Contract analysis

I. INTRODUCTION AND PROGRAM OVERVIEW 1.1 Purpose of the Training Program This Training Program constitutes a core component of Dunmore Energy Holdings Ltd.'s ("DEH" or the "Company") Enhanced Sanctions & Export Controls Compliance Program (the "Program"), which was formally adopted by the DEH Board of Directors on October 1, 2023. The Program was developed in direct response to findings from the internal investigatio

II. MODULE 1: OVERVIEW OF U.S. SANCTIONS LAWS AND OFAC PROGRAMS 2.1 What Are Economic Sanctions? Economic sanctions are restrictions imposed by the United States government on economic and financial transactions with targeted countries, governments, entities, and individuals. The purpose of U.S. economic sanctions is to advance the national security and foreign policy objectives of the United States, including the pr

III. MODULE 2: U.S. EXPORT CONTROL REGULATIONS (EAR) 3.1 Overview of the Export Administration Regulations In addition to the sanctions laws administered by OFAC, Dunmore's operations are subject to U.S. export control regulations administered by the Bureau of Industry and Security ("BIS"), a bureau within the U.S. Department of Commerce. The export control regime is distinct from, but complementary to, the sanctions

IV. MODULE 3: DUNMORE-SPECIFIC RISK PROFILE AND LESSONS LEARNED 4.1 Dunmore's Business Operations and Risk Areas Dunmore Energy Holdings Ltd. operates a diversified global energy business encompassing oil and gas exploration, production, and trading, as well as renewable energy development. The geographic breadth and operational complexity of Dunmore's business create a multifaceted risk profile with respect to sanct