Contract analysis

I. Introduction and Purpose I am Victoria Chambers, a partner in the White Collar & Investigations practice at Calderwood & Harkness LLP in our Washington, D.C. office. I write on behalf of the firm's client, Dunmore Energy Holdings Ltd. ("Dunmore" or "DEH"), in connection with the enclosed Initial Voluntary Self-Disclosure ("VSD") being transmitted herewith to the Office of Foreign Assets Control ("OFAC") of the U.S

II. Identification of the Disclosing Party The disclosing party in this voluntary self-disclosure is Dunmore Energy Holdings Ltd., the particulars of which are set forth below: Full Legal Name: Dunmore Energy Holdings Ltd. Entity Type: Exempted company incorporated with limited liability under the laws of the Cayman Islands. Cayman Islands Company Registration Number: MC-334821. Registered Office: Harbour Place, 4th

III. Summary of Apparent Violations Based on Calderwood & Harkness's comprehensive internal investigation, which is described in greater detail in Section IV below and in the enclosed VSD narrative, Dunmore has identified the following categories of apparent violations of OFAC-administered sanctions programs. Dunmore reports these matters to OFAC in the interest of full transparency and in furtherance of its commitme

1. Directive 2 Designation (Sectoral Sanctions). On November 15, 2019, OFAC designated Volkhov under Directive 2 issued pursuant to Executive Order 13662 of March 20, 2014, which imposed sectoral sanctions on the energy sector of the Russian Federation. Directive 2 prohibits transactions by U.S. persons, or within the United States, involving new debt of longer than 90 days maturity or new equity of persons identifie

2. SDN List Designation (Full blocking Sanctions). On April 6, 2022, OFAC designated Volkhov under Executive Order 14024 of April 15, 2021, and added Volkhov to the Specially Designated Nationals and blocked Persons List ("SDN List"), thereby imposing full blocking sanctions. This designation prohibits all transactions by U.S. persons with Volkhov and requires the blocking of all property and interests in property of

1. Petronova Trading FZE. Office 1407, Al Shafar Tower, Dubai Internet City, Dubai, United Arab Emirates. Petronova is alleged to be a front entity operating on behalf of Volkhov Industrial Group JSC. The entity is managed by Sergei Volkov, a Russian national and UAE resident. Calderwood & Harkness's analysis, applying OFAC's 50 Percent Rule as set forth in OFAC's Revised Guidance on Entities Owned by Persons Whose P

2. Zenith Petroleum DMCC. Unit 2201, Jumeirah Bay Tower X2, Cluster X, Jumeirah Lakes Towers, Dubai, United Arab Emirates. Zenith is managed by Farhan Qureshi, a Pakistani national and UAE resident. Zenith was involved as a named counterparty in two of the nine flagged transactions. The evidence gathered to date suggests that Zenith may have served as an additional intermediary for Volkhov-connected transactions, alt

3. Caspian Logistik GmbH. Mönckebergstraße 22, 20095 Hamburg, Germany. Managed by Klaus Weidemann, a German national. Caspian Logistik served as a logistics and freight forwarding facilitator for the oilfield equipment shipments described in Section III.D above. Ridgeline's investigation identified documentation suggesting that Caspian Logistik coordinated directly with Volkhov-affiliated entities regarding the deliv

IV. Summary of Internal Investigation and Cooperation with DOJ Dunmore's internal investigation was initiated promptly upon the identification of potential sanctions exposure and has been comprehensive in scope. The key milestones and parameters of the investigation are as follows: Identification of Potential Exposure. Upon the April 6, 2022 addition of Volkhov Industrial Group JSC to the SDN List under Executive Ord

V. Personnel Actions Taken Dunmore has taken prompt and decisive personnel actions with respect to the individuals most closely associated with the apparent violations described in this VSD:

1. Natasha Sorokin (then-Senior Trader, DTI). Ms. Sorokin was placed on administrative leave on May 16, 2022, immediately upon the identification of evidence indicating her direct involvement in the transactions at issue. Ms. Sorokin was formally separated from Dunmore effective September 15, 2022. Ms. Sorokin is represented by Philip Keane of Wexford Keane LLP, Washington, D.C.

2. Derek Hargrave (then-President, DTI). Mr. Hargrave was placed on administrative leave on July 1, 2022, following the conclusion of the first round of witness interviews and the identification of evidence indicating that Mr. Hargrave supervised and approved the transactions at issue. Mr. Hargrave was formally separated from Dunmore effective October 1, 2022. Mr. Hargrave is represented by James Overstreet of Overst

3. Gerald Fisk (former Chief Compliance Officer, DEH). Mr. Fisk departed Dunmore on June 10, 2022. Although Mr. Fisk was the individual who first identified the potential exposure on April 11, 2022, the internal investigation identified concerns regarding the adequacy of the compliance screening procedures in place during Mr. Fisk's tenure as CCO. Mr. Fisk is represented by Catherine Blackthorn of Blackthorn & Associ

4. Priya Nayar (new Chief Compliance Officer, DEH). Ms. Nayar was appointed as Dunmore's Chief Compliance Officer effective August 1, 2022, replacing Mr. Fisk. Ms. Nayar is a seasoned compliance professional with extensive experience in sanctions and export control compliance, and she reports directly to General Counsel Marcus Wellbourne with a dotted-line reporting relationship to the Audit and Compliance Committee

VI. Remediation Measures Undertaken and Planned Dunmore has undertaken, and continues to undertake, significant remediation measures to address the compliance deficiencies identified through the internal investigation and to strengthen its sanctions and export controls compliance program going forward. On December 15, 2022, Calderwood & Harkness retained Pemberton Investors Solutions LLC ("Marlowe Asset Management"),

VII. Voluntary Disgorgement Dunmore recognizes the seriousness of the apparent violations described in this VSD and is prepared to make a voluntary disgorgement payment to the U.S. Department of the Treasury representing the estimated net profits derived from the nine tainted crude oil swap transactions identified in Section III.B above. The estimated disgorgement amount has been calculated as follows: • Aggregate no

VIII. Mitigating Factors Dunmore respectfully submits that the following mitigating factors, as set forth in OFAC's Economic Sanctions Enforcement Guidelines (31 C.F.R. Part 501, Appendix A), are applicable to this voluntary self-disclosure and should be considered by OFAC in determining the appropriate enforcement response:

1. Voluntary Self-Disclosure. Dunmore is making this disclosure to OFAC voluntarily, prior to any OFAC inquiry, investigation, or enforcement action directed at Dunmore or any of its subsidiaries. Under OFAC's Enforcement Guidelines, a voluntary self-disclosure is a significant mitigating factor that may result in a reduction of up to fifty percent (50%) of the applicable base penalty amount for non-egregious cases.

2. Full Cooperation. Dunmore has cooperated fully and voluntarily with the DOJ throughout the course of the government's inquiry and is committed to providing the same level of cooperation to OFAC. Dunmore has produced extensive documentation, made current and former employees available for interviews, and provided timely and transparent communications regarding the findings of the internal investigation.

3. Comprehensive Remediation. Dunmore has taken swift and decisive remediation measures, including the separation of the individuals primarily responsible for the apparent violations, the appointment of a new Chief Compliance Officer, and the engagement of a leading compliance consulting firm to design and implement an enhanced compliance program. These remediation efforts demonstrate Dunmore's genuine commitment to

4. Conduct Not Directed by Senior Management at the Parent Level. The evidence gathered through the internal investigation indicates that the conduct giving rise to the apparent violations was primarily attributable to individuals operating at the DTI trading desk level — specifically, Derek Hargrave (then-President of DTI) and Natasha Sorokin (then-Senior Trader at DTI). There is no evidence that senior management a

5. No Prior OFAC Enforcement History. Neither Dunmore nor any of its subsidiaries has been the subject of any prior OFAC enforcement action, civil penalty, finding of violation, cautionary letter, or other adverse enforcement determination. Dunmore has no history of sanctions violations. Dunmore respectfully requests that OFAC give appropriate weight to these mitigating factors in its evaluation of this matter, consi

IX. Enclosed Materials The following materials are enclosed with this letter and are being submitted to OFAC as part of this voluntary self-disclosure:

1. Voluntary Self-Disclosure Narrative. Comprehensive filing document setting forth the factual background, detailed transaction analysis, legal analysis, and conclusions of Dunmore's internal investigation, as prepared by Conrad Reeves, Senior Counsel, Export Controls & Sanctions, and Jasmine Thornton, Lead Associate, Calderwood & Harkness LLP.

2. Appendix A: Transaction Summary Schedule — All 14 Crude Oil Swap Transactions (June 2020 – February 2022). This schedule summarizes all fourteen crude oil swap transactions with an aggregate notional value of $218.7 million, and identifies the nine transactions ($156.3 million in aggregate notional value) determined to involve Volkhov-controlled entities.

3. Appendix B: Summary of Ridgeline Advisory Group Forensic Findings. This appendix presents the key findings of Ridgeline Advisory Group's forensic accounting analysis, including payment flow analysis documenting $34.2 million in payments across 127 transactions routed through intermediary accounts at Crescent Commercial Bank PJSC (Dubai, UAE).

4. Appendix C: Beneficial Ownership Analysis — Petronova Trading FZE and 50% Rule Assessment. This appendix sets forth Calderwood & Harkness's analysis of the beneficial ownership structure of Petronova Trading FZE and the application of OFAC's 50 Percent Rule to the determination that Petronova is owned or controlled by Volkhov Industrial Group JSC.

5. Appendix D: Oilfield Equipment Export Shipment Summary. This appendix summarizes the oilfield equipment shipments valued at approximately $12.4 million facilitated by DTI through Caspian Logistik GmbH, including ECCN classifications (2B350 and 2B999), shipment dates, consignees, and end-user information.

6. Appendix E: Organizational Chart — Dunmore Energy Holdings Ltd. and Relevant Subsidiaries. This appendix provides a graphical organizational chart depicting the corporate structure of Dunmore Energy Holdings Ltd. and its relevant subsidiaries, including DTI.

7. Appendix F: Timeline of Key Events. This appendix provides a chronological timeline of the key events relevant to this voluntary self-disclosure, including the dates of the transactions at issue, the identification of potential exposure, the retention of counsel, the DOJ subpoena, and the milestones of the internal investigation.

X. Coordination with DOJ Dunmore wishes to confirm that the DOJ attorneys assigned to this matter are aware of, and have been informed regarding, the filing of this voluntary self-disclosure with OFAC. Specifically, AUSA Meredith Calloway, together with Trial Attorneys Samuel Kovacs and Diana Pressman of the DOJ National Security Division, Counterintelligence and Export Control Section, have been notified that Dunmor

XI. Point of Contact and Request for Acknowledgment The primary point of contact for OFAC regarding this voluntary self-disclosure and all related matters is: Victoria Chambers Partner, White Collar & Investigations Calderwood & Harkness LLP 1750 Pennsylvania Avenue NW, Suite 800 Washington, DC 20006 Telephone: (202) 448-7215 Email: vchambers@calderwoodharkness.com Additional contacts authorized to communicate with O

1. Voluntary Self-Disclosure Narrative

2. Appendix A: Transaction Summary Schedule — All 14 Crude Oil Swap Transactions (June 2020 – February 2022)

3. Appendix B: Summary of Ridgeline Advisory Group Forensic Findings

4. Appendix C: Beneficial Ownership Analysis — Petronova Trading FZE and 50% Rule Assessment

5. Appendix D: Oilfield Equipment Export Shipment Summary

6. Appendix E: Organizational Chart — Dunmore Energy Holdings Ltd. and Relevant Subsidiaries

7. Appendix F: Timeline of Key Events