

4. KYC Deficiencies at DTI The investigation has also identified material deficiencies in DTI's Know-Your-Customer ("KYC") documentation for Petronova Trading FZE, which contributed to DTI's failure to identify the Volkhov beneficial ownership connection prior to the commencement of the DOJ inquiry. DTI's KYC file on Petronova was materially deficient. The file contained only the following items: (i) a copy of Sergei

1. Legal Framework Under OFAC's Revised Guidance on Entities Owned by Persons Whose Property and Interests in Property are blocked, published on August 13, 2014 (the "50% Rule Guidance"), any entity that is owned, directly or indirectly, 50 percent or more in the aggregate by one or more blocked persons is itself considered a blocked person, regardless of whether the entity itself appears on the SDN List. The 50% Rul

2. Application to Petronova The application of the 50% Rule to Petronova Trading FZE depends on the determination of whether Volkhov Industrial Group JSC (and/or Arkady Volkhov, if individually designated) beneficially owns Petronova at or above the 50% threshold, and on the applicable sanctions regime in effect at the relevant time. Post–April 6, 2022 (SDN Designation): If Volkhov Industrial Group JSC (or Arkady Vol

3. Assessment of Ownership Percentage The formal JAFZA records identify Sergei Volkov as the 100% registered owner and sole shareholder of Petronova Trading FZE. However, OFAC's 50% Rule is not limited to formal, registered ownership. OFAC's guidance and enforcement practice make clear that the 50% Rule looks through nominees, agents, and front persons to identify the actual beneficial owner of an entity. Where an in

V. Implications for Dunmore's Transactions A. Crude Oil Swap Transactions DTI executed fourteen crude oil swap transactions between June 2020 and February 2022, with an aggregate notional value of approximately $218.7 million, with Petronova Trading FZE and Zenith Petroleum DMCC serving as counterparties. These transactions involved the exchange of crude oil price risk, with physical delivery components in certain in

VI. Relationship Between Petronova and Zenith Petroleum DMCC This memorandum focuses primarily on Petronova Trading FZE. However, the investigation has produced preliminary findings suggesting that a second Dubai-based entity, Zenith Petroleum DMCC, was also involved in a subset of the flagged crude oil swap transactions with DTI and may have connections to the Volkhov network. Zenith Petroleum DMCC is registered at

VII. Knowledge and Involvement of DTI Personnel The investigation has identified three DTI employees whose knowledge and involvement in the suspect transactions are of particular significance to the DOJ inquiry: Natasha Sorokin, Senior Trader, DTI. Ms. Sorokin served as DTI's primary point of contact with Sergei Volkov and Petronova Trading FZE. She was responsible for originating, negotiating, and executing crude oi

VIII. Recommendations A. Further Investigative Steps Based on the analysis set forth in this memorandum, I recommend the following additional investigative steps to strengthen the factual record and refine the beneficial ownership analysis:

1. Formal UBO Declarations: Obtain formal ultimate beneficial ownership declarations from JAFZA to the extent available under UAE law, potentially through the cooperation of Al-Farooq & Partners (local counsel in Dubai). While JAFZA's disclosure requirements were limited during the relevant period, recent amendments to UAE beneficial ownership regulations may provide additional avenues for obtaining ownership informa

2. Complete Forensic Tracing: Request that Ridgeline Advisory Group LLC complete the full forensic tracing of all funds flowing from Petronova Trading FZE to VIG-affiliated entities, including the identification and analysis of all intermediary accounts and entities in the payment chain. The final forensic report from Ridgeline is expected by approximately April 1, 2023. In the interim, we should request periodic upd

3. Additional Russian Corporate Registry Extracts: Obtain additional Russian corporate registry (EGRUL) extracts for any entities in the Volkhov/Volkov ownership chain that have not yet been fully documented, including any entities identified through Ridgeline's forensic tracing as intermediaries in the payment flows from Petronova. This may require engagement of Russian corporate search services or, if available, co

4. Cross-Reference with Export Control Analysis: Cross-reference the findings of this beneficial ownership analysis with the separate export control analysis being conducted in connection with the oilfield equipment export activities involving Caspian Logistik GmbH (a German-registered logistics company), to determine whether Petronova or Volkov had any involvement in the equipment facilitation transactions under rev

5. Continued E-discovery Review: Continue the review of DTI electronic communications for further evidence of VIG control over Petronova's commercial decisions. The Nexagen Analytics technology-assisted review ("TAR") of the DTI document collection is ongoing. As of the date of this memorandum, 2,347,812 documents have been collected from custodian accounts and DTI servers, and the review is in progress. Priority sho

IX. Appendices (Referenced) The following appendices are referenced in and support the analysis contained in this memorandum. Appendices are maintained separately and are available upon request from the investigation team file maintained by Calderwood & Harkness LLP. Appendix A: Petronova Trading FZE — JAFZA Registration Documents (excerpts), including certificate of registration, memorandum of association, and share