Contract analysis

I. Introduction and Purpose This letter supplements the initial proffer letter dated July 15, 2022, transmitted by the undersigned on behalf of Dunmore Energy Holdings Ltd. ("Dunmore" or "DEH") to your office in connection with the ongoing inquiry by the U.S. Department of Justice ("DOJ" or the "Department") into certain transactions involving Dunmore's Dubai-based trading subsidiary, Dunmore Trading International Lt

II. Background — Scope of the Forensic Investigation A. Retention of Ridgeline Advisory Group LLC At the direction of Calderwood & Harkness, Dunmore retained Ridgeline Advisory Group LLC, located at 1825 Connecticut Avenue NW, Suite 400, Washington, DC 20009, on May 2, 2022, to conduct a forensic accounting investigation into certain transaction flows involving DTI. The engagement is being led by Dr. Margaret Liu, CP

1. Trading Desk Records. Transaction records, trade confirmations, and settlement documentation from DTI's Dubai-based trading desk covering the period from March 2020 through April 2022. These records encompass the full universe of DTI's crude oil, refined products, and derivatives trading activity during the relevant period.

2. Banking Records. Wire transfer records and SWIFT messages from Crescent Commercial Bank PJSC ("Crescent" or "CCB"), located at Al Maktoum Tower, DIFC, P.O. Box 335102, Dubai, UAE. Crescent served as DTI's primary trade finance bank during the relevant period, with relationship management provided by Khalid Mansour, a Vice President in Crescent's Trade Finance Division. Ridgeline obtained and analyzed complete tran

3. Internal Financial Records. Accounts payable and accounts receivable ledgers maintained by Rajesh Malhotra, Controller of DTI. These records include journal entries, intercompany transfer documentation, and supporting invoices for the relevant period.

4. Shipping and Logistics Documentation. Shipping records, bills of lading, vessel charter party agreements, port clearance documents, and logistics coordination files maintained by Yves Leclerc, Director of Logistics & Shipping at DTI. These records document the physical movement of crude oil cargoes and oilfield equipment relevant to the transactions under review.

5. Corporate Registry and KYC Files. Corporate registry filings, beneficial ownership records, and know-your-customer ("KYC") files maintained by DTI's compliance function with respect to Petronova, Zenith Petroleum, and Caspian Logistik. These records include entity formation documents, shareholder registries, director appointments, and due diligence questionnaires completed by these counterparties.

6. E-discovery Corpus. An electronic discovery corpus collected and processed by Nexagen Analytics Inc. ("Nexagen") under Project No. NX-DEH-2204 (project manager: Brian Cavanaugh). Nexagen performed technology-assisted review ("TAR") of 2,347,812 documents collected from custodians and data sources across six jurisdictions: the Cayman Islands, the United Arab Emirates, the United States, Germany, Nigeria, and the Un

1. Derek Hargrave, former President of DTI. Mr. Hargrave was placed on administrative leave effective July 1, 2022, and was subsequently separated from Dunmore effective October 1, 2022. Mr. Hargrave is represented by James Overstreet of Overstreet & McClain PLLC, located in Dallas, Texas. Mr. Hargrave exercised direct supervisory authority over DTI's trading operations during the entirety of the relevant period and

2. Natasha Sorokin, former Senior Trader at DTI, a Russian-American dual national. Ms. Sorokin was placed on administrative leave effective May 16, 2022, and was separated from Dunmore effective September 15, 2022. Ms. Sorokin is represented by Philip Keane of Wexford Keane LLP, located in Washington, D.C. Ms. Sorokin served as the primary trader on the transactions at issue and maintained direct communications with

3. Omar Al-Rashidi, Head of Middle East Operations, DTI. Mr. Al-Rashidi remains employed by Dunmore and has been identified as a cooperating witness. Mr. Al-Rashidi has participated in witness interviews conducted by Calderwood & Harkness and has indicated his willingness to participate in a proffer session with your office at an appropriate time.

4. Rajesh Malhotra, Controller, DTI. Mr. Malhotra remains employed by Dunmore and has participated in witness interviews. Mr. Malhotra processed and authorized wire transfers that are the subject of the payment structuring analysis described in Section IV below.

5. Yves Leclerc, Director of Logistics & Shipping, DTI. Mr. Leclerc remains employed by Dunmore and has participated in witness interviews. Mr. Leclerc coordinated shipping and logistics arrangements for the oilfield equipment exports described in Section V below.

III. Summary of Forensic Findings — Crude Oil Swap Transactions A. Overview of the 14 Flagged Transactions Between June 2020 and February 2022, DTI's Dubai-based trading desk executed fourteen (14) crude oil swap transactions with a combined notional value of approximately $218.7 million. These transactions were identified in our initial proffer letter of July 15, 2022, as potentially problematic. Ridgeline's forensi

IV. Summary of Forensic Findings — Payment Structuring Through Crescent Commercial Bank A. Overview of Structured Payments In connection with its analysis of the crude oil swap transactions described in Section III above, Ridgeline identified approximately $34.2 million in payments that were routed through a series of intermediary accounts at Crescent Commercial Bank PJSC, Dubai. These payments spanned the period fro

V. Summary of Forensic Findings — Oilfield Equipment Exports A. Overview. In addition to the crude oil swap transactions and associated payment structuring described above, Ridgeline's forensic analysis identified a separate but related category of potentially problematic activity: the export of oilfield drilling equipment and components facilitated by DTI between August 2020 and January 2022. During this period, DTI

VI. Status of the Internal Investigation A. Witness Interviews Calderwood & Harkness's internal investigation has included an extensive program of witness interviews. As of the date of this letter, the Firm has completed the first round of witness interviews, consisting of twenty-two (22) interviews conducted between May 18 and June 30, 2022. The Firm is well into the second round of interviews, which commenced on Au

VII. Cooperation and Continued Commitment Dunmore wishes to reaffirm its unwavering commitment to full and transparent cooperation with the DOJ National Security Division and the Office of Foreign Assets Control ("OFAC") in connection with this matter. Since the inception of the DOJ inquiry in April 2022, Dunmore has demonstrated its commitment to cooperation through the following actions, among others: (i) Dunmore h

VIII. Reservation of Rights Dunmore reserves all applicable rights, privileges, and defenses, including but not limited to attorney-client privilege, attorney work product protections, joint defense and common interest protections, and any other protections afforded under applicable law. Nothing in this supplemental proffer letter or in Dunmore's cooperation with the Department shall be construed as a waiver of any s

IX. Closing and Contact Information We appreciate your office's continued professionalism and constructive engagement with Dunmore and Calderwood & Harkness throughout this investigation. We are prepared to meet with you and your colleagues at your earliest convenience to discuss the forensic findings summarized herein in further detail. We believe that an in-person meeting would be productive and would enable us to

X. Signature block Respectfully submitted, CALDERWOOD & HARKNESS LLP By: ________ Victoria Chambers Partner, White Collar & Investigations 1750 Pennsylvania Avenue NW, Suite 800 Washington, DC 20006 Telephone: (202) 555-7438 Email: vchambers@calderwoodharkness.com

XI. Enclosures The following materials are enclosed herewith. All enclosed materials are designated as attorney work product, prepared at the direction of counsel in furtherance of Dunmore's cooperation with the Department, and are provided on a selective-waiver basis to DOJ only, consistent with the protocol established on July 1, 2022. Enclosure A: Summary Transaction Schedule — Crude Oil Swap Transactions with Pet

XII. Distribution cc (via electronic transmission): Samuel Kovacs, Trial Attorney Counterintelligence and Export Control Section DOJ National Security Division Diana Pressman, Trial Attorney Counterintelligence and Export Control Section DOJ National Security Division bcc (internal distribution only — not transmitted to DOJ): Howard Quinn, Billing Partner, Calderwood & Harkness LLP Jasmine Thornton, Lead Associate, C