Contract analysis

I. Upjohn / Corporate Miranda Warning At the outset of the interview, at approximately 9:30 a.m., Jasmine Thornton administered the Upjohn corporate Miranda warning to Ms. Sorokin in accordance with the Witness Interview Protocol dated April 18, 2022, prepared by Victoria Chambers. The warning was delivered orally and Ms. Sorokin was provided with a written copy of the warning for her reference. Ms. Sorokin was given

1. Calderwood & Harkness LLP represents Dunmore Energy Holdings Ltd. and its subsidiaries — not Ms. Sorokin individually. The firm's duties of loyalty and confidentiality run to the corporate client, and not to any individual employee, officer, or director.

2. The purpose of the interview is to gather facts in connection with the firm's internal investigation on behalf of Dunmore related to the DOJ inquiry concerning potential violations of U.S. sanctions laws and export control regulations. The interview is part of a broader fact-gathering effort and Ms. Sorokin's cooperation is requested in connection with that effort.

3. Communications during the interview are protected by Dunmore's attorney-client privilege, which belongs to Dunmore (not to Ms. Sorokin personally), and Dunmore may choose to waive that privilege and disclose the substance of the interview to the DOJ, OFAC, or other third parties at any time and in its sole discretion. Ms. Sorokin was advised that she should not assume that anything she says during the interview wi

4. Ms. Sorokin has the right to retain her own personal attorney at her own expense. Calderwood & Harkness cannot provide her with individual legal advice and is not in a position to advise her regarding any personal legal exposure she may have. She was encouraged to consider whether she wished to consult with personal counsel before or during the interview.

5. Dunmore expects Ms. Sorokin's full cooperation and truthful responses to all questions posed during the interview. Providing false or misleading information could have consequences including, but not limited to, disciplinary action up to and including termination of her employment. Ms. Sorokin stated that she understood all of the foregoing points. She confirmed that she wished to proceed with the interview withou

II. Background and Employment History Ms. Sorokin provided the following background and employment information in response to preliminary questions. Full Name: Natasha Sorokin. Citizenship: Russian-American dual national. Ms. Sorokin stated that she was born in St. Petersburg, Russia, and emigrated to the United States for university education. She became a naturalized United States citizen in approximately 2014. She

III. Organizational Structure and Reporting at DTI Ms. Sorokin was asked to describe the organizational and reporting structure at DTI's Dubai trading desk, with a particular focus on the individuals who were involved in or had visibility into the transactions at issue in the investigation. She described the following key individuals and their roles: • Derek Hargrave, President, DTI: Mr. Hargrave is the most senior e

IV. Relationship with Petronova Trading FZE and Sergei Volkov A. Introduction to Petronova Ms. Sorokin was asked to describe how DTI's business relationship with Petronova Trading FZE came about and the circumstances of her initial introduction to the entity. Ms. Sorokin stated that she first became aware of Petronova Trading FZE in approximately late 2019 or early 2020. Petronova is registered at Office 1407, Al Sha

V. Knowledge of Volkhov Industrial Group JSC Connections A. Direct Questions Regarding Volkhov Ms. Sorokin was asked directly whether she was aware of any connection — corporate, financial, or otherwise — between Petronova Trading FZE and Volkhov Industrial Group JSC, a Russian energy conglomerate headquartered at 12 Kutuzovsky Prospekt, Moscow 121248, Russia, and chaired by Arkady Volkhov. Ms. Sorokin initially stat

VI. The 14 Crude Oil Swap Transactions Ms. Sorokin was shown a schedule of the 14 crude oil swap transactions executed between June 2020 and February 2022 involving Petronova Trading FZE and Zenith Petroleum DMCC as counterparties. The schedule was prepared by Ridgeline Advisory Group LLC (Engagement No. RAG-2022-0319) and reflected a total notional value of approximately $218.7 million across the 14 transactions. Ms

1. Volkov would initiate contact and propose a deal, identifying the crude oil grade, approximate volume, proposed price or pricing formula, and delivery window. These initial contacts typically occurred via phone call or Meridian Services Inc. message.

2. Sorokin would assess prevailing market conditions, evaluate the proposed pricing against benchmark levels and DTI's current trading book, and negotiate specific terms with Volkov, including adjustments to price, volume, delivery dates, and demurrage provisions.

3. If the proposed terms were commercially attractive, Sorokin would present the deal to Derek Hargrave for approval. For transactions above the $10 million notional threshold, Hargrave's sign-off was required before the trade could be confirmed. Sorokin stated she presented the terms to Hargrave either verbally (in the office) or via a brief email summarizing the key commercial parameters.

4. Upon receiving Hargrave's approval, Sorokin would confirm the trade with Volkov and initiate the documentation process.

5. Deal confirmations, formal trade documentation, invoices, and shipping documents were handled by Yves Leclerc (logistics) and Rajesh Malhotra (finance/controller) in coordination with Petronova's back-office team. Ms. Sorokin stated that this deal flow was consistent across substantially all of the 14 transactions. She noted that some of the smaller transactions may have proceeded without formal email documentatio

VII. Use of Encrypted Messaging and Personal Communications Ms. Sorokin was asked about her use of communication channels for business purposes, with particular focus on the use of encrypted messaging applications and personal devices. Ms. Sorokin confirmed that she regularly communicated with Sergei Volkov via Meridian Services Inc., which is an end-to-end encrypted messaging application, in addition to DTI's offici

VIII. Oilfield Equipment Exports and Caspian Logistik GmbH Ms. Sorokin was asked about the oilfield equipment exports identified in the investigation, valued at approximately $12.4 million, which were facilitated through Caspian Logistik GmbH, a German logistics company registered at Mönckebergstraße 22, 20095 Hamburg, Germany, and managed by Klaus Weidemann. Ms. Sorokin stated that she was "peripherally aware" of so

IX. Payment Structuring and Crescent Commercial Bank Ms. Sorokin was asked about the payment flows identified by Ridgeline Advisory Group LLC in connection with the Petronova and Zenith Petroleum transactions. Specifically, she was asked about $34.2 million in payments across 127 individual transactions that were routed through intermediary accounts held at Crescent Commercial Bank PJSC (Al Maktoum Tower, DIFC, P.O.

X. Interactions with Gerald Fisk (Former CCO) and Compliance Function Ms. Sorokin was asked in detail about her interactions with Gerald Fisk, then-Chief Compliance Officer of Dunmore Energy Holdings Ltd. Mr. Fisk departed Dunmore on June 10, 2022, approximately one week after this interview. He subsequently retained Catherine Blackthorn of Blackthorn & Associates LLP, 700 Louisiana Street, Suite 4300, Houston, TX 77

XI. Interactions with Derek Hargrave Ms. Sorokin was asked about Derek Hargrave's involvement in and knowledge of the Petronova Trading FZE and Zenith Petroleum DMCC transactions. Ms. Sorokin stated that Hargrave approved all of the transactions at issue, either verbally or via email. She reiterated that transactions above the notional threshold required Hargrave's express sign-off, and she stated that she recalled p

XII. Interactions with Omar Al-Rashidi Ms. Sorokin was asked about Omar Al-Rashidi's involvement in and knowledge of the Petronova Trading FZE relationship and the transactions at issue. Ms. Sorokin stated that Al-Rashidi, in his capacity as Head of Middle East Operations, was aware of the Petronova relationship. She stated that Al-Rashidi participated in some introductory meetings with Sergei Volkov, consistent with

XIII. Sorokin's Assessment of Her Own Conduct At the conclusion of the substantive questioning, Ms. Sorokin was asked for her overall assessment of her conduct in connection with the Petronova and Zenith Petroleum transactions. Ms. Sorokin maintained that she acted in good faith throughout the relevant period and consistent with the prevailing practices on the DTI trading desk. She stated that she carried out her tra

XIV. Documents Referenced and Reviewed During Interview The following documents were referenced and/or reviewed by Ms. Sorokin during the course of the interview:

1. Schedule of 14 crude oil swap transactions (June 2020 – February 2022), reflecting a total notional value of approximately $218.7 million, prepared by Ridgeline Advisory Group LLC, Engagement No. RAG-2022-0319.

2. Select email correspondence between Natasha Sorokin and Sergei Volkov (Petronova Trading FZE), extracted from DTI's email systems and produced as part of the internal investigation document collection.

3. Select Meridian Services Inc. message exports from Ms. Sorokin's personal mobile device, collected pursuant to the litigation hold notice issued by Dunmore on April 20, 2022, and processed by Nexagen Analytics Inc. (Project No. NX-DEH-2204).

4. Petronova Trading FZE corporate documentation, including trade license and certificate of incorporation from the Jebel Ali Free Zone Authority.

5. Select wire transfer records from Crescent Commercial Bank PJSC, reflecting payments in connection with the transactions at issue.

6. Select bills of lading and cargo documentation for crude oil shipments associated with the Petronova and Zenith Petroleum transactions. Ms. Sorokin reviewed each document when presented and was asked questions based on the documents' contents. Her responses to document-specific questions are reflected in the substantive sections of this memorandum. ATTORNEY-CLIENT PRIVILEGED / ATTORNEY WORK PRODUCT / CONFIDENTIAL

XV. Credibility Assessment and Open Questions Credibility Observations Ms. Sorokin was generally responsive throughout the interview and provided detailed, coherent accounts of deal execution, the organizational structure at DTI, and the counterparty relationships at issue. She appeared to have a strong recollection of the trading mechanics and the commercial terms of the transactions, consistent with her role as the

1. Meridian Services Inc. Message Review: Full review of Meridian Services Inc. messages between Sorokin and Volkov to determine whether Volkhov Industrial Group connections, beneficial ownership, or sourcing arrangements were discussed directly in private communications. The messages processed by Nexagen Analytics Inc. (Project No. NX-DEH-2204) should be reviewed in their entirety, with particular attention to messa

2. Cross-Reference with Hargrave Interview: Cross-referencing Ms. Sorokin's account — including her statements regarding Hargrave's approval of all transactions, his encouragement of the Petronova relationship, and his meetings with Volkov — with Derek Hargrave's interview memorandum (conducted May 25, 2022, separately memorialized) to identify any inconsistencies or corroborative details.

3. Counterparty Onboarding Verification: Verification of Ms. Sorokin's claim that she submitted Petronova Trading FZE's corporate documentation to Gerald Fisk and the Houston compliance team for review and approval. This should include a search of Fisk's email records and the compliance function's files for any record of receipt, review, or clearance of Petronova documentation.

4. Zenith Petroleum / Farhan Qureshi Analysis: Further analysis of the specific transactions that Ms. Sorokin identified as involving Zenith Petroleum DMCC, and determination of Farhan Qureshi's relationship with Volkov, including any corporate, financial, or familial connections between Qureshi, Zenith Petroleum, and Volkhov-connected entities.

5. Al-Rashidi Debriefing Cross-Reference: Cross-referencing with Omar Al-Rashidi's debriefing and any subsequent DOJ interview to determine what he communicated regarding his mid-2021 statement about "Petronova's oil" being "Volkhov oil," whether he escalated the concern to anyone at Dunmore, and whether his account is consistent with Ms. Sorokin's recollection.

6. Trade Capture System Records: Review of DTI's trade capture system records to verify Hargrave's approval of each of the 14 transactions above the $10 million notional threshold, including whether approval was documented in the system or only communicated verbally.

7. Sorokin's Role Selection: Whether Ms. Sorokin's dual Russian-American nationality, her Russian-language fluency, and her prior professional experience in the Russian crude oil market played a role in her selection as the primary point of contact with Russian-origin counterparties, and whether this selection was a deliberate management decision by Hargrave or arose organically. ATTORNEY-CLIENT PRIVILEGED / ATTORNEY

XVI. Next Steps Based on the information obtained during this interview, the following next steps are recommended:

1. Second-Round Interview of Ms. Sorokin: A second-round interview of Ms. Sorokin is recommended after the completion of the full Meridian Services Inc. message review (Nexagen Analytics Inc., Project No. NX-DEH-2204) and the ongoing forensic accounting analysis by Ridgeline Advisory Group LLC (Engagement No. RAG-2022-0319). The second interview should focus on any communications or financial records that are inconsi

2. Jurisdictional Nexus Analysis: Coordinate with Conrad Reeves on whether Ms. Sorokin's specific trading activities — as a United States citizen — independently establish the jurisdictional nexus required for potential violations of the International Emergency Economic Powers Act, 50 U.S.C. §§ 1701–1706, regardless of DTI's Cayman Islands incorporation and UAE operational domicile. As a U.S. person, Ms. Sorokin is s

3. Personal Counsel Advisory: It is recommended that Ms. Sorokin be advised, through appropriate channels, that she may wish to retain personal counsel in light of the investigation's potential trajectory. Given the nature of the facts disclosed during this interview — including her role as the executing trader on all 14 transactions, her status as a U.S. citizen, and her acknowledged awareness of potential Volkhov c

4. Privilege and Distribution: This interview memorandum is to be maintained under attorney-client privilege and attorney work product protection. Distribution is limited to the Calderwood & Harkness LLP investigation team — specifically, Victoria Chambers, Howard Quinn, Conrad Reeves, Jasmine Thornton, Liam Donahue, and Nicholas Ferreira — and to Marcus Wellbourne, General Counsel of Dunmore Energy Holdings Ltd. It

XVII. Signatures / Distribution This memorandum was prepared by the undersigned and has been reviewed by the Responsible Partner prior to distribution. Prepared by: ________________________________________ Jasmine Thornton Lead Associate Calderwood & Harkness LLP ________________________________________ Liam Donahue Working Associate Calderwood & Harkness LLP Reviewed and Approved by: ________________________________