Contract analysis

I. Executive Summary The purpose of this memorandum is to set forth the comprehensive ongoing monitoring, testing, and audit framework designed to ensure the sustained effectiveness of Dunmore Energy Holdings Ltd.'s ("Dunmore" or "DEH") Enhanced Sanctions & Export Controls Compliance Program (the "Enhanced Program"), which was formally adopted by the Board of Directors of Dunmore Energy Holdings Ltd. on October 1, 20

II. Background and Procedural Context A. The DOJ Inquiry and Internal Investigation On April 19, 2022, the DOJ National Security Division opened a formal inquiry into Dunmore Energy Holdings Ltd. and its subsidiary, Dunmore Trading International Ltd., concerning potential violations of U.S. sanctions laws and export control regulations. The inquiry was initiated following intelligence received by the DOJ from multipl

III. Monitoring and Testing Framework — Structural Overview A. Three Lines of Defense Model The monitoring and testing framework is structured in accordance with the "Three Lines of Defense" model, which is widely recognized as a best practice in compliance program design and is consistent with the expectations reflected in the DOJ Evaluation Guidance. Under this model, responsibility for compliance is distributed ac

IV. OFAC Sanctions Screening — Ongoing Monitoring Protocols A. Automated Screening System The cornerstone of the Enhanced Program's ongoing sanctions monitoring capability is a robust automated screening system that provides real-time interdiction screening of all relevant parties against applicable OFAC sanctions lists and programs. The automated screening system is designed to screen all counterparties, beneficial

V. Export Controls — Ongoing Monitoring Protocols A. Export Classification and License Determination The export control monitoring protocols within the Enhanced Program address the specific vulnerabilities identified in connection with the oilfield equipment exports facilitated through Caspian Logistik GmbH. The investigation determined that DTI facilitated exports of items classified under ECCN 2B350 (chemical manuf

VI. Transaction Sampling and Testing Methodology A. Sampling Protocol — Crude Oil and Commodity Trades The Compliance Department will conduct quarterly sampling and testing of crude oil, refined product, and commodity swap transactions executed by DTI. The sampling protocol is designed to provide statistically meaningful coverage of DTI's trading activity while allocating enhanced scrutiny to transactions presenting

VII. Annual Comprehensive Compliance Assessment A. Scope and Objectives The Enhanced Program provides for an annual comprehensive compliance assessment designed to evaluate both the design and operating effectiveness of the sanctions and export controls compliance program as a whole. The annual assessment serves as the most rigorous and holistic evaluation mechanism within the monitoring and testing framework, supple

VIII. Third-Party Due Diligence — Ongoing Monitoring A. Counterparty Risk Rating and Refreshment The Enhanced Program establishes a tiered counterparty risk rating system that categorizes all counterparties on a three-level scale — High, Medium, and Low — based on a multi-factor risk assessment. The risk rating determines the frequency and depth of ongoing due diligence activities for each counterparty. The risk fact