Contract analysis

I. EXECUTIVE SUMMARY This memorandum analyzes the role of Yves Leclerc, Director of Logistics & Shipping at Dunmore Trading International Ltd. ("DTI"), a wholly owned subsidiary of Dunmore Energy Holdings Ltd. ("Dunmore" or the "Company"), in facilitating oilfield equipment shipments valued at approximately $12.4 million to end users in Russia via Caspian Logistik GmbH ("Caspian Logistik"), a German-registered logist

II. BACKGROUND ON YVES LECLERC A. Professional History and Role at DTI Yves Leclerc is a French national who has been employed by DTI since approximately 2016. He holds the title of Director of Logistics & Shipping and is based at DTI's principal office in Dubai, UAE (Level 14, Gate Building 3, Dubai International Financial Centre, P.O. Box 506774, Dubai, UAE). Prior to joining DTI, Leclerc accumulated experience in

III. THE OILFIELD EQUIPMENT EXPORT TRANSACTIONS A. Overview of Shipments Between August 2020 and January 2022, DTI facilitated the export of oilfield drilling equipment and components with an aggregate value of approximately $12.4 million. The equipment at issue includes drilling components, downhole tools, measurement instrumentation, and related spare parts used in upstream oil and gas exploration and production op

IV. LECLERC'S ROLE — DOCUMENT REVIEW FINDINGS A. Email and Communication Evidence As part of the internal investigation, Calderwood & Harkness oversaw the collection and processing of Leclerc's email custodial files from DTI's systems in Dubai. Leclerc was among the custodians identified in the preservation notice and data collection protocol. His email data was collected, processed, and hosted by Nexagen Analytics I

V. LECLERC'S WITNESS INTERVIEWS A. First Interview — June 22, 2022 The first interview of Yves Leclerc was conducted on June 22, 2022, by Amara Osei at Calderwood & Harkness's London office, located at 30 St Mary Axe, 12th Floor, London EC3A 8BF. Prior to the commencement of substantive questioning, Leclerc was administered the firm's standard Upjohn corporate Miranda warning, in accordance with the Witness Interview

VI. ASSESSMENT OF LECLERC'S KNOWLEDGE AND CULPABILITY A. Knowledge of Sanctions and Export Controls The assessment of Leclerc's knowledge of applicable sanctions and export control requirements is central to determining his potential legal exposure. Several factors are relevant to this analysis. First, Leclerc is a French national with no formal training in U.S. sanctions law, U.S. export control law, or the specific

VII. POTENTIAL LEGAL EXPOSURE A. Export Control Violations (EAR) The shipments of oilfield equipment classified under ECCN 2B350 and ECCN 2B999 to end users in Russia potentially violated EAR § 746.5, which, during the relevant period, imposed license requirements for the export, reexport, and transfer of specified items to Russia and Belarus, including items classified under the relevant ECCNs. A detailed analysis o

VIII. RECOMMENDATIONS A. Continued Cooperation Based on the assessment set forth in this memorandum, we recommend that Leclerc remain available for further interviews if requested by DOJ or OFAC. Any such request should be coordinated through Calderwood & Harkness. If OFAC Compliance Analyst Erin Matsuda or any other government representative contacts Leclerc directly, Leclerc should be instructed to refer the inquir