Contract analysis

I. COVER PAGE AND TRANSMITTAL INFORMATION VOLUNTARY SELF-DISCLOSURE Pursuant to 31 C.F.R. Part 501, Appendix A Addressee: Office of Foreign Assets Control Compliance and Enforcement Division U.S. Department of the Treasury 1500 Pennsylvania Avenue NW Washington, D.C. 20220 Filing Entity: Dunmore Energy Holdings Ltd., an exempted company incorporated with limited liability under the laws of the Cayman Islands, Cayman

II. EXECUTIVE SUMMARY Dunmore Energy Holdings Ltd. ("Dunmore" or "DEH") hereby voluntarily discloses to the Office of Foreign Assets Control ("OFAC") apparent violations of U.S. sanctions laws arising from activities conducted at its Dubai-based subsidiary, Dunmore Trading International Ltd. ("DTI"), DIFC License No. CL-4827, with its principal office located at Level 14, Gate Building 3, Dubai International Financia

III. DESCRIPTION OF THE DISCLOSING ENTITY A. Dunmore Energy Holdings Ltd. — Corporate Overview Dunmore Energy Holdings Ltd. ("Dunmore" or "DEH") is an exempted company incorporated with limited liability under the laws of the Cayman Islands, Cayman Company Registration No. MC-334821. Dunmore's registered office is located at Harbour Place, 4th Floor, 103 South Church Street, George Town, Grand Cayman KY1-1002, Cayman

IV. APPLICABLE OFAC PROGRAMS AND LEGAL FRAMEWORK A. Executive Order 13662 and Directive 2 — Sectoral Sanctions, Energy Sector of the Russian Federation Executive Order 13662, signed by the President on March 20, 2014, authorizes the Secretary of the Treasury, in consultation with the Secretary of State, to impose sanctions on persons determined to be operating in specified sectors of the Russian Federation economy, i

V. COUNTERPARTIES TO THE APPARENT VIOLATIONS A. Petronova Trading FZE Entity Information. Petronova Trading FZE ("Petronova") is a Free Zone Establishment registered in the Jebel Ali Free Zone Authority ("JAFZA"), Dubai, United Arab Emirates. Petronova's registered address is Office 1407, Al Shafar Tower, Dubai Internet City, Dubai, United Arab Emirates. Petronova's Managing Director is Sergei Volkov, a Russian natio

VI. DETAILED DESCRIPTION OF APPARENT VIOLATIONS A. Category 1: Crude Oil Swap Transactions ($218.7 Million Total Notional / $156.3 Million Tainted)

1. Overview. Between approximately June 2020 and February 2022, DTI's Dubai-based trading desk executed fourteen crude oil swap transactions with a total aggregate notional value of approximately $218.7 million. The counterparties to these transactions were Petronova Trading FZE (twelve transactions) and Zenith Petroleum DMCC (two transactions). The transactions were structured as commodity swap agreements, with DTI

2. Identification of Tainted Transactions Calderwood & Harkness retained Ridgeline Advisory Group LLC ("Ridgeline"), a forensic accounting and financial advisory firm, to conduct a comprehensive forensic analysis of the fourteen crude oil swap transactions. The engagement was initiated on May 2, 2022, under Engagement No. RAG-2022-0319. The engagement was led by Dr. Margaret Liu, CPA, CFE, a recognized expert in fore

3. Transaction-by-Transaction Summary A detailed summary of all fourteen crude oil swap transactions is set forth in the Transaction Summary Schedule attached hereto as Appendix A. The Transaction Summary Schedule is presented in spreadsheet format and includes, for each transaction, the following information: (a) Transaction reference number (DTI internal booking reference); (b) Trade date (the date on which the swa

4. Sanctions Analysis for Category 1 The sanctions analysis for the Category 1 transactions requires consideration of two distinct regulatory regimes, depending on the date of the transaction: Directive 2 Period (November 15, 2019 through April 5, 2022). During this period, Volkhov was designated under Directive 2 of E.O. 13662, which imposed restrictions on transactions by U.S. persons involving new debt of longer t

1. Overview. Between approximately August 2020 and January 2022, DTI facilitated the export of oilfield drilling equipment and components with an aggregate value of approximately $12.4 million to end users in Russia. The equipment was shipped from various points of origin in Europe and the Middle East, routed through Caspian Logistik GmbH in Hamburg, Germany, which served as the logistics and freight-forwarding agent

2. End-User Certificate Issues Calderwood & Harkness's investigation included a detailed review of the end-user certifications associated with each of the equipment shipments facilitated by Caspian Logistik GmbH. The review, performed by Liam Donahue and set forth in a Calderwood & Harkness memorandum dated July 20, 2022, identified significant irregularities in the end-user certificates submitted in connection with

3. Tangential Involvement of Dunmore Renewables GmbH One of the suspect equipment export transactions involved Dunmore Renewables GmbH, the company's German subsidiary based in Hamburg. In this transaction, which occurred in approximately November 2021, Dunmore Renewables GmbH facilitated the procurement of certain specialized drilling components from a European manufacturer and transferred the components to Caspian

4. OFAC Implications The oilfield equipment exports to Russia present potential violations of OFAC-administered sanctions programs to the extent that the equipment was exported to, or for the benefit of, Volkhov-controlled entities or other persons subject to OFAC sanctions, including persons identified on the SDN List or SSI List. The diversion of equipment to sanctioned end users through the use of false end-user c

1. Overview. Ridgeline Advisory Group LLC's forensic analysis identified approximately $34.2 million in payments that were routed through a series of intermediary accounts maintained at Crescent Commercial Bank PJSC in Dubai during the period March 2020 through March 2022. The $34.2 million was distributed across 127 individual wire transactions. The forensic analysis concluded that the payments were structured in a

2. Structuring Methods The investigation identified the following principal methods by which payments were structured to evade sanctions screening: (a) Use of Multiple Intermediary Accounts. Rather than directing payments from DTI directly to Petronova Trading FZE or other Volkhov-connected counterparties, payments were routed through a series of intermediary accounts held at Crescent Commercial Bank in the names of

3. OFAC Implications Payment structuring designed to evade sanctions screening constitutes an apparent violation of the prohibitions on evasion, avoidance, or circumvention of U.S. sanctions under the applicable OFAC programs. Section 1705(a) of IEEPA (50 U.S.C. § 1705(a)) prohibits any person from causing a violation, conspiring to violate, or attempting to violate the sanctions imposed under executive orders admini

VII. DISCOVERY AND REPORTING TIMELINE A. Discovery of Potential Violations Dunmore's discovery of its potential exposure to OFAC sanctions liability occurred in the immediate aftermath of OFAC's addition of Volkhov Industrial Group JSC to the SDN List on April 6, 2022, pursuant to Executive Order 14024. On April 11, 2022, then-Chief Compliance Officer Gerald Fisk conducted a routine screening refresh of Dunmore's cou