Contract analysis

I. COVER PAGE AND TRANSMITTAL STATEMENT Dunmore Energy Holdings Ltd. ("Dunmore" or "DEH"), a Cayman Islands–domiciled exempted company with limited liability, through its undersigned counsel at Calderwood & Harkness LLP, hereby respectfully submits this Voluntary Self-Disclosure ("VSD") to the Office of Foreign Assets Control ("OFAC") of the U.S. Department of the Treasury, pursuant to 31 C.F.R. § 501.604 and in acco

II. EXECUTIVE SUMMARY Dunmore Energy Holdings Ltd. is a Cayman Islands–domiciled exempted company with limited liability (Cayman Islands Registrar of Companies registration number MC-334821), with its operational headquarters located at 1200 McKinney Street, Suite 3400, Houston, Texas 77010. Dunmore is a diversified energy company principally engaged in oil and gas exploration, production, and trading, as well as ren

III. DISCLOSING PARTY INFORMATION A. Entity Identification Full Legal Name: Dunmore Energy Holdings Ltd. Short Name / Trade Name: Dunmore; DEH Entity Type: Exempted company incorporated with limited liability under the laws of the Cayman Islands Cayman Islands Registrar of Companies Registration Number: MC-334821 Date of Incorporation: March 15, 2012 Registered Office: Harbour Place, 4th Floor, 103 South Church Stree

IV. OFAC PROGRAMS AND LEGAL AUTHORITIES AT ISSUE The apparent violations described in this VSD implicate the following OFAC-administered sanctions programs, executive orders, regulations, and legal authorities. This section provides a summary of the relevant legal framework to contextualize the conduct described in Section VI below. A. Executive Order 13662 and Directive 2 (Sectoral Sanctions — Energy Sector of the R

V. BACKGROUND: HOW THE APPARENT VIOLATIONS WERE DISCOVERED A. OFAC Designation of Volkhov (April 6, 2022) On April 6, 2022, OFAC announced a series of new SDN designations targeting Russian persons and entities in connection with the ongoing conflict in Ukraine and Russia's harmful foreign activities. Among those designated was Volkhov Industrial Group JSC, a Russian industrial conglomerate headquartered at 12 Kutuzo

VI. DETAILED DESCRIPTION OF APPARENT VIOLATIONS A. Category 1: Crude Oil Swap Transactions with Volkhov-Connected Intermediaries

1. Overview of Counterparties The crude oil swap transactions at issue were conducted between DTI and two Dubai-based counterparties: Petronova Trading FZE and Zenith Petroleum DMCC. The following provides a detailed description of each counterparty, including the results of the beneficial ownership analysis that established the Volkhov connections underlying these transactions. Petronova Trading FZE. Petronova Tradi

2. Description of Transactions Between June 2020 and February 2022, DTI's Dubai-based trading desk executed a total of fourteen (14) crude oil swap transactions with Petronova Trading FZE and Zenith Petroleum DMCC. The aggregate notional value of these fourteen transactions was approximately $218.7 million. The forensic analysis conducted by Ridgeline Advisory Group LLC determined that at least nine (9) of the fourte

3. Roles of Key Individuals Derek Hargrave (President, DTI). Mr. Hargrave served as President of DTI and was the most senior Dunmore executive in Dubai during the relevant period. As President, Mr. Hargrave had supervisory authority over DTI's trading desk and was responsible for approving all significant trading relationships and transactions. The evidence obtained during the investigation establishes that Mr. Hargr

1. Counterparty: Caspian Logistik GmbH Caspian Logistik GmbH is a Gesellschaft mit beschränkter Haftung registered in Hamburg, Germany (Handelsregister: HRB 163258, Amtsgericht Hamburg). Caspian Logistik's registered address is Mönckebergstraße 22, 20095 Hamburg, Germany. The Managing Director of Caspian Logistik is Klaus Weidemann, a German national. Caspian Logistik was incorporated on July 15, 2016, and describes

2. Description of the Exports Between August 2020 and January 2022, DTI facilitated the export of oilfield drilling equipment and components to Russia through Caspian Logistik GmbH. The equipment was valued at approximately $12.4 million in aggregate across multiple shipments. The equipment consisted primarily of downhole drilling tools, drill pipe assemblies, mud pump components, and related oilfield service equipme