1016-00007 · Client 1016 · OFAC Filing

ofac-supplemental-request-annotated.docx DOCUMENT M&A / Corporate

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PRIVILEGED AND CONFIDENTIAL / ATTORNEY WORK PRODUCT

[File copy — received from OFAC November 29, 2023; scanned and annotated by L. Nazari]

DEPARTMENT OF THE TREASURY OFFICE OF FOREIGN ASSETS CONTROL Washington, D.C. 20220

November 29, 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., Request for Supplemental Information

Dear Ms. Anand:

The Office of Foreign Assets Control ("OFAC") has reviewed the voluntary self-disclosure ("VSD") filed on behalf of Dunmore Energy Holdings Ltd. ("DEH") and Dunmore Trading International Ltd. ("DTI") on October 6, 2023, and assigned Case No. VS-1014-00001. OFAC appreciates the cooperation of DEH and DTI in bringing this matter to our attention through the voluntary self-disclosure process.

In order to assist OFAC in its review and evaluation of the disclosed conduct, we request that you provide the following supplemental information and documentation on behalf of your clients. The specific items requested are set forth below.

1. Wire Transfer Details

For each of the five (5) U.S. dollar wire transfers referenced in the VSD — specifically, those payments processed through Ridgeline National Bank, N.A. in Houston, Texas, originating from the account of Caspian Star Commodities DMCC at Emirates Gulf Commercial Bank, Dubai, United Arab Emirates — please provide the following:

(a) The complete SWIFT message (MT103 or equivalent) for each wire transfer, including all fields reflecting the originator and originator's bank, the beneficiary and beneficiary's bank, any intermediary banks involved in the processing of the payment, the transaction amount, applicable currency code, and the value date for each transfer.

(b) Written confirmation from Ridgeline National Bank, N.A. that these five transactions were processed through its U.S. operations, including any internal transaction reference numbers assigned by Ridgeline National Bank, N.A. to each payment.

2. Beneficial Ownership Diligence

Please provide a detailed description of DTI's beneficial ownership diligence procedures as they existed at the following two points in time:

(a) As of the date of Caspian Star Commodities DMCC's initial onboarding as a counterparty of DTI (reported in the VSD as July 8, 2021); and

(b) As of the date of the October 2022 re-screening of Caspian Star Commodities DMCC referenced in the VSD.

In addition, with respect to each of the two dates identified above, please provide:

(a) A description of the specific databases, screening platforms, and other sources consulted in connection with the beneficial ownership diligence conducted at each date, including but not limited to the HCS ScreenPro platform operated by Harborview Compliance Solutions Inc., and any government or commercial sanctions lists, adverse media databases, corporate registry searches, or other due diligence tools utilized;

(b) A description of the screening parameters and match thresholds used at each date, including fuzzy-match percentage settings, alias configurations, transliteration protocols, and any filters or exclusion criteria applied during the screening process;

(c) Copies of any beneficial ownership certifications, representations, declarations, or questionnaires obtained from Caspian Star Commodities DMCC, its officers, or its principals — including, specifically, any such documents executed or provided by Farid Mammadov in his capacity as the nominal owner and/or managing director of Caspian Star Commodities DMCC — together with any internal memoranda or notes prepared by DTI personnel in connection with the review or evaluation of such certifications or representations.

3. Prior and Subsequent Transactions

Please confirm whether DTI or any other direct or indirect subsidiary of DEH conducted any transactions — including but not limited to purchases, sales, brokerage arrangements, agency transactions, financing, or other commercial dealings — with Caspian Star Commodities DMCC or any other entity owned or controlled by, or otherwise associated with, Timur R. Kadyrov (SDN Entry ID 47218; listed under program RUSSIA-EO14024; date of birth September 7, 1971):

(a) At any time prior to September 12, 2022, which is the date of the first subject transaction identified in the VSD (Invoice CS-DTI-0091); and

(b) At any time after January 23, 2023, which is the date of the fifth and final subject transaction identified in the VSD (Invoice CS-DTI-0115).

If any such transactions are identified, please provide complete details regarding the nature, value, counterparties, dates, and U.S. nexus (if any) of each such transaction, along with copies of all relevant documentation, including contracts, invoices, payment records, and shipping documents.

4. Remedial Measures Update

Please provide an update on the current status of the compliance enhancements described in Section IV.7 of the VSD. This update should include evidence of implementation of each measure referenced therein, including but not limited to the following:

(a) Confirmation of the upgrade to DTI's sanctions screening tool, including the identity of the upgraded platform, the date of implementation, and documentation reflecting the completion of the upgrade;

(b) Documentation relating to the hiring or appointment of a dedicated Sanctions Compliance Officer, as referenced in the VSD, including the date of hire, the individual's title, reporting line, and a summary of the individual's relevant qualifications and experience;

(c) Copies of any updated sanctions compliance policies, procedures, or internal controls that have been adopted or implemented by DEH, DTI, or any DEH subsidiary since the filing of the VSD, including any revisions to counterparty onboarding procedures, enhanced due diligence protocols, escalation procedures, and periodic re-screening schedules.

5. Corporate Structure

Please provide a current organizational chart for DEH showing all direct and indirect subsidiaries of DEH, including DTI, with the jurisdiction of incorporation or organization for each entity. Within this organizational chart or in an accompanying schedule, please identify:

(a) Any DEH subsidiary (direct or indirect) that engages in commodities trading, whether as a principal, agent, broker, or in any other capacity; and

(b) Any DEH subsidiary (direct or indirect) that maintains one or more accounts at a financial institution located in the United States, identifying the name of each such financial institution and the type of account maintained.

Please provide the requested information within thirty (30) days of the date of this letter (i.e., by no later than December 29, 2023). If you anticipate that you will be unable to provide any of the requested information within this timeframe, please contact the undersigned as soon as practicable to discuss an alternative schedule. OFAC appreciates the continued cooperation of DEH and DTI in this matter.

Sincerely,

/s/ Thomas W. Harrington

Thomas W. Harrington Assistant Director, Enforcement Division Office of Foreign Assets Control U.S. Department of the Treasury

[ANNOTATION — L. Nazari, 11/30/2023:]

Receipt and Filing: Letter received via Severin Partners LLC overnight delivery on November 29, 2023. Envelope postmarked November 29, 2023, from the Department of the Treasury, Office of Foreign Assets Control, Washington, D.C. 20220. Original letter scanned to PDF and uploaded to the firm's document management system on November 30, 2023. Hard copy placed in the correspondence sub-file for Matter No. 1016-00007.

Response Deadline: The letter imposes a thirty (30) day response deadline from the date of the letter. Based on the November 29, 2023 date, the calculated hard deadline is December 29, 2023.

Internal Target Submission Date: Per discussion with Priya Anand on the morning of November 30, 2023, the team will target submission of the supplemental response by December 22, 2023, in order to allow a one-week buffer before the hard OFAC deadline. If circumstances require, we retain the option of submitting up to and including December 29, 2023, but the strong preference is to avoid using the full window. If by December 15, 2023 it appears that the December 22 target is not achievable, Priya will evaluate whether to contact OFAC to request a brief extension or whether the remaining items can be finalized within the original timeframe.

Coordination Assignments — Items 1 through 3 and Item 5:

Coordination is needed with Derek Huang (Chief Compliance Officer, Dunmore Energy Holdings Ltd., London) and Gregor Albrecht (Managing Director, Dunmore Trading International Ltd., Geneva) for the following items:

Item 1 — Wire Transfer Details / MT103s: Gregor Albrecht to submit a request to Ridgeline National Bank, N.A. for certified copies of the complete SWIFT MT103 messages for each of the five subject wire transfers, along with written confirmation that the transactions were processed through Ridgeline's U.S. operations. If Ridgeline National Bank requires a formal request letter on outside counsel letterhead (which is common for U.S. banks responding to document requests in connection with regulatory matters), Calderwood & Harkness will prepare and transmit the letter directly to Ridgeline's legal or compliance department. Gregor to confirm Ridgeline's requirements by December 4, 2023 at the latest so that the formal request, if needed, can be sent no later than December 5, 2023. Allow 10–14 business days for Ridgeline's response. This is the tightest timeline item and should be treated as the critical path.

Item 2 — Beneficial Ownership Diligence: Gregor Albrecht to prepare a narrative description of DTI's beneficial ownership diligence procedures as they existed at the time of Caspian Star's onboarding (July 8, 2021) and at the time of the October 2022 re-screening. Gregor should pull and provide copies of the actual ScreenPro reports generated at each date, along with documentation of the match thresholds and screening parameters in effect at the time. In addition, Gregor to locate and produce copies of any beneficial ownership certifications or KYC questionnaires signed by Caspian Star Commodities DMCC or by Farid Mammadov as nominal owner and managing director. C&H will review the narrative and supporting documentation, supplement as needed, and prepare the final response. Gregor to provide initial materials by December 8, 2023.

Item 3 — Prior and Subsequent Transactions: Derek Huang and Gregor Albrecht to jointly confirm, via a comprehensive search of all DEH group trading systems (including the Axiom trade management platform and any legacy systems), whether DTI or any other DEH subsidiary conducted any transactions with Caspian Star Commodities DMCC, or with any other entity associated with Timur R. Kadyrov, (a) prior to September 12, 2022 (Invoice CS-DTI-0091) or (b) after January 23, 2023 (Invoice CS-DTI-0115). The search should cover all entity names and known aliases for both Caspian Star and Kadyrov. Derek and Gregor to provide a written confirmation of the search methodology and results by December 11, 2023.

Item 5 — Corporate Structure: Derek Huang to provide a current organizational chart for DEH reflecting all direct and indirect subsidiaries, including jurisdictions of incorporation. Derek to annotate or separately identify (a) which subsidiaries engage in any form of commodities trading and (b) which subsidiaries maintain accounts at U.S. financial institutions, specifying the bank name and account type for each. Derek to provide initial chart by December 6, 2023. C&H will review for completeness and formatting before inclusion in the response submission.

Item 4 — Remediation Update:

This item can be largely prepared from Calderwood & Harkness's own files, without significant additional input from the client, by reference to the following:

• The Compliance Enhancement Memorandum prepared by C&H and delivered to DEH and DTI, dated September 25, 2023;

• The implementation tracking spreadsheet maintained by the C&H project team, last updated November 15, 2023;

• Correspondence from Derek Huang dated October 18, 2023 confirming the hiring of Nadia Ferraro as dedicated Sanctions Compliance Officer (start date October 16, 2023, reporting to Derek);

• The revised DTI Sanctions Compliance Policy (Version 3.0), approved by the DTI Board on November 3, 2023;

• The Harborview Compliance Solutions Inc. confirmation letter dated October 27, 2023 regarding the upgrade from ScreenPro Standard to ScreenPro Enhanced, with expanded Russian-language transliteration capabilities and lowered fuzzy-match thresholds.

C&H to prepare a draft of the Item 4 response by December 8, 2023 for Priya's review.

Coordination Calls: Setting up two coordination calls:

• December 4, 2023 (Monday), 9:00 a.m. EST / 2:00 p.m. GMT / 3:00 p.m. CET — Initial coordination call with Derek Huang, Gregor Albrecht, and the C&H team (Priya Anand, L. Nazari, and associate TBD) to walk through each OFAC request item, confirm assignments and deadlines, and identify any anticipated obstacles.

• December 5, 2023 (Tuesday), 10:00 a.m. EST / 3:00 p.m. GMT / 4:00 p.m. CET — Follow-up call, if needed, to address the Ridgeline National Bank request process for Item 1 and any issues identified during the December 4 call.

Matter Filing: This annotated file copy is filed in Matter No. 1016-00007 (Dunmore Energy Holdings Ltd. — OFAC Voluntary Self-Disclosure).

Distribution: Copies of the OFAC letter (without this annotation) forwarded to Marcus Whitfield (Senior Vice President & General Counsel, Dunmore Energy Holdings Ltd., London) per Priya Anand's instruction, via encrypted email, on November 30, 2023. A copy of this annotated version is retained in the C&H working file only and has not been shared with the client.

PRIVILEGED AND CONFIDENTIAL / ATTORNEY WORK PRODUCT — This document and all annotations herein were prepared by and at the direction of counsel in anticipation of litigation and in connection with the provision of legal advice. Do not distribute outside of Calderwood & Harkness LLP without express authorization from the responsible partner.

PRIVILEGED AND CONFIDENTIAL / ATTORNEY WORK PRODUCT
[File copy — received from OFAC November 29, 2023; scanned and annotated by L. Nazari]
DEPARTMENT OF THE TREASURY OFFICE OF FOREIGN ASSETS CONTROL Washington, D.C. 20220
November 29, 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., Request for Supplemental Information
Dear Ms. Anand:
The Office of Foreign Assets Control ("OFAC") has reviewed the voluntary self-disclosure ("VSD") filed on behalf of Dunmore Energy Holdings Ltd. ("DEH") and Dunmore Trading International Ltd. ("DTI") on October 6, 2023, and assigned Case No. VS-1014-00001. OFAC appreciates the cooperation of DEH and DTI in bringing this matter to our attention through the voluntary self-disclosure process.
In order to assist OFAC in its review and evaluation of the disclosed conduct, we request that you provide the following supplemental information and documentation on behalf of your clients. The specific items requested are set forth below.
1. Wire Transfer Details
For each of the five (5) U.S. dollar wire transfers referenced in the VSD — specifically, those payments processed through Ridgeline National Bank, N.A. in Houston, Texas, originating from the account of Caspian Star Commodities DMCC at Emirates Gulf Commercial Bank, Dubai, United Arab Emirates — please provide the following:
(a) The complete SWIFT message (MT103 or equivalent) for each wire transfer, including all fields reflecting the originator and originator's bank, the beneficiary and beneficiary's bank, any intermediary banks involved in the processing of the payment, the transaction amount, applicable currency code, and the value date for each transfer.
(b) Written confirmation from Ridgeline National Bank, N.A. that these five transactions were processed through its U.S. operations, including any internal transaction reference numbers assigned by Ridgeline National Bank, N.A. to each payment.
2. Beneficial Ownership Diligence
Please provide a detailed description of DTI's beneficial ownership diligence procedures as they existed at the following two points in time:
(a) As of the date of Caspian Star Commodities DMCC's initial onboarding as a counterparty of DTI (reported in the VSD as July 8, 2021); and
(b) As of the date of the October 2022 re-screening of Caspian Star Commodities DMCC referenced in the VSD.
In addition, with respect to each of the two dates identified above, please provide:
(a) A description of the specific databases, screening platforms, and other sources consulted in connection with the beneficial ownership diligence conducted at each date, including but not limited to the HCS ScreenPro platform operated by Harborview Compliance Solutions Inc., and any government or commercial sanctions lists, adverse media databases, corporate registry searches, or other due diligence tools utilized;
(b) A description of the screening parameters and match thresholds used at each date, including fuzzy-match percentage settings, alias configurations, transliteration protocols, and any filters or exclusion criteria applied during the screening process;
(c) Copies of any beneficial ownership certifications, representations, declarations, or questionnaires obtained from Caspian Star Commodities DMCC, its officers, or its principals — including, specifically, any such documents executed or provided by Farid Mammadov in his capacity as the nominal owner and/or managing director of Caspian Star Commodities DMCC — together with any internal memoranda or notes prepared by DTI personnel in connection with the review or evaluation of such certifications or representations.
3. Prior and Subsequent Transactions
Please confirm whether DTI or any other direct or indirect subsidiary of DEH conducted any transactions — including but not limited to purchases, sales, brokerage arrangements, agency transactions, financing, or other commercial dealings — with Caspian Star Commodities DMCC or any other entity owned or controlled by, or otherwise associated with, Timur R. Kadyrov (SDN Entry ID 47218; listed under program RUSSIA-EO14024; date of birth September 7, 1971):
(a) At any time prior to September 12, 2022, which is the date of the first subject transaction identified in the VSD (Invoice CS-DTI-0091); and
(b) At any time after January 23, 2023, which is the date of the fifth and final subject transaction identified in the VSD (Invoice CS-DTI-0115).
If any such transactions are identified, please provide complete details regarding the nature, value, counterparties, dates, and U.S. nexus (if any) of each such transaction, along with copies of all relevant documentation, including contracts, invoices, payment records, and shipping documents.
4. Remedial Measures Update
Please provide an update on the current status of the compliance enhancements described in Section IV.7 of the VSD. This update should include evidence of implementation of each measure referenced therein, including but not limited to the following:
(a) Confirmation of the upgrade to DTI's sanctions screening tool, including the identity of the upgraded platform, the date of implementation, and documentation reflecting the completion of the upgrade;
(b) Documentation relating to the hiring or appointment of a dedicated Sanctions Compliance Officer, as referenced in the VSD, including the date of hire, the individual's title, reporting line, and a summary of the individual's relevant qualifications and experience;
(c) Copies of any updated sanctions compliance policies, procedures, or internal controls that have been adopted or implemented by DEH, DTI, or any DEH subsidiary since the filing of the VSD, including any revisions to counterparty onboarding procedures, enhanced due diligence protocols, escalation procedures, and periodic re-screening schedules.
5. Corporate Structure
Please provide a current organizational chart for DEH showing all direct and indirect subsidiaries of DEH, including DTI, with the jurisdiction of incorporation or organization for each entity. Within this organizational chart or in an accompanying schedule, please identify:
(a) Any DEH subsidiary (direct or indirect) that engages in commodities trading, whether as a principal, agent, broker, or in any other capacity; and
(b) Any DEH subsidiary (direct or indirect) that maintains one or more accounts at a financial institution located in the United States, identifying the name of each such financial institution and the type of account maintained.
Please provide the requested information within thirty (30) days of the date of this letter (i.e., by no later than December 29, 2023). If you anticipate that you will be unable to provide any of the requested information within this timeframe, please contact the undersigned as soon as practicable to discuss an alternative schedule. OFAC appreciates the continued cooperation of DEH and DTI in this matter.
Sincerely,
/s/ Thomas W. Harrington
Thomas W. Harrington Assistant Director, Enforcement Division Office of Foreign Assets Control U.S. Department of the Treasury
[ANNOTATION — L. Nazari, 11/30/2023:]
Receipt and Filing: Letter received via Severin Partners LLC overnight delivery on November 29, 2023. Envelope postmarked November 29, 2023, from the Department of the Treasury, Office of Foreign Assets Control, Washington, D.C. 20220. Original letter scanned to PDF and uploaded to the firm's document management system on November 30, 2023. Hard copy placed in the correspondence sub-file for Matter No. 1016-00007.
Response Deadline: The letter imposes a thirty (30) day response deadline from the date of the letter. Based on the November 29, 2023 date, the calculated hard deadline is December 29, 2023.
Internal Target Submission Date: Per discussion with Priya Anand on the morning of November 30, 2023, the team will target submission of the supplemental response by December 22, 2023, in order to allow a one-week buffer before the hard OFAC deadline. If circumstances require, we retain the option of submitting up to and including December 29, 2023, but the strong preference is to avoid using the full window. If by December 15, 2023 it appears that the December 22 target is not achievable, Priya will evaluate whether to contact OFAC to request a brief extension or whether the remaining items can be finalized within the original timeframe.
Coordination Assignments — Items 1 through 3 and Item 5:
Coordination is needed with Derek Huang (Chief Compliance Officer, Dunmore Energy Holdings Ltd., London) and Gregor Albrecht (Managing Director, Dunmore Trading International Ltd., Geneva) for the following items:
Item 1 — Wire Transfer Details / MT103s: Gregor Albrecht to submit a request to Ridgeline National Bank, N.A. for certified copies of the complete SWIFT MT103 messages for each of the five subject wire transfers, along with written confirmation that the transactions were processed through Ridgeline's U.S. operations. If Ridgeline National Bank requires a formal request letter on outside counsel letterhead (which is common for U.S. banks responding to document requests in connection with regulatory matters), Calderwood & Harkness will prepare and transmit the letter directly to Ridgeline's legal or compliance department. Gregor to confirm Ridgeline's requirements by December 4, 2023 at the latest so that the formal request, if needed, can be sent no later than December 5, 2023. Allow 10–14 business days for Ridgeline's response. This is the tightest timeline item and should be treated as the critical path.
Item 2 — Beneficial Ownership Diligence: Gregor Albrecht to prepare a narrative description of DTI's beneficial ownership diligence procedures as they existed at the time of Caspian Star's onboarding (July 8, 2021) and at the time of the October 2022 re-screening. Gregor should pull and provide copies of the actual ScreenPro reports generated at each date, along with documentation of the match thresholds and screening parameters in effect at the time. In addition, Gregor to locate and produce copies of any beneficial ownership certifications or KYC questionnaires signed by Caspian Star Commodities DMCC or by Farid Mammadov as nominal owner and managing director. C&H will review the narrative and supporting documentation, supplement as needed, and prepare the final response. Gregor to provide initial materials by December 8, 2023.
Item 3 — Prior and Subsequent Transactions: Derek Huang and Gregor Albrecht to jointly confirm, via a comprehensive search of all DEH group trading systems (including the Axiom trade management platform and any legacy systems), whether DTI or any other DEH subsidiary conducted any transactions with Caspian Star Commodities DMCC, or with any other entity associated with Timur R. Kadyrov, (a) prior to September 12, 2022 (Invoice CS-DTI-0091) or (b) after January 23, 2023 (Invoice CS-DTI-0115). The search should cover all entity names and known aliases for both Caspian Star and Kadyrov. Derek and Gregor to provide a written confirmation of the search methodology and results by December 11, 2023.
Item 5 — Corporate Structure: Derek Huang to provide a current organizational chart for DEH reflecting all direct and indirect subsidiaries, including jurisdictions of incorporation. Derek to annotate or separately identify (a) which subsidiaries engage in any form of commodities trading and (b) which subsidiaries maintain accounts at U.S. financial institutions, specifying the bank name and account type for each. Derek to provide initial chart by December 6, 2023. C&H will review for completeness and formatting before inclusion in the response submission.
Item 4 — Remediation Update:
This item can be largely prepared from Calderwood & Harkness's own files, without significant additional input from the client, by reference to the following:
• The Compliance Enhancement Memorandum prepared by C&H and delivered to DEH and DTI, dated September 25, 2023;
• The implementation tracking spreadsheet maintained by the C&H project team, last updated November 15, 2023;
• Correspondence from Derek Huang dated October 18, 2023 confirming the hiring of Nadia Ferraro as dedicated Sanctions Compliance Officer (start date October 16, 2023, reporting to Derek);
• The revised DTI Sanctions Compliance Policy (Version 3.0), approved by the DTI Board on November 3, 2023;
• The Harborview Compliance Solutions Inc. confirmation letter dated October 27, 2023 regarding the upgrade from ScreenPro Standard to ScreenPro Enhanced, with expanded Russian-language transliteration capabilities and lowered fuzzy-match thresholds.
C&H to prepare a draft of the Item 4 response by December 8, 2023 for Priya's review.
Coordination Calls: Setting up two coordination calls:
• December 4, 2023 (Monday), 9:00 a.m. EST / 2:00 p.m. GMT / 3:00 p.m. CET — Initial coordination call with Derek Huang, Gregor Albrecht, and the C&H team (Priya Anand, L. Nazari, and associate TBD) to walk through each OFAC request item, confirm assignments and deadlines, and identify any anticipated obstacles.
• December 5, 2023 (Tuesday), 10:00 a.m. EST / 3:00 p.m. GMT / 4:00 p.m. CET — Follow-up call, if needed, to address the Ridgeline National Bank request process for Item 1 and any issues identified during the December 4 call.
Matter Filing: This annotated file copy is filed in Matter No. 1016-00007 (Dunmore Energy Holdings Ltd. — OFAC Voluntary Self-Disclosure).
Distribution: Copies of the OFAC letter (without this annotation) forwarded to Marcus Whitfield (Senior Vice President & General Counsel, Dunmore Energy Holdings Ltd., London) per Priya Anand's instruction, via encrypted email, on November 30, 2023. A copy of this annotated version is retained in the C&H working file only and has not been shared with the client.
PRIVILEGED AND CONFIDENTIAL / ATTORNEY WORK PRODUCT — This document and all annotations herein were prepared by and at the direction of counsel in anticipation of litigation and in connection with the provision of legal advice. Do not distribute outside of Calderwood & Harkness LLP without express authorization from the responsible partner.

PRIVILEGED AND CONFIDENTIAL / ATTORNEY WORK PRODUCT

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