Contract analysis

I. EXECUTIVE SUMMARY Calderwood & Harkness LLP respectfully submits this White Paper on behalf of its client, Dunmore Energy Holdings Ltd. ("Dunmore," "DEH," or the "Company"), a Cayman Islands–domiciled exempted company with its operational headquarters located at 1200 McKinney Street, Suite 3400, Houston, Texas 77010. The purpose of this submission is to demonstrate that Dunmore has satisfied each and every prerequ

II. BACKGROUND A. Dunmore Energy Holdings Ltd. — Corporate Overview Dunmore Energy Holdings Ltd. is an exempted company incorporated with limited liability under the laws of the Cayman Islands, bearing Registration Number MC-334821. While domiciled in the Cayman Islands for corporate structuring purposes, Dunmore's operational headquarters are located at 1200 McKinney Street, Suite 3400, Houston, Texas 77010, and the

1. Crude Oil Swap Transactions Between approximately June 2020 and February 2022, DTI executed fourteen (14) crude oil swap transactions with two Dubai-based trading counterparties: Petronova Trading FZE (a free zone entity in Dubai; Managing Director Sergei Volkov) and Zenith Petroleum DMCC (a Dubai Multi Commodities Centre entity; Managing Director Farhan Qureshi). These fourteen transactions had a combined notiona

2. Oilfield Equipment Exports Between approximately August 2020 and January 2022, DTI facilitated the export of oilfield drilling equipment and components to end users in Russia. The equipment in question included items classified under Export Control Classification Numbers (ECCNs) 2B350 and 2B999 under the Commerce Control List, and had an aggregate value of approximately $12.4 million. These exports were routed thr

3. Payment Structuring Between approximately March 2020 and March 2022, a total of $34.2 million in payments was routed through a series of intermediary accounts maintained at Crescent Commercial Bank PJSC, a Dubai-based financial institution (Relationship Manager Khalid Mansour). These payments were distributed across one hundred twenty-seven (127) individual transactions. The structuring of these payments—through m

III. THE DOJ CORPORATE ENFORCEMENT POLICY — LEGAL FRAMEWORK A. Overview of the Policy This White Paper is submitted against the backdrop of the Department of Justice's Corporate Enforcement Policy, most recently updated in September 2022. The Policy represents the Department's articulation of the principles and standards that guide the exercise of prosecutorial discretion in matters involving corporate criminal condu

IV. APPLICATION TO DUNMORE — VOLUNTARY SELF-DISCLOSURE A. Prompt Internal Identification and Escalation Dunmore's response to the potential sanctions exposure was swift and decisive. Within five days of Volkhov's addition to the SDN List on April 6, 2022, Dunmore's then-Chief Compliance Officer, Gerald Fisk, identified the Company's potential historical exposure to Volkhov through the Petronova counterparty relations

V. APPLICATION TO DUNMORE — FULL COOPERATION A. Document Preservation and Production Dunmore's document preservation and production efforts have been comprehensive, timely, and well above the standard required for a finding of full cooperation. Preservation. Litigation hold notices were issued within one day of Calderwood & Harkness's retention — on April 20, 2022 — to all Dunmore entities globally. These hold notice

VI. APPLICATION TO DUNMORE — TIMELY AND APPROPRIATE REMEDIATION A. Personnel Actions Dunmore took swift and decisive personnel action against each of the three individuals identified as most responsible for the misconduct. These actions were taken promptly upon the identification of the individuals' roles and were not deferred pending the conclusion of the internal investigation or the government's inquiry. • Natasha