Contract analysis

I. Executive Summary This memorandum presents the results of counterparty due diligence conducted on Zenith Petroleum DMCC ("Zenith Petroleum" or the "Company"), a Dubai-based petroleum trading company managed by Farhan Qureshi, a Pakistani national resident in the United Arab Emirates. The due diligence was undertaken as part of the broader internal investigation into potential sanctions violations by Dunmore Energy

II. Scope and Methodology A. Scope of Inquiry The due diligence inquiry focused on the following principal areas with respect to Zenith Petroleum:

1. Corporate structure and formation. Examination of Zenith Petroleum's legal formation, registered address, trade licensing, and organizational documents as filed with the Dubai Multi Commodities Centre ("DMCC").

2. Beneficial ownership. Identification and verification, to the extent possible, of the ultimate beneficial owner(s) of Zenith Petroleum, including an assessment of whether any beneficial ownership interest is held, directly or indirectly, by Volkhov Industrial Group JSC, Arkady Volkhov, Sergei Volkov, Petronova Trading FZE, or any other OFAC-designated person or entity.

3. Commercial activities. Review of Zenith Petroleum's principal lines of business, trading counterparties, geographical focus, and commodity trading patterns, with particular attention to any involvement in Russian-origin crude oil markets or trade flows involving the Commonwealth of Independent States ("CIS") region.

4. Relationships with Petronova Trading FZE, Volkhov Industrial Group JSC, and affiliated entities. Investigation of any direct or indirect commercial, financial, or personal relationships between Zenith Petroleum (or its principal, Farhan Qureshi) and Petronova Trading FZE (managed by Sergei Volkov, a Russian national and UAE resident), Volkhov Industrial Group JSC (chaired by Arkady Volkhov), or any other OFAC-desi

5. OFAC screening. Screening of Zenith Petroleum and its known personnel against the OFAC SDN List, the Sectoral Sanctions Identifications ("SSI") List, and the Consolidated Screening List, as well as other relevant sanctions and export control lists. The temporal scope of the inquiry covers the period from January 1, 2019 to the present date. This timeframe is consistent with the scope established by grand jury subp

1. DMCC Corporate Registry Filings. Corporate registration records and trade license records for Zenith Petroleum DMCC as maintained by the DMCC. The registered address reflected in these filings is Unit 2201, Jumeirah Bay Tower X2, Cluster X, Jumeirah Lakes Towers, Dubai, UAE.

2. OFAC and Sanctions Databases. The OFAC SDN List, the SSI List, and the Consolidated Screening List were searched as of the date of this memorandum (July 5, 2022). Additional screening was conducted against the European Union Consolidated List of Sanctions, the United Kingdom's Office of Financial Sanctions Implementation ("OFSI") Consolidated List, and the United Nations Security Council Sanctions Lists.

3. Open-Source intelligence (OSINT). The investigation team conducted open-source research utilizing corporate databases (including Bureau van Dijk's Orbis database, Dunmore Enterprises, and the UAE Ministry of Economy commercial registry), media reports, shipping and cargo tracking databases (including Halcyon Health IT and Ridgeway Technologies), and commercial registries in the UAE, Pakistan, and the Russian Feder

4. DTI Custodian Documents. Documents produced from the files and electronic devices of the following DTI data custodians were reviewed for information relevant to Zenith Petroleum: • Derek Hargrave, President, DTI (placed on administrative leave effective July 1, 2022); • Natasha Sorokin, Senior Trader, DTI (placed on administrative leave effective May 16, 2022); • Omar Al-Rashidi, Head of Middle East Operations, DT

5. Banking Records. Payment records obtained from Crescent Commercial Bank PJSC ("Crescent Bank"), Dubai, including wire transfer confirmations, account statements, and correspondence with the bank's relationship manager, Khalid Mansour. These records were obtained through Dunmore's existing banking relationship with Crescent Bank and pursuant to voluntary cooperation by the bank.

6. Ridgeline Advisory Group LLC — Preliminary Forensic Tracing. Preliminary forensic tracing information prepared by Ridgeline Advisory Group LLC under Engagement No. RAG-2022-0319. Dr. Margaret Liu, CPA, CFE, serves as engagement lead. Ridgeline was retained by this firm on May 2, 2022, to conduct forensic accounting analysis of the fourteen flagged crude oil swap transactions, trace payment flows, and identify conn

7. Nexagen Analytics Inc. — Document Review Platform. Relevant custodian documents were identified and reviewed through the e-discovery platform maintained by Nexagen Analytics Inc. (Project No. NX-DEH-2204; project manager: Brian Cavanaugh). The document population for the Zenith Petroleum review was identified using technology-assisted review ("TAR"), supplemented by targeted keyword and date-range searches. The TA

8. Witness Interview Memoranda. Memoranda prepared from first-round witness interviews conducted between May 18 and June 30, 2022. The interviews most directly relevant to the Zenith Petroleum due diligence are: • Omar Al-Rashidi, interviewed June 14, 2022 (counsel present: Jasmine Thornton, Amara Osei); and • Natasha Sorokin, interviewed June 2, 2022 (counsel present: Jasmine Thornton; Sorokin's personal counsel Phi

III. Corporate Profile — Zenith Petroleum DMCC A. Formation and Registration Zenith Petroleum DMCC is a company formed and registered under the DMCC Companies Regulations within the Dubai Multi Commodities Centre free zone. The key registration details are as follows: • Full legal name: Zenith Petroleum DMCC • Entity type: DMCC company (limited liability company registered with the Dubai Multi Commodities Centre) • R

IV. The Two Flagged Crude Oil Swap Transactions A. Transaction Overview As noted above, Zenith Petroleum was a named counterparty in two of the fourteen crude oil swap transactions executed by DTI between June 2020 and February 2022 that have been flagged for investigation. Both of these transactions fall within the subset of nine "tainted" transactions — with a combined notional value of approximately $156.3 million

V. Connections to Petronova Trading FZE and Volkhov Industrial Group A. Relationship Between Zenith Petroleum and Petronova Trading FZE The investigation has uncovered substantial documentary and circumstantial evidence of a close commercial relationship between Zenith Petroleum and Petronova Trading FZE. Petronova is a free zone entity registered at Office 1407, Al Shafar Tower, Dubai Internet City, Dubai, UAE, and

VI. Assessment of Dunmore's Pre-Transaction Due Diligence on Zenith Petroleum A. DTI's KYC and Onboarding Records The investigation team reviewed DTI's counterparty onboarding file for Zenith Petroleum DMCC. The file, which was maintained in DTI's compliance records and retrieved from Rajesh Malhotra's custodian files, is notable for its thinness. The onboarding file contained the following materials: • Basic DMCC re

1. Involvement in Russian-origin crude oil trades. Both Zenith Petroleum transactions involved Urals-grade crude oil loaded at Russian export terminals (Novorossiysk and Primorsk). Given the heightened sanctions risk associated with Russian-origin energy commodities — particularly after OFAC's November 2019 designation of Volkhov under Directive 2 — any transaction involving Russian-origin crude should have been flag

2. Temporal overlap with Petronova transactions. The two Zenith Petroleum transactions occurred during the same period in which DTI was executing similar crude oil swap transactions with Petronova Trading FZE. In several instances, the Zenith Petroleum and Petronova transactions involved similar cargo lots, loading ports, and vessel charters. This overlap should have been detected by any reasonably designed transacti

3. Payment structures through Crescent Commercial Bank PJSC. The routing of payments through Zenith Petroleum's and Petronova's accounts at the same Crescent Bank branch, with transfers between the two entities occurring in close temporal proximity to the DTI transactions, is a classic indicator of layered or structured payment flows designed to obscure the ultimate beneficiary of a transaction. These payment pattern

4. Al-Rashidi's awareness of the Petronova–Zenith Petroleum relationship. Omar Al-Rashidi, who approved the onboarding of Zenith Petroleum as a counterparty, has acknowledged in his interview that he was aware of the commercial relationship between Petronova and Zenith Petroleum. This awareness should have prompted Al-Rashidi to escalate the matter to the Chief Compliance Officer or to insist on enhanced due diligenc

VII. Regulatory Implications A. OFAC Sanctions Analysis The two Zenith Petroleum transactions described in this memorandum potentially violated Directive 2 under Executive Order 13662, which imposes sectoral sanctions on the energy sector of the Russian Federation. Volkhov Industrial Group JSC was added to the SSI List under Directive 2 effective November 15, 2019. Both Zenith Petroleum transactions — dated October 2

VIII. Open Items and Recommendations A. Further Investigation Steps Based on the findings set forth in this memorandum, the investigation team recommends the following additional steps to further develop the factual record regarding Zenith Petroleum:

1. Additional banking records. We recommend requesting additional account records from Crescent Commercial Bank PJSC for Zenith Petroleum's accounts, including complete account statements, wire transfer details, and supporting documentation for the full period of January 2019 to present. These records should be obtained through Dunmore's existing relationship with Khalid Mansour at Crescent Bank. The objective is to

2. Ridgeline forensic analysis. We recommend that Ridgeline Advisory Group be directed to complete its full forensic analysis of the two Zenith Petroleum transaction flows, including a complete tracing of the upstream sourcing chain and the downstream payment flows, as part of its broader engagement. Ridgeline's final forensic report is expected by approximately April 1, 2023. However, given the significance of the Z

3. Interview of Farhan Qureshi. We recommend exploring the feasibility of securing a voluntary interview with Farhan Qureshi. Such an interview could provide critical information about Zenith Petroleum's upstream suppliers, its relationship with Petronova and Sergei Volkov, and the extent of Qureshi's knowledge of the Volkhov connection. However, any outreach to Qureshi must be carefully assessed in light of jurisdic

4. Second-round witness interviews. The second round of witness interviews is scheduled to commence on August 5, 2022. We recommend that the following topics be addressed in the second-round interviews: • Re-interview of Omar Al-Rashidi: Al-Rashidi should be asked to provide additional detail regarding his understanding of the relationship between Zenith Petroleum and Petronova, the basis for his characterization of

IX. Conclusion Based on the due diligence findings set forth in this memorandum, the investigation team has reached the following conclusions:

1. Zenith Petroleum DMCC, while not itself an OFAC-designated entity, functioned as a secondary intermediary in a supply chain that facilitated DTI's access to crude oil originating from Volkhov Industrial Group-controlled operations. The evidence indicates that Zenith Petroleum operated in close coordination with Petronova Trading FZE, serving as an additional layer of intermediation designed to distance DTI from th

2. The two flagged crude oil swap transactions involving Zenith Petroleum — with a combined notional value of approximately $41.5 million — are properly included within the nine tainted transactions (totaling approximately $156.3 million in notional value) that Ridgeline Advisory Group has identified as involving crude oil ultimately sourced from or destined for Volkhov-connected entities, in potential violation of O

3. DTI's failure to conduct adequate counterparty due diligence on Zenith Petroleum at the time of onboarding — including the failure to perform OFAC screening, the failure to investigate Zenith Petroleum's ownership and business relationships, and the failure to conduct enhanced due diligence despite the entity's activity in Russian-origin crude markets — constitutes a significant compliance failure. The subsequent

4. Further investigation is needed. The forensic analysis of the Zenith Petroleum transaction flows is preliminary, and important open questions remain regarding the full payment chain, the identity of upstream suppliers, and the extent of knowledge and intent on the part of DTI personnel. The investigation team's recommendations for further steps are set forth in Section VIII above. This memorandum will be supplemen