Contract analysis

I. Purpose of This Letter We write on behalf of our client, Dunmore Energy Holdings Ltd. ("Dunmore" or "DEH"), an exempted company incorporated with limited liability under the laws of the Cayman Islands, with operational headquarters located at 1200 McKinney Street, Suite 3400, Houston, Texas 77010. As you are aware, this firm has represented Dunmore in connection with the ongoing inquiry by the U.S. Department of J

II. Background — Cooperation and Investigation Context Since the inception of the DOJ's inquiry, Dunmore has cooperated fully and in good faith with CES, and has endeavored at every stage to provide the government with timely, transparent, and comprehensive information regarding the conduct under investigation. We take this opportunity to summarize the principal milestones of Dunmore's cooperation to date, as reflect

III. Voluntary Disgorgement We further note that, on November 30, 2023, Dunmore made a voluntary disgorgement payment in the amount of $8,750,000 (eight million seven hundred fifty thousand dollars) to the United States Treasury. The disgorgement amount represents the estimated net profits derived by Dunmore from the nine tainted crude oil swap transactions identified in the Ridgeline forensic analysis. The calculati

IV. Summary of the Enhanced Program and Report Contents The enclosed Supplemental Remediation Report documents, in detail, the design, adoption, and full implementation of the Enhanced Sanctions & Export Controls Compliance Program. As set forth more fully in the Report, the Enhanced Program represents a comprehensive overhaul and strengthening of Dunmore's compliance infrastructure, tailored to address the specific

V. Benchmarking Against DOJ Guidance The Enhanced Program and the enclosed Report were developed and benchmarked against the DOJ's Evaluation of Corporate Compliance Programs (as updated in March 2023) and the DOJ Corporate Enforcement Policy (as updated in September 2022). In developing the Enhanced Program, Dunmore and its advisors carefully considered the criteria set forth in those guidance documents for evaluati

VI. Request for Consideration Toward Declination In light of the foregoing, we respectfully request that the DOJ consider the full scope of Dunmore's extraordinary cooperation, thorough remediation, and voluntary disgorgement in its evaluation of the appropriate resolution of this matter. We submit that the totality of Dunmore's conduct since the inception of the DOJ's inquiry warrants a declination of prosecution un

1. Timely Retention of Counsel and Prompt Investigation. Dunmore retained Calderwood & Harkness on April 14, 2022, just five days before the formal inception of the DOJ inquiry, and promptly commenced a comprehensive internal investigation that ultimately encompassed the review of over 2.3 million documents and 47 witness interviews across six jurisdictions.

2. Comprehensive and Timely Document Productions. Dunmore produced a total of 438,916 responsive documents to the DOJ in two productions, bearing Bates numbers DEH-DOJ-000001 through DEH-DOJ-438916. These productions were made on a rolling basis and were completed within approximately nine months of the issuance of the grand jury subpoena.

3. Full Witness Cooperation. Dunmore made its personnel, including cooperating witness Omar Al-Rashidi, available for government interviews and provided full and candid responses to all of the government's questions. Dunmore remains prepared to make its personnel available for any further interviews or testimony the government may request.

4. Voluntary Self-Disclosure to OFAC. Dunmore filed a voluntary self-disclosure with OFAC on June 1, 2023, disclosing the apparent violations identified through the internal investigation and demonstrating its commitment to transparency with all relevant regulatory authorities.

5. Voluntary Disgorgement. Dunmore made a voluntary disgorgement payment of $8.75 million to the U.S. Treasury on November 30, 2023, representing estimated net profits from the tainted crude oil swap transactions, made in good faith and without contest.

6. Thorough Remediation. Dunmore has implemented comprehensive remedial measures, including the separation of responsible individuals (Derek Hargrave and Natasha Sorokin), the appointment of a new Chief Compliance Officer (Priya Nayar) with a direct reporting line to the Board of Directors, and the design and full implementation of the Enhanced Sanctions & Export Controls Compliance Program, as documented in the encl

7. No Prior Violations. Dunmore has no prior history of sanctions or export control violations, enforcement actions, or criminal charges. The conduct at issue, while serious, represents a departure from Dunmore's otherwise clean compliance record. We believe that these factors, considered in their totality, satisfy the criteria for a declination under the DOJ Corporate Enforcement Policy and demonstrate that Dunmore

VII. Description of Enclosed Materials Enclosed with this letter, please find the following materials:

1. Supplemental Remediation Report to DOJ — Implementation Summary, prepared by Victoria Chambers and Conrad Reeves, Calderwood & Harkness LLP, dated January 15, 2024.

2. Appendices to the Supplemental Remediation Report, including: (a) Copy of the Board Resolution of Dunmore Energy Holdings Ltd., dated October 1, 2023, adopting the Enhanced Sanctions & Export Controls Compliance Program; (b) Summary of the Enhanced Sanctions & Export Controls Compliance Policy; (c) Training completion records for all relevant Dunmore personnel globally; and (d) Monitoring and testing framework doc

VIII. Closing Trial Attorney Samuel Kovacs and Trial Attorney Diana Pressman of the Counterintelligence and Export Control Section are copied on this letter, as indicated below. We trust that any communications regarding this letter or the enclosed Report may be directed to any of the recipients copied herein, as appropriate. This letter and the enclosed Report are submitted on a confidential basis. This letter const