PRIVILEGED AND CONFIDENTIAL — ATTORNEY-CLIENT COMMUNICATION
Derek, Gregor,
I hope you are both well. I am writing to follow up on the call Priya Anand had with Marcus Whitfield yesterday (November 30) regarding the supplemental information request that OFAC issued in connection with Case No. VS-1014-00001.
As you are aware, OFAC's supplemental request is dated November 29, 2023, and carries a 30-day response deadline of December 29, 2023. To allow adequate time for internal review, quality control, and any necessary revisions before submission, Calderwood & Harkness is targeting a final submission date of December 22, 2023. That gives us a one-week buffer, but it means we need to move promptly on the underlying information collection.
The purpose of this email is to lay out the specific items OFAC has requested, assign collection responsibilities between you, and establish target delivery dates for each category. I have organized these by recipient below, with cross-references to the numbered categories in OFAC's letter. Please review carefully and let me know as soon as possible if any of the target dates present difficulties so that we can adjust accordingly.
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**I. ITEMS ASSIGNED TO DEREK HUANG (Dunmore Energy Holdings)**
**A. Remediation Status Update (OFAC Request #4)** **Target Delivery to C&H: December 8, 2023**
OFAC has asked for a comprehensive update on the remedial measures DEH and DTI have implemented since the apparent violations were identified. We will need the following from you:
1. **Screening Platform Upgrade.** Confirmation that Dunmore Trading International Ltd. ("DTI," Companies House No. 12849371, 25 Finsbury Square, London EC2A 1PQ) has migrated from the HCS ScreenPro platform provided by Harborview Compliance Solutions Inc. to either (a) the upgraded beneficial ownership screening module (we understand HCS ScreenPro was upgraded to Version 5.0, effective August 1, 2023) or (b) a new vendor entirely. Please confirm which path DTI took and provide any relevant documentation (e.g., updated service agreement, migration confirmation, or new vendor contract).
2. **Quarterly Manual Reviews.** Please confirm whether Omnivael Global Advisors LLC, which we understand was engaged effective September 15, 2023, is now conducting quarterly manual reviews of DTI's sanctions screening processes, and if so, please provide a copy of the engagement letter or statement of work.
3. **New Sanctions Compliance Officer.** We need the name, title, start date, and a brief biographical summary for DTI's new Sanctions Compliance Officer. Our understanding is that Kira Petrossian was hired in this role effective October 2, 2023. Please confirm and provide her bio.
4. **Updated Global Sanctions Compliance Policy.** A copy of the DTI Global Sanctions Compliance Policy, Version 4.0, effective November 1, 2023, reflecting the move to quarterly re-screening of all counterparties. If there are any companion procedures documents, please include those as well.
5. **Training Records.** Copies of all training records and certifications completed by DTI personnel since June 2023. We understand that sanctions compliance training was completed for 56 DTI personnel between August 14 and October 31, 2023. Please provide attendance rosters, training materials or syllabi, and any certificates of completion.
**B. Corporate Organizational Chart (OFAC Request #5)** **Target Delivery to C&H: December 11, 2023**
OFAC has requested a current organizational chart for Dunmore Energy Holdings Ltd. (registered in the Cayman Islands; principal office at 1200 Travis Street, Suite 3400, Houston, TX 77002) showing all direct and indirect subsidiaries. The chart must:
1. Clearly notate which entities engage in commodities trading. Our understanding is that DTI is the sole DEH subsidiary involved in commodities trading — please confirm.
2. Identify which subsidiaries maintain accounts at U.S. financial institutions. We are aware that the following entities hold accounts at Ridgeline National Bank, N.A. in Houston: - Dunmore upstream LLC - Dunmore Renewables Inc. - Dunmore Capital Services Ltd.
Please confirm this is a complete list and identify any additional subsidiaries with U.S. banking relationships.
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**II. ITEMS ASSIGNED TO GREGOR ALBRECHT (Dunmore Trading International)**
**A. SWIFT Messages / Wire Transfer Records (OFAC Request #1)** **Target Delivery to C&H: December 11, 2023**
OFAC has requested complete MT103 SWIFT messages for all five USD wire payments associated with the Caspian Star Commodities DMCC (Unit 4412, JBC 1, Cluster G, JLT, Dubai, UAE) relationship. These are as follows:
| No.
**Total: $4,726,500**
These payments were transmitted from Caspian Star's account at Emirates Gulf Commercial Bank (Dubai) to DTI's USD account at Ridgeline National Bank, N.A. (700 Louisiana Street, Suite 4800, Houston, TX 77002). The MT103s should be obtainable from Ridgeline.
In addition to the SWIFT messages, we need written confirmation from Ridgeline National Bank that these five transactions were processed through its U.S. (Houston) operations. If Ridgeline requires a formal request letter from Calderwood & Harkness to release these records, please let me know and I will prepare one promptly.
**B. Beneficial Ownership Diligence Procedures (OFAC Request #2)** **Target Delivery to C&H: December 8, 2023**
OFAC has asked for a detailed narrative description of DTI's beneficial ownership diligence procedures as they existed at two points in time:
1. **July 2021** — specifically as of July 8, 2021, when Caspian Star Commodities DMCC was onboarded as a counterparty. 2. **October 2022** — when DTI conducted its annual re-screening of Caspian Star. We understand this re-screening was originally scheduled for July 2022 but was delayed to October 2022 due to staffing shortages.
For each point in time, the narrative should address:
- The databases and screening tools used (i.e., HCS ScreenPro, provided by Harborview Compliance Solutions Inc.); - The screening parameters applied (e.g., match thresholds, lists screened against, depth of beneficial ownership inquiry); - Any beneficial ownership certifications or representations obtained from Caspian Star and/or its nominal managing director, Farid Mammadov; and - The role played by Ashworth & Kline LLP (10 Aldermanbury, London EC2V 7HR), which served as DTI's outside trade compliance counsel and supported the original screening in July 2021.
Please also locate and provide copies of any beneficial ownership certification forms signed by Caspian Star or Farid Mammadov at onboarding or at re-screening.
Gregor, I recognize that reconstructing these procedures, particularly the 2021 process, may require some digging. We are happy to assist with drafting the narrative once you have assembled the underlying facts and documents — please just get us the raw materials and we will work it into the format OFAC expects.
**C. Prior/Subsequent Transactions Confirmation (OFAC Request #3)** **Target Delivery to C&H: December 11, 2023**
OFAC has requested written confirmation that neither DTI nor any other DEH subsidiary transacted with Caspian Star Commodities DMCC or any entity associated with Timur R. Kadyrov (SDN Entry ID 47218, program RUSSIA-EO14024, date of birth September 7, 1971) before September 12, 2022 or after January 23, 2023.
We understand that DTI blocked Caspian Star in its systems on June 5, 2023, and that no transactions occurred after the final payment on January 23, 2023. Calderwood & Harkness will draft the confirmation letter for your review and signature, but we need you to first run a thorough search of all DTI and DEH subsidiary trading systems — including any archived or legacy platforms — to verify that no transactions with Caspian Star or any Kadyrov-associated entity occurred outside the September 2022 – January 2023 window. Please document the scope of your search (systems queried, date ranges, search terms) so that we can represent the methodology to OFAC.
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**III. PROPOSED CALLS**
To ensure we are all aligned and to walk through the OFAC request in detail, I would like to schedule two calls:
**Call 1: Monday, December 4, 2023** - **Time:** 9:00 AM EST / 2:00 PM GMT - **Participants:** Derek Huang, Gregor Albrecht, Priya Anand, Robert Jansen, Leila Nazari - **Purpose:** Detailed walkthrough of the OFAC supplemental request; discussion of any questions or concerns regarding the items outlined above
**Call 2: Tuesday, December 12, 2023** - **Time:** 10:00 AM EST / 3:00 PM GMT - **Purpose:** Follow-up review of all collected materials; identification of any gaps before C&H begins drafting the response
Please confirm your availability for both calls at your earliest convenience. If either date or time does not work, let me know and I will circulate alternatives.
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**IV. GENERAL INSTRUCTIONS**
As a reminder, please mark all communications — internal and external — relating to this matter as **"Privileged and Confidential — Attorney-Client Communication."** This applies to emails, memoranda, document transmittals, and any notes generated in connection with your collection efforts. If you have any doubt about whether a particular communication should be so marked, please err on the side of caution and reach out to me or Priya.
If any of the target dates above are problematic, please notify me as soon as possible so that we can adjust our internal timeline while preserving the December 22 submission target.
Thank you both for your prompt attention to this. We understand the volume of material involved and appreciate your cooperation in meeting these deadlines. Please do not hesitate to call or email with any questions.
Best regards,
Leila Nazari Associate Calderwood & Harkness LLP 400 Park Avenue, 28th Floor New York, NY 10022 Tel: (212) 555-0193 l.nazari@calderwoodharkness.com
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