Contract analysis

I. Introduction & Purpose Calderwood & Harkness LLP represents Dunmore Energy Holdings Ltd. ("Dunmore" or "DEH"), an exempted company incorporated with limited liability under the laws of the Cayman Islands (Company Registration No. MC-334821), with its operational headquarters located at 1200 McKinney Street, Suite 3400, Houston, Texas 77010. We write on Dunmore's behalf to provide supplemental information responsiv

II. Section 1: Supplemental Transaction Details — Crude Oil Swap Transactions A. Overview of All 14 Crude Oil Swap Transactions As disclosed in the June 1, 2023 VSD, between June 2020 and February 2022, Dunmore Trading International Ltd. ("DTI"), a wholly owned trading subsidiary of Dunmore organized and operating under a Dubai International Financial Centre ("DIFC") License (License No. CL-4827), executed fourteen (

1. Petronova Trading FZE ("Petronova"), a free zone establishment registered in the Jebel Ali Free Zone ("JAFZA"), Dubai, United Arab Emirates. Petronova's registered address is Office 1407, Al Shafar Tower, Dubai Internet City, Dubai, UAE. Its Managing Director and sole registered shareholder is Sergei Volkov, a Russian national who is a resident of the United Arab Emirates.

2. Zenith Petroleum DMCC ("Zenith Petroleum"), a company registered with the Dubai Multi Commodities Centre ("DMCC") in Dubai, United Arab Emirates. Zenith Petroleum's registered address is Unit 2201, Jumeirah Bay Tower X2, Cluster X, Jumeirah Lakes Towers, Dubai, UAE. Its Managing Director is Farhan Qureshi, a Pakistani national who is a resident of the United Arab Emirates. The fourteen crude oil swap transactions

III. Section 2: Petronova Trading FZE — Beneficial Ownership Details Ms. Matsuda's July 18, 2023 email specifically requested additional beneficial ownership information regarding Petronova Trading FZE. The following information is provided in response. Corporate Structure and Ownership. Petronova Trading FZE was established as a free zone establishment under the Jebel Ali Free Zone Authority ("JAFZA") on June 7, 201

IV. Section 3: Oilfield Equipment Export Details — Caspian Logistik GmbH Ms. Matsuda's August 7, 2023 telephone request included a specific inquiry regarding the oilfield equipment exports facilitated by DTI through Caspian Logistik GmbH. The following information is provided in response. Overview of Oilfield Equipment Exports. Between August 2020 and January 2022, DTI facilitated the export of oilfield drilling equi

V. Section 4: Payment Structuring Through Crescent Commercial Bank PJSC Ms. Matsuda's July 18, 2023 email and August 7, 2023 telephone call both requested additional detail regarding the payment flows associated with the transactions at issue. The following information is provided in response. Overview of Payment Flows. Ridgeline Advisory Group's forensic accounting analysis identified approximately $34.2 million in

VI. Section 5: Key Personnel Involved in the Transactions In response to Ms. Matsuda's request for a comprehensive identification of the individuals responsible for, or materially involved in, the transactions at issue, Dunmore provides the following summary. A key personnel chart depicting each individual's role, organizational position, and involvement in the relevant transactions is enclosed as Exhibit F.

1. Derek Hargrave — Former President, DTI. Mr. Hargrave served as President of Dunmore Trading International Ltd. from 2017 through 2022, during which time he supervised the trading desk and was responsible for the overall management and strategic direction of DTI's commodity trading operations. Mr. Hargrave approved the establishment of counterparty relationships with both Petronova Trading FZE and Zenith Petroleum

2. Natasha Sorokin — Former Senior Trader, DTI. Ms. Sorokin served as Senior Trader on DTI's crude oil trading desk from 2019 through 2022. She is a Russian-American dual national. Ms. Sorokin was the primary point of contact with Sergei Volkov (Petronova's Managing Director) and was responsible for the day-to-day execution of the crude oil swap transactions at issue. Her email account contained the communications de

3. Gerald Fisk — Former Chief Compliance Officer, DEH. Mr. Fisk served as Chief Compliance Officer of Dunmore Energy Holdings Ltd. from 2016 through June 2022, based in the Houston, Texas headquarters. Mr. Fisk was responsible for the design, implementation, and oversight of Dunmore's sanctions and export controls compliance program, including OFAC screening procedures, counterparty due diligence protocols, and compl

4. Omar Al-Rashidi — Head of Middle East Operations, DTI. Mr. Al-Rashidi serves as Head of Middle East Operations for DTI, based in the Dubai office. Mr. Al-Rashidi had operational oversight of DTI's regional trading activities and relationships with UAE-based counterparties. Mr. Al-Rashidi is a cooperating witness in the internal investigation and has provided detailed information to Ridgeline and Calderwood & Harkn

5. Yves Leclerc — Director of Logistics & Shipping, DTI. Mr. Leclerc, a French national, serves as Director of Logistics & Shipping for DTI, responsible for coordinating vessel charters, freight forwarding, and physical delivery of commodity cargoes. Mr. Leclerc facilitated the shipping arrangements for the oilfield equipment exports conducted through Caspian Logistik GmbH, including the arrangement of freight forwar

VII. Section 6: Compliance Remediation Update Dunmore wishes to update OFAC on the compliance remediation steps taken since the filing of the June 1, 2023 VSD, and the steps that are in progress. Dunmore views comprehensive remediation as a critical component of its response to the apparent violations and its commitment to building a robust, best-in-class sanctions and export controls compliance program. Appointment

VIII. Section 7: Voluntary Disgorgement Dunmore is in the process of calculating and preparing a voluntary disgorgement payment representing the estimated net profits derived from the nine (9) tainted crude oil swap transactions identified in this letter and in the June 1, 2023 VSD. The calculation methodology is as follows: • Aggregate notional value of tainted transactions: $156,300,000 • Estimated net margin: 5.6%

IX. Section 8: Enclosed Supplemental Documents The following exhibits are enclosed with this letter, as referenced herein: Exhibit A: Detailed transaction-level schedule of all fourteen (14) crude oil swap transactions, with the nine (9) tainted transactions highlighted, including counterparty identification, transaction date, notional value, commodity description, payment details, vessel/delivery references, and Vol

X. Reservation of Rights and Continuing Cooperation Dunmore Energy Holdings Ltd. expressly reserves all rights and defenses available to it under applicable law, regulation, and executive order, including but not limited to any defenses based on the scope of the relevant sanctions authorities, the application of the 50 Percent Rule, the availability of general or specific licenses, and the adequacy of the evidentiary

XI. Confidentiality Dunmore respectfully requests that OFAC treat the supplemental information contained in this letter and the enclosed Exhibits A through F as confidential business information, to the fullest extent permitted by law, including under the Trade Secrets Act, 18 U.S.C. § 1905, the Freedom of Information Act, 5 U.S.C. § 552 (particularly Exemptions 4 and 7), and any other applicable legal protections. T

XII. Closing We trust that the foregoing supplemental information is responsive to Ms. Matsuda's requests. Dunmore remains committed to cooperating fully with OFAC and to providing any additional information or clarification that may be needed as OFAC's review of this matter continues. Should you wish to discuss any aspect of this submission, I am available at your convenience and can be reached at my direct dial num