Contract analysis

I. Purpose of This Letter The purpose of this letter is to transmit, on behalf of Dunmore, the comprehensive internal investigation report (the "Report"), dated May 15, 2023, consisting of one hundred seventy-six (176) pages, together with the exhibits and appendices referenced therein. The Report is enclosed herewith in hard copy (two bound copies, marked "Copy 1 of 2" and "Copy 2 of 2," respectively) and in searcha

II. Background and Context of the Investigation A. Origins of the Inquiry The Department's inquiry arose in connection with potential violations of United States sanctions laws, including programs administered by the Office of Foreign Assets Control ("OFAC") of the U.S. Department of the Treasury, and U.S. export control regulations. The potential violations involve activities conducted at the overseas trading desk o

1. International Emergency Economic Powers Act ("IEEPA"), 50 U.S.C. §§ 1701–1706, which provides the statutory basis for the imposition of economic sanctions by the President of the United States;

2. Export Control Reform Act ("ECRA"), 50 U.S.C. §§ 4801–4852, which governs the control of exports, reexports, and in-country transfers of items subject to the Export Administration Regulations;

3. OFAC Directive 2 under Executive Order 13662, which imposes sectoral sanctions on the energy sector of the Russian Federation. Volkhov Industrial Group JSC, the entity of central relevance to this investigation, was designated under Directive 2 as a person operating in the energy sector of the Russian Federation on November 15, 2019 (OFAC List of Sectoral Sanctions Identifications);

4. Executive Order 14024 (April 15, 2021, as amended), "Blocking Property With Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation," under which OFAC imposed a full Specially Designated Nationals ("SDN") blocking designation on Volkhov Industrial Group JSC, effective April 6, 2022;

5. Export Administration Regulations ("EAR"), 15 C.F.R. Parts 730–774, including, in particular, § 746.5 (Russia/Belarus), which imposes license requirements on the export, reexport, and transfer of specified items to Russia and Belarus; and

6. Related executive orders, OFAC guidance, and Bureau of Industry and Security ("BIS") rulings applicable during the period under review. The interplay of these authorities is significant because the conduct at issue spans a period during which the sanctions landscape applicable to Russia-connected entities underwent substantial and rapid evolution — from the sectoral sanctions regime under E.O. 13662 through the co

III. Scope of the Internal Investigation The internal investigation covered the period from approximately January 1, 2019 through the present date, matching the temporal scope of Grand Jury Subpoena No. GJ No. 22-418. The scope of the investigation encompassed the following principal areas: (a) All transactions between Dunmore entities — primarily DTI, but also including Dunmore Energy Holdings Ltd. (Cayman Islands),

IV. Summary of Investigation Activities A. Document Collection and Review Nexagen Analytics Inc. ("Nexagen"), a nationally recognized e-discovery and forensic data collection firm, was retained under engagement Project No. NX-DEH-2204, under the supervision of Nexagen project manager Brian Cavanaugh and Calderwood & Harkness's e-discovery lead, Thomas Bradshaw, Esq. Nexagen was engaged to collect, process, host, and

V. Summary of Key Findings Presented in the Report The Report details findings across three principal categories of conduct occurring between approximately March 2020 and April 2022. The evidence indicates that this conduct was carried out under the supervision and direction of Derek Hargrave (President, DTI) and with the direct involvement of Natasha Sorokin (Senior Trader, DTI). While a full recitation of the findi

VI. Personnel Actions Taken In response to the findings of the internal investigation as they developed over the course of 2022, Dunmore took the following personnel actions: • Gerald Fisk (former Chief Compliance Officer): Mr. Fisk departed Dunmore on June 10, 2022. The circumstances of his departure and the company's assessment of his role are discussed at Section VI.A of the Report. • Natasha Sorokin (former Senio

VII. Cooperation and Remediation A. Voluntary Cooperation Dunmore wishes to emphasize its full and timely voluntary cooperation with the Department throughout the pendency of this investigation. From the outset, Dunmore has been committed to cooperation consistent with the principles articulated in the DOJ Corporate Enforcement Policy (as updated in September 2022), including by providing timely disclosure of relevan

VIII. Privilege Reservation The Report is provided to the Department pursuant to the selective waiver protocol established in Calderwood & Harkness's memorandum to AUSA Calloway dated July 1, 2022, and acknowledged by the Department in correspondence dated July 8, 2022. That protocol provides that the disclosure of privileged materials to the Department in connection with this investigation is made on a limited and s

IX. Confidentiality Request Dunmore respectfully requests that the Department treat the Report and all of its contents as confidential in accordance with the Department's standard practices for the handling of materials provided by cooperating parties. The Report contains proprietary business information of Dunmore and its subsidiaries, including commercially sensitive trading data, financial information, counterpart

X. Availability for Discussion The undersigned, together with Jasmine Thornton, Conrad Reeves, and other members of the Calderwood & Harkness investigation team, are available to discuss the Report's findings, methodology, and conclusions at the Department's convenience. We would welcome the opportunity to arrange a detailed presentation or walkthrough of the Report for AUSA Calloway, Trial Attorney Kovacs, Trial Att

XI. Enclosures The following materials are enclosed with this letter:

1. Internal Investigation Report of Calderwood & Harkness LLP Regarding Dunmore Energy Holdings Ltd. — Comprehensive Findings and Recommendations (176 pages; two bound hard copies, marked "Copy 1 of 2" and "Copy 2 of 2");

2. Encrypted USB drive containing a searchable PDF version of the Report (decryption password transmitted separately); and

3. Index of Exhibits and Appendices referenced in the Report, including a master table of exhibits, appendices, and supporting schedules. We wish to express our sincere appreciation for the professionalism, thoroughness, and constructive engagement that you, Trial Attorney Kovacs, Trial Attorney Pressman, and the entire CES investigation team have demonstrated throughout this process. Dunmore values the opportunity t