PRIVILEGED AND CONFIDENTIAL / ATTORNEY WORK PRODUCT
[File copy — received from OFAC October 18, 2023; scanned and annotated by R. Jansen]
DEPARTMENT OF THE TREASURY
OFFICE OF FOREIGN ASSETS CONTROL
Washington, D.C. 20220
October 18, 2023
Priya Anand, Esq. Calderwood & Harkness LLP 400 Park Avenue, 28th Floor New York, NY 10022
Re: Voluntary Self-Disclosure Case No. VS-1014-00001 Dunmore Energy Holdings Ltd. / Dunmore Trading International Ltd.
Dear Ms. Anand:
This letter acknowledges receipt by the Office of Foreign Assets Control ("OFAC") of the voluntary self-disclosure ("VSD") submitted on October 6, 2023, on behalf of your clients, Dunmore Energy Holdings Ltd. and Dunmore Trading International Ltd. (collectively, the "Reporting Parties"). The submission has been assigned Case No. VS-1014-00001, and this case number should be used in all future correspondence and submissions relating to this matter.
OFAC will review the information and documentation provided in the VSD submission. During the course of its review, OFAC may contact you or your clients if additional information, documentation, or clarification is required. Any supplemental submissions, correspondence, or inquiries regarding this matter should reference Case No. VS-1014-00001 and should be directed to the Office of Foreign Assets Control, Compliance and Enforcement Division, U.S. Department of the Treasury, 1500 Pennsylvania Avenue NW, Washington, D.C. 20220.
Please be advised that the submission of a voluntary self-disclosure does not preclude OFAC from taking any enforcement action with respect to the apparent violations described therein, including, but not limited to, the imposition of civil monetary penalties pursuant to the applicable sanctions authorities, if such action is warranted based upon the facts and circumstances of the matter. OFAC will, however, afford the Reporting Parties credit for voluntary self-disclosure in a manner consistent with OFAC's Economic Sanctions Enforcement Guidelines, 31 C.F.R. Part 501, Appendix A, as applicable.
Sincerely,
[signature]
Andrea M. Gacki Director Office of Foreign Assets Control U.S. Department of the Treasury
[ANNOTATION — R. Jansen, 10/19/2023:]
1. Original letter received via Severin Partners LLC (tracking no. 7749-2081-4463) at Calderwood & Harkness LLP, New York office, on October 18, 2023. Letter scanned to PDF and filed in the firm's document management system under Matter No. 1016-00007 (Dunmore Energy Holdings Ltd. — OFAC VSD).
2. Per Priya Anand's instruction, copies of this acknowledgment letter were forwarded on October 19, 2023, to the following individuals at Dunmore Energy Holdings Ltd. ("DEH"):
• Marcus Whitfield, Senior Vice President & General Counsel, Dunmore Energy Holdings Ltd., 1200 Louisiana Street, Suite 3500, Houston, TX 77002 (via encrypted email and hard copy via overnight courier);
• Derek Huang, Chief Compliance Officer, Dunmore Energy Holdings Ltd., same address (via encrypted email and hard copy via overnight courier).
3. OFAC Case No. VS-1014-00001 has been confirmed and logged in the firm's docketing and case management system. All applicable follow-up and deadline reminders have been set; the matter has been tagged for ongoing monitoring of any supplemental information requests from OFAC.
4. This is the standard-form OFAC acknowledgment letter issued in connection with all voluntary self-disclosures received by the Compliance and Enforcement Division. The enforcement caveat language in the third paragraph is boilerplate that is included in every VSD acknowledgment and should not be interpreted as an indication that OFAC has made any preliminary determination regarding the likelihood or severity of enforcement action. No further substantive analysis from OFAC is expected at this stage.