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PRIVILEGED & CONFIDENTIAL ATTORNEY-CLIENT COMMUNICATION

CALDERWOOD & HARKNESS LLP Counselors at Law

400 Park Avenue, 28th Floor New York, NY 10022 Tel: (212) 555-0100

Fax: (212) 555-0101

www.calderwoodharkness.com

December 22, 2023

VIA Severin Partners LLC AND ELECTRONIC SUBMISSION (OFAC PORTAL)

Thomas W. Harrington Assistant Director, Enforcement Division Office of Foreign Assets Control U.S. Department of the Treasury 1500 Pennsylvania Avenue, NW Washington, DC 20220

Re: Supplemental Submission — Case No. VS-2023-04871 Dunmore Energy Holdings Ltd. / Dunmore Trading International Ltd.

Dear Mr. Harrington:

This firm represents Dunmore Energy Holdings Ltd. ("DEH"), a Cayman Islands exempted company limited by shares (EIN: 98-1347562), and its wholly owned subsidiary, Dunmore Trading International Ltd. ("DTI"), a private company limited by shares registered in England and Wales (Companies House No. 12849371), in connection with the above-referenced matter. We submit this supplemental response on behalf of DEH and DTI to address the letter dated November 29, 2023, from the Office of Foreign Assets Control ("OFAC"), Enforcement Division, requesting additional information in connection with Case No. VS-2023-04871.

As OFAC is aware, DEH and DTI filed an original voluntary self-disclosure ("VSD") on October 6, 2023, pursuant to 31 C.F.R. § 501.806, reporting certain transactions that may have constituted apparent violations of the sanctions regulations administered by OFAC. OFAC's November 29, 2023 letter identified five categories of additional information and documentation that OFAC requested in order to further evaluate the matters disclosed in the VSD. Each of those five requests is addressed in turn below, with supporting documents enclosed at the referenced tabs. DEH and DTI have endeavored to respond as comprehensively as possible and to provide all reasonably available documentation relevant to each request. To the extent OFAC identifies any additional areas of inquiry, DEH and DTI remain fully committed to cooperating with OFAC's review and will promptly supplement this submission as needed.

I. Wire Transfer Details (Response to OFAC Request No. 1)

OFAC's first request sought complete details regarding the five U.S. dollar-denominated wire transfers associated with the transactions reported in the VSD, including copies of all SWIFT messages, identification of all originating, intermediary, and receiving financial institutions, and confirmation of whether any U.S.-located financial institutions processed the transfers.

A. MT103 SWIFT Messages

Enclosed at Tab 1 are copies of the five MT103 SWIFT messages corresponding to the five USD wire transfers made in connection with Invoices CS-DTI-0091, CS-DTI-0094, CS-DTI-0101, CS-DTI-0108, and CS-DTI-0115. Each MT103 SWIFT message has been obtained directly from Ridgeline National Bank, N.A. ("Ridgeline"), DTI's U.S. banking institution, and the copies enclosed are unredacted, complete, and certified by Ridgeline's wire operations department as true and accurate reproductions of the original messages.

Each of the five SWIFT messages confirms that the respective wire transfer was originated by Emirates Gulf Commercial Bank, a commercial bank licensed and regulated in the United Arab Emirates, acting on behalf of Caspian Star Commodities DMCC ("Caspian Star"), a DMCC Free Zone Company registered at Unit 4412, Jumeirah Business Centre 1, Cluster G, Jumeirah Lakes Towers, Dubai, United Arab Emirates. Each SWIFT message further confirms that the wire transfer was received by Ridgeline National Bank, N.A., located at 700 Louisiana Street, Suite 4800, Houston, Texas 77002, for credit to DTI's USD-denominated operating account (Account No. XXXX-XXXX-7831). As reflected in the SWIFT messages and as confirmed by Ridgeline, no intermediary U.S. banks were involved in any of the five transfers. Each transfer was routed directly from Emirates Gulf Commercial Bank to Ridgeline through the SWIFT network without passing through any additional correspondent banking institutions.

B. Ridgeline National Bank Confirmation

Enclosed at Tab 1-A is a letter from Ridgeline National Bank, N.A., dated December 15, 2023, addressed to this firm and executed by Sarah Kling, Senior Vice President and Head of Compliance, Wire Operations Division. The Ridgeline letter confirms the following: (i) all five wire transfers identified in the table below were processed through Ridgeline's Houston, Texas operations center; (ii) the funds were received into DTI's USD operating account (Account No. XXXX-XXXX-7831) on the value dates reflected in the MT103 SWIFT messages; and (iii) no intermediary U.S. financial institutions were involved in the processing of any of the five transfers. The Ridgeline letter further confirms that Ridgeline has conducted an internal review of its records and has identified no additional wire transfers between Caspian Star Commodities DMCC (or any known alias or related entity) and any account maintained at Ridgeline by DTI or any other DEH affiliate.

C. Wire Transfer Summary

The following table summarizes the five wire transfers at issue. All data has been verified against the MT103 SWIFT messages enclosed at Tab 1:

These five transactions total $4,726,500.00 in aggregate. All payments were denominated in U.S. dollars and were processed through a U.S. financial institution (Ridgeline National Bank, N.A., Houston, Texas), thereby establishing the involvement of a U.S. person and the nexus to the United States relevant to OFAC's jurisdiction under 31 C.F.R. Part 594 and Executive Order 14024.

As set forth in the original VSD, Caspian Star Commodities DMCC was at all relevant times owned or controlled by Timur R. Kadyrov (date of birth: September 7, 1971; nationality: Russian Federation), who was designated as a Specially Designated National ("SDN") on March 18, 2022 (SDN Entry ID 47218; program tag: RUSSIA-EO14024), pursuant to Executive Order 14024 of April 15, 2021, "Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation." Kadyrov's designation was based on his status as a senior official and significant shareholder in entities operating in the energy sector of the Russian Federation economy. All five of the subject transactions occurred after the effective date of Kadyrov's SDN designation.

II. Beneficial Ownership Diligence (Response to OFAC Request No. 2)

OFAC's second request sought a detailed description of the beneficial ownership due diligence procedures that DTI applied to Caspian Star at the time of onboarding and at any subsequent review points, including an explanation of why those procedures did not identify Timur R. Kadyrov as a beneficial owner of Caspian Star.

A. Overview

Enclosed at Tab 2 is a detailed narrative description of DTI's beneficial ownership diligence procedures as they were applied at two relevant points in time: (a) the initial onboarding of Caspian Star on July 8, 2021, and (b) the annual re-screening of Caspian Star conducted in October 2022. The narrative enclosed at Tab 2 has been prepared by this firm based on DTI's internal records and on interviews conducted with relevant DTI personnel. The discussion below summarizes the key elements of that narrative.

B. Onboarding Procedures (July 2021)

Caspian Star was onboarded as a counterparty to DTI on July 8, 2021. At that time, DTI's counterparty onboarding procedure (governed by Version 2.4 of DTI's Global Sanctions Compliance Policy, then in effect) required the collection and review of the following documentation for all new counterparties:

(a) a completed Know Your Customer ("KYC") questionnaire, in the form prescribed by DTI's compliance department, requesting information regarding the counterparty's legal name, jurisdiction of formation, registered address, principal business activities, directors and officers, and ultimate beneficial ownership;

(b) corporate registry extracts from the relevant jurisdiction of incorporation or registration — in this case, a copy of Caspian Star's DMCC commercial license, which identified the entity's legal name, license number, registered office address, and authorized business activities;

(c) passport copies of all directors and shareholders holding twenty-five percent (25%) or more of the issued share capital or equivalent ownership interests in the counterparty; and

(d) a signed beneficial ownership declaration, in the form prescribed by DTI's compliance department, identifying all natural persons who directly or indirectly own or control twenty-five percent (25%) or more of the counterparty, or who otherwise exercise significant control over the counterparty.

The onboarding of Caspian Star was performed by DTI's London-based compliance team, located at DTI's principal office at 25 Finsbury Square, London EC2A 1PQ, United Kingdom. The compliance team was supported in this effort by DTI's then-outside trade compliance counsel, the law firm of Ashworth & Kline LLP, located at 10 Aldermanbury, London EC2V 7HR, United Kingdom. The engagement with Ashworth & Kline was led by Nigel Ashworth, the firm's senior partner and head of its international trade compliance practice. Ashworth & Kline reviewed the KYC documentation package submitted by Caspian Star and provided a compliance memorandum to DTI's compliance team advising that the documentation appeared complete and that no issues had been identified. A copy of Ashworth & Kline's compliance memorandum is included in the narrative at Tab 2.

The beneficial ownership declaration submitted in connection with Caspian Star's onboarding was signed by Farid Mammadov, identified as the Nominal Managing Director of Caspian Star Commodities DMCC. Mr. Mammadov's signed declaration, dated July 6, 2021, represented that Mr. Mammadov was the sole ultimate beneficial owner (100%) of Caspian Star Commodities DMCC. The declaration further represented that no other natural person directly or indirectly owned or controlled twenty-five percent (25%) or more of Caspian Star, and that no undisclosed arrangements (including nominee shareholder agreements, trust structures, or side agreements) existed with respect to the ownership or control of Caspian Star. A copy of Mr. Mammadov's signed beneficial ownership declaration is enclosed at Tab 2-A.

Following receipt and review of the KYC documentation, DTI's compliance team conducted sanctions screening on July 8 through July 12, 2021, using HCS ScreenPro (Version 4.1.7), an automated sanctions screening platform provided by Harborview Compliance Solutions Inc., a compliance technology firm headquartered at 2300 Clarendon Boulevard, Suite 700, Arlington, Virginia 22201. HCS ScreenPro Version 4.1.7 screened counterparty data against the following sanctions lists: (i) the OFAC Specially Designated Nationals and blocked Persons List (the "SDN List"); (ii) the European Union Consolidated Sanctions List; and (iii) the United Kingdom Office of Financial Sanctions Implementation ("OFSI") Consolidated List of Financial Sanctions Targets.

The HCS ScreenPro platform included a beneficial ownership module that cross-referenced the names of identified shareholders and beneficial owners (as provided in the counterparty's KYC documentation) against the applicable sanctions lists. However, the beneficial ownership module in Version 4.1.7 did not independently verify ownership claims through external corporate intelligence databases, adverse media searches, or other third-party data sources. The module relied exclusively on the information provided by the counterparty in the KYC questionnaire and beneficial ownership declaration.

The screening conducted on July 8–12, 2021 returned no matches for "Caspian Star Commodities DMCC" or "Farid Mammadov" against any of the three sanctions lists described above. Based on these results and the documentation reviewed, Caspian Star was assigned a "Standard Risk" rating under DTI's then-applicable risk classification framework.

It is critical to note that at the time of Caspian Star's onboarding in July 2021, Timur R. Kadyrov had not yet been designated by OFAC or by any other sanctions authority. Mr. Kadyrov's designation as an SDN did not occur until March 18, 2022, approximately eight months after Caspian Star's onboarding. Accordingly, even if DTI's screening procedures had been more expansive, a screening conducted in July 2021 would not have returned a sanctions match for Mr. Kadyrov.

C. Re-Screening Procedures (October 2022)

Effective January 1, 2022, DTI adopted Version 3.2 of its Global Sanctions Compliance Policy, which incorporated several enhancements to DTI's ongoing counterparty monitoring obligations. Among other changes, Policy Version 3.2 required annual re-screening of all active counterparties against the then-current sanctions lists maintained by OFAC, the EU, and the UK OFSI. Under the annual re-screening schedule, each counterparty was to be re-screened no later than the anniversary of its onboarding date.

The annual re-screening for Caspian Star was due by July 8, 2022 — one year from the date of Caspian Star's initial onboarding. However, the re-screening was delayed until October 2022 due to a compliance staffing vacancy within DTI's London-based compliance team. Specifically, the compliance analyst who had been assigned responsibility for counterparty re-screening departed DTI in June 2022, and the position was not filled until a replacement analyst began work on September 12, 2022. DTI acknowledges that this delay in re-screening fell below the standard set by its own internal policy and has since implemented measures to ensure that staffing vacancies do not result in similar delays in the future, as described in Section IV below.

When the re-screening was conducted in October 2022, DTI's compliance team re-ran the names "Caspian Star Commodities DMCC" and "Farid Mammadov" through HCS ScreenPro, which had by that time been updated to Version 4.2.3. No hits were returned. The failure to identify a sanctions nexus during the October 2022 re-screening was attributable to two factors:

(i) Although Timur R. Kadyrov had been designated as an SDN on March 18, 2022, the SDN List entry for Mr. Kadyrov did not at that time expressly identify Caspian Star Commodities DMCC as an entity owned or controlled by Mr. Kadyrov. The linkage between Mr. Kadyrov and Caspian Star was not reflected on the SDN List (or in OFAC's publicly available supplemental information) until OFAC's May 12, 2023 update. Consequently, a search for "Caspian Star Commodities DMCC" against the SDN List would not have returned a match to Mr. Kadyrov at any point prior to May 2023.

(ii) The beneficial ownership module within HCS ScreenPro Version 4.2.3, as with its predecessor version, relied on corporate registry data and counterparty-provided KYC documentation to determine beneficial ownership. The corporate registry data available to the platform at the time of the October 2022 re-screening continued to reflect Farid Mammadov as the 100% owner and sole beneficial owner of Caspian Star Commodities DMCC. HCS ScreenPro did not, at that time, incorporate independent third-party corporate intelligence data feeds that might have identified Mr. Kadyrov's undisclosed beneficial ownership interest.

Additionally, DTI did not re-collect the beneficial ownership declaration from Caspian Star at the time of the October 2022 re-screening. Under Policy Version 3.2, re-collection of the beneficial ownership declaration was required only upon a change in counterparty ownership that had been affirmatively reported by the counterparty. No such change had been reported by Caspian Star, and accordingly, the compliance team did not request an updated declaration. DTI now recognizes that this approach created a significant gap in its diligence framework, as it placed undue reliance on the counterparty's own representations without independent verification.

D. Current Enhanced Procedures (Post-Remediation)

As described in greater detail in Section IV below, DTI has since taken substantial remedial steps to address the deficiencies identified in its beneficial ownership diligence procedures. Most significantly, since August 1, 2023, DTI has upgraded its screening platform to HCS ScreenPro Version 5.0, which incorporates third-party corporate intelligence data feeds — including data provided by Meridian Corporate intelligence Ltd. — to independently verify beneficial ownership structures against sanctions lists. HCS ScreenPro Version 5.0 provides real-time monitoring and alerting when the ownership structures of previously screened entities change, enabling DTI's compliance team to identify sanctions risks on a dynamic, ongoing basis rather than relying solely on periodic re-screening cycles.

In addition, DTI has engaged Omnivael Global Advisors LLC, a specialized compliance advisory firm based in Arlington, Virginia, to conduct quarterly manual reviews of all counterparties classified as "Elevated Risk" or higher. These manual reviews include independent verification of beneficial ownership through open-source intelligence, commercial databases, and adverse media screening. The Overwatch engagement became effective on September 15, 2023, and the first quarterly review cycle was completed on December 1, 2023.

III. Prior Transactions (Response to OFAC Request No. 3)

OFAC's third request sought confirmation as to whether DEH, DTI, or any other DEH subsidiary had conducted any transactions with Caspian Star or any other entity associated with Timur R. Kadyrov outside of the five transactions reported in the VSD, and, if so, complete details regarding any such transactions.

A. Certification

Enclosed at Tab 3 is a signed certification from Gregor Albrecht, Managing Director of DTI, and Derek Huang, Chief Compliance Officer of DEH, executed under penalty of perjury pursuant to 28 U.S.C. § 1746. The certification confirms the following:

(a) Neither DTI nor any other DEH subsidiary conducted any transactions with Caspian Star Commodities DMCC prior to September 12, 2022 (the date of the first subject transaction, corresponding to Invoice CS-DTI-0091) or after January 23, 2023 (the date of the fifth and final subject transaction, corresponding to Invoice CS-DTI-0115). Although Caspian Star was onboarded as a counterparty in July 2021 and a 2021 ISDA Master Agreement was executed at that time, no trade confirmations were issued and no transactions were conducted under the Master Agreement until September 2022.

(b) A comprehensive search of all DEH group trading systems — including DTI's ETRM (Energy Trading and Risk Management) platform, DEH's consolidated accounting system, and the trading systems of all other DEH subsidiaries — has been conducted, covering the period from January 1, 2020 through the date of the certification. The search encompassed all known entities and individuals identified by OFAC as associated with Timur R. Kadyrov, including those listed in OFAC's May 12, 2023 SDN List update and any additional names identified through DTI's enhanced screening procedures. No transactions with any such entity or individual have been identified outside of the five transactions reported in the VSD.

(c) DTI's only contractual relationship with Caspian Star was governed by a 2021 ISDA Master Agreement (International Swaps and Derivatives Association form), together with a Schedule and five trade confirmations corresponding to the five subject transactions. The transactions involved the purchase by DTI of physical low-sulfur fuel oil, 380 CST grade, delivered FOB (free on board) Fujairah, United Arab Emirates, with payment in U.S. dollars by wire transfer to DTI's account at Ridgeline National Bank, N.A. All contractual relationships with Caspian Star have been terminated. DTI blocked all dealings with Caspian Star on June 5, 2023, within three business days of Derek Huang's discovery of the SDN link on June 2, 2023. The blocking was implemented through DTI's ETRM system and was confirmed by DTI's compliance team. Ridgeline National Bank was notified of the blocking on June 6, 2023, and has confirmed that no further transactions involving Caspian Star will be processed through DTI's accounts.

The certification was prepared in coordination with this firm and reflects the results of an extensive internal review conducted by DEH's and DTI's compliance, trading, and legal departments, with the assistance of external forensic accountants engaged by this firm. DEH and DTI stand behind the accuracy of the certification and will promptly notify OFAC if any additional information comes to light that is inconsistent with the representations contained therein.

IV. Remedial Measures Update (Response to OFAC Request No. 4)

OFAC's fourth request sought an update on the status of the remedial compliance measures referenced in Section IV.7 of the original VSD, together with supporting evidence of implementation.

A. Overview

Enclosed at Tab 4 is a detailed remediation status report addressing each compliance enhancement referenced in Section IV.7 of the original VSD. The remediation status report describes the steps that DEH and DTI have taken since the filing of the VSD to strengthen DTI's sanctions compliance program and to prevent the recurrence of the type of conduct reported in the VSD. Supporting evidence of implementation is included as sub-tabs within Tab 4. A summary of the key remedial measures follows.

B. Screening Technology Upgrade

DTI has completed the migration of its sanctions screening platform from HCS ScreenPro Version 4.2.3 to HCS ScreenPro Version 5.0, effective August 1, 2023. The upgrade to Version 5.0 was a critical component of the remedial program described in the VSD and represents a significant enhancement to DTI's screening capabilities. Version 5.0 incorporates an enhanced beneficial ownership module that integrates third-party corporate intelligence data feeds, including data provided by Meridian Corporate intelligence Ltd. ("Meridian"), a leading provider of corporate ownership and beneficial interest data covering more than 300 jurisdictions worldwide. The Meridian data feeds are updated daily and provide DTI's compliance team with access to corporate registry information, shareholder records, and beneficial ownership data that is independently sourced and verified by Meridian's research analysts.

In addition, HCS ScreenPro Version 5.0 provides real-time monitoring and alerting functionality. When the ownership structure of any previously screened entity changes — whether as reflected in corporate registry filings, commercial databases, or sanctions list updates — the system generates an automated alert to DTI's compliance team, triggering an immediate review. The platform independently verifies beneficial ownership claims against the OFAC SDN List, the EU Consolidated Sanctions List, and the UK OFSI Consolidated List of Financial Sanctions Targets, and extends its screening to cover entities subject to the OFAC 50 Percent Rule (31 C.F.R. § 587.309). Confirmation documentation from Harborview Compliance Solutions Inc. regarding the completed migration and the capabilities of Version 5.0 is enclosed at Tab 4.

C. Third-Party Manual Review

DTI has engaged Omnivael Global Advisors LLC ("Overwatch"), a specialized compliance advisory firm headquartered in Arlington, Virginia, to conduct quarterly manual reviews of DTI's counterparty portfolio, effective September 15, 2023. The engagement letter with Overwatch, a copy of which is enclosed at Tab 4, defines the scope of the quarterly reviews to include:

(i) independent verification of the beneficial ownership of all counterparties rated "Elevated Risk" or higher under DTI's risk classification framework, using open-source intelligence, commercial corporate intelligence databases, and non-public intelligence databases maintained by Overwatch;

(ii) comprehensive adverse media screening for all such counterparties, covering English-language and non-English-language media sources, regulatory enforcement actions, and litigation filings;

(iii) cross-referencing of all identified beneficial owners, directors, officers, and key personnel of such counterparties against the OFAC SDN List, the OFAC Sectoral Sanctions Identifications List, the EU Consolidated Sanctions List, the UK OFSI Consolidated List, and additional sanctions and watch lists maintained by the governments of Canada, Australia, Japan, and Switzerland; and

(iv) the preparation of a written report to DTI's compliance team and to DEH's Chief Compliance Officer summarizing the results of each quarterly review, identifying any counterparties for which ownership, sanctions, or adverse media concerns have been identified, and recommending any further investigative or remedial steps.

The first quarterly review cycle under the Overwatch engagement was completed on December 1, 2023. No new sanctions concerns were identified in connection with any of DTI's currently active counterparties. The Overwatch report for the first review cycle is included in the remediation status report at Tab 4.

D. Dedicated Sanctions Compliance Officer

DTI has appointed Kira Petrossian as DTI's dedicated Sanctions Compliance Officer, effective October 2, 2023. Ms. Petrossian is based in DTI's London office at 25 Finsbury Square, London EC2A 1PQ, and has direct reporting lines to both the DTI Managing Director, Gregor Albrecht, and the DEH Chief Compliance Officer, Derek Huang. This dual-reporting structure is designed to ensure that sanctions compliance matters receive appropriate attention at both the subsidiary and parent-company levels and that there is a clear and unimpeded escalation path for any sanctions-related concerns.

Ms. Petrossian brings more than twelve years of experience in sanctions compliance, having previously served as Deputy Head of Financial Sanctions Compliance at a major international bank and as a senior analyst in the UK HM Treasury's Office of Financial Sanctions Implementation. Her responsibilities at DTI include oversight of all sanctions screening and monitoring activities, management of the Overwatch engagement, review and approval of all new counterparty onboardings, and preparation of the quarterly sanctions compliance reports to the DEH Board of Directors described below. Ms. Petrossian's curriculum vitae is enclosed at Tab 4-A.

E. Policy Updates

DTI has adopted an updated version of its Global Sanctions Compliance Policy — Version 4.0, effective November 1, 2023. Policy Version 4.0 was developed with the assistance of this firm and reflects the lessons learned from the matters reported in the VSD. A complete copy of Policy Version 4.0 is enclosed at Tab 4-B. The key changes in Policy Version 4.0, as compared to the prior version (Version 3.2), include the following:

(i) Reduced Re-Screening Interval. The re-screening interval for all active counterparties has been reduced from annual to quarterly. Under Policy Version 4.0, every active counterparty is re-screened against all applicable sanctions lists no less frequently than once every calendar quarter. This is in addition to the real-time monitoring provided by HCS ScreenPro Version 5.0.

(ii) Mandatory Annual Re-Collection of Beneficial Ownership Declarations. Policy Version 4.0 requires mandatory re-collection of beneficial ownership declarations from all counterparties at least annually, regardless of whether the counterparty has reported a change in ownership. This requirement is designed to eliminate the gap identified in the VSD, where DTI's prior policy (Version 3.2) required re-collection only upon a counterparty-reported ownership change, thereby creating undue reliance on counterparty self-reporting.

(iii) Mandatory Escalation Protocol. Policy Version 4.0 introduces a mandatory escalation protocol under which any counterparty flagged by internal auditors, compliance analysts, external compliance advisors (including Overwatch), or any other source for any risk-related reason — including but not limited to sanctions risk, anti-money laundering risk, anti-bribery risk, or adverse media exposure — must undergo an immediate enhanced sanctions review. The enhanced review must be completed within five business days of the initial flag and must be documented in writing with a recommendation for continued engagement, enhanced monitoring, or termination of the counterparty relationship.

(iv) Documentation Requirements. Policy Version 4.0 requires that all screening results — including negative results (i.e., instances where no sanctions matches are identified) — be documented with date and time stamps and analyst sign-off. This requirement ensures a complete audit trail for all screening activities and facilitates regulatory inquiries.

(v) Board-Level Reporting. Policy Version 4.0 establishes a quarterly sanctions compliance reporting obligation to the DEH Board of Directors. The quarterly report, prepared by the Sanctions Compliance Officer (Ms. Petrossian) and reviewed by the Chief Compliance Officer (Mr. Huang), covers the results of all screening and monitoring activities conducted during the quarter, the status of any open sanctions investigations or inquiries, and any changes to the sanctions regulatory landscape that may affect DEH's or DTI's operations.

F. Training

DTI has completed a comprehensive mandatory sanctions compliance training program for all DTI trading and compliance personnel. The training was conducted between August 14, 2023 and October 31, 2023, and was attended by all fifty-six (56) employees identified as within the scope of the training requirement, representing 100% completion. The training was developed and delivered by this firm in collaboration with DTI's compliance team and covered the following topics:

(i) an overview of OFAC's sanctions programs, with particular emphasis on the Russia-related sanctions administered pursuant to Executive Order 14024 (program tag: RUSSIA-EO14024) and the 50 Percent Rule under 31 C.F.R. § 587.309;

(ii) red flags for sanctions evasion in the context of international commodities trading, including the use of nominee shareholders, shell companies, and complex ownership structures to conceal the involvement of designated persons;

(iii) beneficial ownership risks specific to the commodities trading industry, including the challenges associated with verifying ownership in jurisdictions with limited corporate transparency requirements;

(iv) DTI's internal escalation procedures for reporting suspected sanctions violations or compliance concerns, including the role and responsibilities of the newly appointed Sanctions Compliance Officer; and

(v) an overview of the potential civil and criminal penalties for sanctions violations under the International Emergency Economic Powers Act ("IEEPA"), 50 U.S.C. § 1705, and the practical implications of those penalties for individual employees.

A training log documenting attendance, completion dates, and employee sign-off for all fifty-six participants is enclosed at Tab 4-C.

V. Corporate Structure (Response to OFAC Request No. 5)

OFAC's fifth request sought a current organizational chart for DEH showing all direct and indirect subsidiaries, together with information regarding which subsidiaries maintain accounts at U.S. financial institutions and whether any such subsidiaries conducted transactions with Caspian Star or any entity associated with Timur R. Kadyrov.

A. Organizational Chart

Enclosed at Tab 5 is a current organizational chart for DEH showing all direct and indirect subsidiaries, prepared as of the date of this submission. The chart reflects the DEH corporate group as currently constituted and identifies each entity's jurisdiction of formation, principal office address, and primary business activities.

B. DEH Ownership and Principal Offices

DEH is majority-owned (68.4%) by Grandview Capital Partners LLC ("Grandview"), a Delaware limited liability company with principal offices at 600 Lexington Avenue, Suite 2200, New York, New York 10022. Grandview's investment in DEH is held through Grandview Energy Fund IV, LP, a Delaware limited partnership. The remaining 31.6% of DEH's equity is held by a combination of management shareholders and institutional co-investors, as detailed in the organizational chart at Tab 5.

DEH's registered address is 4th Floor, Harbour Place, 103 South Church Street, George Town, Grand Cayman KY1-1002, Cayman Islands. DEH's principal U.S. office is located at 1200 Travis Street, Suite 3400, Houston, Texas 77002. DEH reported fiscal year 2022 annual revenue of approximately $2.14 billion and employs approximately 3,800 individuals worldwide. DEH's operations span multiple business segments, including upstream oil and gas production in the Gulf of Mexico, West Africa, and Southeast Asia; physical commodities trading (through DTI); and renewable energy development (solar and wind) in the U.S. Southwest.

C. DTI

DTI (25 Finsbury Square, London EC2A 1PQ, United Kingdom) is identified on the organizational chart as the sole DEH subsidiary engaged in physical commodities trading. DTI's trading activities encompass crude oil, fuel oil, gasoil, and liquefied natural gas ("LNG"). DTI is the only DEH subsidiary that maintained any contractual or commercial relationship with Caspian Star Commodities DMCC, as confirmed in the certification enclosed at Tab 3.

D. Other DEH Subsidiaries with U.S. Bank Accounts

In addition to DTI, three other DEH subsidiaries maintain accounts at U.S. financial institutions. Each of these entities is identified below, together with a confirmation that none of them has engaged in commodities trading or has conducted any transactions with Caspian Star Commodities DMCC or any other entity associated with Timur R. Kadyrov:

(i) Dunmore upstream LLC — a Delaware limited liability company engaged in upstream oil and gas exploration and production in the Gulf of Mexico. Dunmore upstream LLC maintains an operating account at Ridgeline National Bank, N.A., Houston, Texas. A review of Dunmore upstream LLC's financial records has confirmed that this entity has not conducted any transactions with Caspian Star Commodities DMCC or any entity or individual identified as associated with Timur R. Kadyrov.

(ii) Dunmore Renewables Inc. — a Delaware corporation engaged in renewable energy development (solar and wind projects) in the U.S. Southwest. Dunmore Renewables Inc. maintains an operating account at Ridgeline National Bank, N.A., Houston, Texas. A review of Dunmore Renewables Inc.'s financial records has confirmed that this entity has not conducted any transactions with Caspian Star Commodities DMCC or any entity or individual identified as associated with Timur R. Kadyrov.

(iii) Dunmore Capital Services Ltd. — a Cayman Islands company that serves as the DEH group's centralized treasury and intercompany financing vehicle. Dunmore Capital Services Ltd. maintains a treasury account at Ridgeline National Bank, N.A., Houston, Texas. A review of Dunmore Capital Services Ltd.'s financial records has confirmed that this entity has not conducted any transactions with Caspian Star Commodities DMCC or any entity or individual identified as associated with Timur R. Kadyrov.

None of the three entities described above is engaged in commodities trading, and none has had any commercial relationship — directly or indirectly — with Caspian Star Commodities DMCC, Timur R. Kadyrov, or any entity known to be associated with Mr. Kadyrov.

Conclusion

DEH and DTI respectfully submit that this supplemental submission fully addresses all five categories of information and documentation requested in OFAC's November 29, 2023 letter. The enclosed materials, together with the narrative descriptions provided herein, are intended to give OFAC a comprehensive understanding of the relevant facts and circumstances, as well as the significant remedial steps that DEH and DTI have taken to strengthen their sanctions compliance program.

DEH and DTI wish to reaffirm their commitment to full and transparent cooperation with OFAC's review of this matter. Since the filing of the original VSD on October 6, 2023, DEH and DTI have devoted substantial resources to investigating the apparent violations, implementing comprehensive remedial measures, and responding promptly and thoroughly to OFAC's requests for additional information. DEH and DTI will continue to cooperate fully with OFAC throughout the pendency of this matter and will promptly supplement this submission if any additional information becomes available that is relevant to OFAC's review.

Should OFAC require any further information or documentation, or wish to discuss any aspect of this submission, we respectfully request that all communications regarding this matter be directed to the undersigned:

Priya Anand, Partner Calderwood & Harkness LLP 400 Park Avenue, 28th Floor New York, NY 10022 Telephone: (212) 555-0147

Email: p.anand@calderwoodharkness.com

We are available to meet with OFAC at its convenience to discuss this submission or any related matters.

Respectfully submitted,

CALDERWOOD & HARKNESS LLP

By: ________

Priya Anand Partner

Date: December 22, 2023

Enclosures:

Tab 1: MT103 SWIFT Messages (five transfers: RNB20220912-01, RNB20221003-01, RNB20221114-01, RNB20221219-01, RNB20230123-01)

Tab 1-A: Ridgeline National Bank, N.A. Confirmation Letter, dated December 15, 2023

Tab 2: Beneficial Ownership Diligence Narrative

Tab 2-A: Farid Mammadov Beneficial Ownership Declaration, dated July 6, 2021

Tab 3: Prior Transactions Certification (signed by Gregor Albrecht, Managing Director, DTI, and Derek Huang, Chief Compliance Officer, DEH)

Tab 4: Remediation Status Report

Tab 4-A: Kira Petrossian — Curriculum Vitae

Tab 4-B: DTI Global Sanctions Compliance Policy, Version 4.0 (effective November 1, 2023)

Tab 4-C: Training Log (56 employees; training period: August 14, 2023 – October 31, 2023)

Tab 5: DEH Corporate Organizational Chart (current as of December 22, 2023)

cc: Derek Huang, Chief Compliance Officer, Dunmore Energy Holdings Ltd. Gregor Albrecht, Managing Director, Dunmore Trading International Ltd. Kira Petrossian, Sanctions Compliance Officer, Dunmore Trading International Ltd.

SWIFT Reference No.	Value Date	Amount (USD)	Corresponding Invoice
RNB20220912-01	September 14, 2022	$1,135,000.00	CS-DTI-0091
RNB20221003-01	October 5, 2022	$987,500.00	CS-DTI-0094
RNB20221114-01	November 16, 2022	$842,000.00	CS-DTI-0101
RNB20221219-01	December 21, 2022	$1,012,000.00	CS-DTI-0108
RNB20230123-01	January 25, 2023	$750,000.00	CS-DTI-0115

PRIVILEGED & CONFIDENTIAL ATTORNEY-CLIENT COMMUNICATION
CALDERWOOD & HARKNESS LLP Counselors at Law
400 Park Avenue, 28th Floor New York, NY 10022 Tel: (212) 555-0100
Fax: (212) 555-0101
www.calderwoodharkness.com
December 22, 2023
VIA Severin Partners LLC AND ELECTRONIC SUBMISSION (OFAC PORTAL)
Thomas W. Harrington Assistant Director, Enforcement Division Office of Foreign Assets Control U.S. Department of the Treasury 1500 Pennsylvania Avenue, NW Washington, DC 20220
Re: Supplemental Submission — Case No. VS-2023-04871 Dunmore Energy Holdings Ltd. / Dunmore Trading International Ltd.
Dear Mr. Harrington:
This firm represents Dunmore Energy Holdings Ltd. ("DEH"), a Cayman Islands exempted company limited by shares (EIN: 98-1347562), and its wholly owned subsidiary, Dunmore Trading International Ltd. ("DTI"), a private company limited by shares registered in England and Wales (Companies House No. 12849371), in connection with the above-referenced matter. We submit this supplemental response on behalf of DEH and DTI to address the letter dated November 29, 2023, from the Office of Foreign Assets Control ("OFAC"), Enforcement Division, requesting additional information in connection with Case No. VS-2023-04871.
As OFAC is aware, DEH and DTI filed an original voluntary self-disclosure ("VSD") on October 6, 2023, pursuant to 31 C.F.R. § 501.806, reporting certain transactions that may have constituted apparent violations of the sanctions regulations administered by OFAC. OFAC's November 29, 2023 letter identified five categories of additional information and documentation that OFAC requested in order to further evaluate the matters disclosed in the VSD. Each of those five requests is addressed in turn below, with supporting documents enclosed at the referenced tabs. DEH and DTI have endeavored to respond as comprehensively as possible and to provide all reasonably available documentation relevant to each request. To the extent OFAC identifies any additional areas of inquiry, DEH and DTI remain fully committed to cooperating with OFAC's review and will promptly supplement this submission as needed.
I. Wire Transfer Details (Response to OFAC Request No. 1)
OFAC's first request sought complete details regarding the five U.S. dollar-denominated wire transfers associated with the transactions reported in the VSD, including copies of all SWIFT messages, identification of all originating, intermediary, and receiving financial institutions, and confirmation of whether any U.S.-located financial institutions processed the transfers.
A. MT103 SWIFT Messages
Enclosed at Tab 1 are copies of the five MT103 SWIFT messages corresponding to the five USD wire transfers made in connection with Invoices CS-DTI-0091, CS-DTI-0094, CS-DTI-0101, CS-DTI-0108, and CS-DTI-0115. Each MT103 SWIFT message has been obtained directly from Ridgeline National Bank, N.A. ("Ridgeline"), DTI's U.S. banking institution, and the copies enclosed are unredacted, complete, and certified by Ridgeline's wire operations department as true and accurate reproductions of the original messages.
Each of the five SWIFT messages confirms that the respective wire transfer was originated by Emirates Gulf Commercial Bank, a commercial bank licensed and regulated in the United Arab Emirates, acting on behalf of Caspian Star Commodities DMCC ("Caspian Star"), a DMCC Free Zone Company registered at Unit 4412, Jumeirah Business Centre 1, Cluster G, Jumeirah Lakes Towers, Dubai, United Arab Emirates. Each SWIFT message further confirms that the wire transfer was received by Ridgeline National Bank, N.A., located at 700 Louisiana Street, Suite 4800, Houston, Texas 77002, for credit to DTI's USD-denominated operating account (Account No. XXXX-XXXX-7831). As reflected in the SWIFT messages and as confirmed by Ridgeline, no intermediary U.S. banks were involved in any of the five transfers. Each transfer was routed directly from Emirates Gulf Commercial Bank to Ridgeline through the SWIFT network without passing through any additional correspondent banking institutions.
B. Ridgeline National Bank Confirmation
Enclosed at Tab 1-A is a letter from Ridgeline National Bank, N.A., dated December 15, 2023, addressed to this firm and executed by Sarah Kling, Senior Vice President and Head of Compliance, Wire Operations Division. The Ridgeline letter confirms the following: (i) all five wire transfers identified in the table below were processed through Ridgeline's Houston, Texas operations center; (ii) the funds were received into DTI's USD operating account (Account No. XXXX-XXXX-7831) on the value dates reflected in the MT103 SWIFT messages; and (iii) no intermediary U.S. financial institutions were involved in the processing of any of the five transfers. The Ridgeline letter further confirms that Ridgeline has conducted an internal review of its records and has identified no additional wire transfers between Caspian Star Commodities DMCC (or any known alias or related entity) and any account maintained at Ridgeline by DTI or any other DEH affiliate.
C. Wire Transfer Summary
The following table summarizes the five wire transfers at issue. All data has been verified against the MT103 SWIFT messages enclosed at Tab 1:
These five transactions total $4,726,500.00 in aggregate. All payments were denominated in U.S. dollars and were processed through a U.S. financial institution (Ridgeline National Bank, N.A., Houston, Texas), thereby establishing the involvement of a U.S. person and the nexus to the United States relevant to OFAC's jurisdiction under 31 C.F.R. Part 594 and Executive Order 14024.
As set forth in the original VSD, Caspian Star Commodities DMCC was at all relevant times owned or controlled by Timur R. Kadyrov (date of birth: September 7, 1971; nationality: Russian Federation), who was designated as a Specially Designated National ("SDN") on March 18, 2022 (SDN Entry ID 47218; program tag: RUSSIA-EO14024), pursuant to Executive Order 14024 of April 15, 2021, "Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation." Kadyrov's designation was based on his status as a senior official and significant shareholder in entities operating in the energy sector of the Russian Federation economy. All five of the subject transactions occurred after the effective date of Kadyrov's SDN designation.
II. Beneficial Ownership Diligence (Response to OFAC Request No. 2)
OFAC's second request sought a detailed description of the beneficial ownership due diligence procedures that DTI applied to Caspian Star at the time of onboarding and at any subsequent review points, including an explanation of why those procedures did not identify Timur R. Kadyrov as a beneficial owner of Caspian Star.
A. Overview
Enclosed at Tab 2 is a detailed narrative description of DTI's beneficial ownership diligence procedures as they were applied at two relevant points in time: (a) the initial onboarding of Caspian Star on July 8, 2021, and (b) the annual re-screening of Caspian Star conducted in October 2022. The narrative enclosed at Tab 2 has been prepared by this firm based on DTI's internal records and on interviews conducted with relevant DTI personnel. The discussion below summarizes the key elements of that narrative.
B. Onboarding Procedures (July 2021)
Caspian Star was onboarded as a counterparty to DTI on July 8, 2021. At that time, DTI's counterparty onboarding procedure (governed by Version 2.4 of DTI's Global Sanctions Compliance Policy, then in effect) required the collection and review of the following documentation for all new counterparties:
(a) a completed Know Your Customer ("KYC") questionnaire, in the form prescribed by DTI's compliance department, requesting information regarding the counterparty's legal name, jurisdiction of formation, registered address, principal business activities, directors and officers, and ultimate beneficial ownership;
(b) corporate registry extracts from the relevant jurisdiction of incorporation or registration — in this case, a copy of Caspian Star's DMCC commercial license, which identified the entity's legal name, license number, registered office address, and authorized business activities;
(c) passport copies of all directors and shareholders holding twenty-five percent (25%) or more of the issued share capital or equivalent ownership interests in the counterparty; and
(d) a signed beneficial ownership declaration, in the form prescribed by DTI's compliance department, identifying all natural persons who directly or indirectly own or control twenty-five percent (25%) or more of the counterparty, or who otherwise exercise significant control over the counterparty.
The onboarding of Caspian Star was performed by DTI's London-based compliance team, located at DTI's principal office at 25 Finsbury Square, London EC2A 1PQ, United Kingdom. The compliance team was supported in this effort by DTI's then-outside trade compliance counsel, the law firm of Ashworth & Kline LLP, located at 10 Aldermanbury, London EC2V 7HR, United Kingdom. The engagement with Ashworth & Kline was led by Nigel Ashworth, the firm's senior partner and head of its international trade compliance practice. Ashworth & Kline reviewed the KYC documentation package submitted by Caspian Star and provided a compliance memorandum to DTI's compliance team advising that the documentation appeared complete and that no issues had been identified. A copy of Ashworth & Kline's compliance memorandum is included in the narrative at Tab 2.
The beneficial ownership declaration submitted in connection with Caspian Star's onboarding was signed by Farid Mammadov, identified as the Nominal Managing Director of Caspian Star Commodities DMCC. Mr. Mammadov's signed declaration, dated July 6, 2021, represented that Mr. Mammadov was the sole ultimate beneficial owner (100%) of Caspian Star Commodities DMCC. The declaration further represented that no other natural person directly or indirectly owned or controlled twenty-five percent (25%) or more of Caspian Star, and that no undisclosed arrangements (including nominee shareholder agreements, trust structures, or side agreements) existed with respect to the ownership or control of Caspian Star. A copy of Mr. Mammadov's signed beneficial ownership declaration is enclosed at Tab 2-A.
Following receipt and review of the KYC documentation, DTI's compliance team conducted sanctions screening on July 8 through July 12, 2021, using HCS ScreenPro (Version 4.1.7), an automated sanctions screening platform provided by Harborview Compliance Solutions Inc., a compliance technology firm headquartered at 2300 Clarendon Boulevard, Suite 700, Arlington, Virginia 22201. HCS ScreenPro Version 4.1.7 screened counterparty data against the following sanctions lists: (i) the OFAC Specially Designated Nationals and blocked Persons List (the "SDN List"); (ii) the European Union Consolidated Sanctions List; and (iii) the United Kingdom Office of Financial Sanctions Implementation ("OFSI") Consolidated List of Financial Sanctions Targets.
The HCS ScreenPro platform included a beneficial ownership module that cross-referenced the names of identified shareholders and beneficial owners (as provided in the counterparty's KYC documentation) against the applicable sanctions lists. However, the beneficial ownership module in Version 4.1.7 did not independently verify ownership claims through external corporate intelligence databases, adverse media searches, or other third-party data sources. The module relied exclusively on the information provided by the counterparty in the KYC questionnaire and beneficial ownership declaration.
The screening conducted on July 8–12, 2021 returned no matches for "Caspian Star Commodities DMCC" or "Farid Mammadov" against any of the three sanctions lists described above. Based on these results and the documentation reviewed, Caspian Star was assigned a "Standard Risk" rating under DTI's then-applicable risk classification framework.
It is critical to note that at the time of Caspian Star's onboarding in July 2021, Timur R. Kadyrov had not yet been designated by OFAC or by any other sanctions authority. Mr. Kadyrov's designation as an SDN did not occur until March 18, 2022, approximately eight months after Caspian Star's onboarding. Accordingly, even if DTI's screening procedures had been more expansive, a screening conducted in July 2021 would not have returned a sanctions match for Mr. Kadyrov.
C. Re-Screening Procedures (October 2022)
Effective January 1, 2022, DTI adopted Version 3.2 of its Global Sanctions Compliance Policy, which incorporated several enhancements to DTI's ongoing counterparty monitoring obligations. Among other changes, Policy Version 3.2 required annual re-screening of all active counterparties against the then-current sanctions lists maintained by OFAC, the EU, and the UK OFSI. Under the annual re-screening schedule, each counterparty was to be re-screened no later than the anniversary of its onboarding date.
The annual re-screening for Caspian Star was due by July 8, 2022 — one year from the date of Caspian Star's initial onboarding. However, the re-screening was delayed until October 2022 due to a compliance staffing vacancy within DTI's London-based compliance team. Specifically, the compliance analyst who had been assigned responsibility for counterparty re-screening departed DTI in June 2022, and the position was not filled until a replacement analyst began work on September 12, 2022. DTI acknowledges that this delay in re-screening fell below the standard set by its own internal policy and has since implemented measures to ensure that staffing vacancies do not result in similar delays in the future, as described in Section IV below.
When the re-screening was conducted in October 2022, DTI's compliance team re-ran the names "Caspian Star Commodities DMCC" and "Farid Mammadov" through HCS ScreenPro, which had by that time been updated to Version 4.2.3. No hits were returned. The failure to identify a sanctions nexus during the October 2022 re-screening was attributable to two factors:
(i) Although Timur R. Kadyrov had been designated as an SDN on March 18, 2022, the SDN List entry for Mr. Kadyrov did not at that time expressly identify Caspian Star Commodities DMCC as an entity owned or controlled by Mr. Kadyrov. The linkage between Mr. Kadyrov and Caspian Star was not reflected on the SDN List (or in OFAC's publicly available supplemental information) until OFAC's May 12, 2023 update. Consequently, a search for "Caspian Star Commodities DMCC" against the SDN List would not have returned a match to Mr. Kadyrov at any point prior to May 2023.
(ii) The beneficial ownership module within HCS ScreenPro Version 4.2.3, as with its predecessor version, relied on corporate registry data and counterparty-provided KYC documentation to determine beneficial ownership. The corporate registry data available to the platform at the time of the October 2022 re-screening continued to reflect Farid Mammadov as the 100% owner and sole beneficial owner of Caspian Star Commodities DMCC. HCS ScreenPro did not, at that time, incorporate independent third-party corporate intelligence data feeds that might have identified Mr. Kadyrov's undisclosed beneficial ownership interest.
Additionally, DTI did not re-collect the beneficial ownership declaration from Caspian Star at the time of the October 2022 re-screening. Under Policy Version 3.2, re-collection of the beneficial ownership declaration was required only upon a change in counterparty ownership that had been affirmatively reported by the counterparty. No such change had been reported by Caspian Star, and accordingly, the compliance team did not request an updated declaration. DTI now recognizes that this approach created a significant gap in its diligence framework, as it placed undue reliance on the counterparty's own representations without independent verification.
D. Current Enhanced Procedures (Post-Remediation)
As described in greater detail in Section IV below, DTI has since taken substantial remedial steps to address the deficiencies identified in its beneficial ownership diligence procedures. Most significantly, since August 1, 2023, DTI has upgraded its screening platform to HCS ScreenPro Version 5.0, which incorporates third-party corporate intelligence data feeds — including data provided by Meridian Corporate intelligence Ltd. — to independently verify beneficial ownership structures against sanctions lists. HCS ScreenPro Version 5.0 provides real-time monitoring and alerting when the ownership structures of previously screened entities change, enabling DTI's compliance team to identify sanctions risks on a dynamic, ongoing basis rather than relying solely on periodic re-screening cycles.
In addition, DTI has engaged Omnivael Global Advisors LLC, a specialized compliance advisory firm based in Arlington, Virginia, to conduct quarterly manual reviews of all counterparties classified as "Elevated Risk" or higher. These manual reviews include independent verification of beneficial ownership through open-source intelligence, commercial databases, and adverse media screening. The Overwatch engagement became effective on September 15, 2023, and the first quarterly review cycle was completed on December 1, 2023.
III. Prior Transactions (Response to OFAC Request No. 3)
OFAC's third request sought confirmation as to whether DEH, DTI, or any other DEH subsidiary had conducted any transactions with Caspian Star or any other entity associated with Timur R. Kadyrov outside of the five transactions reported in the VSD, and, if so, complete details regarding any such transactions.
A. Certification
Enclosed at Tab 3 is a signed certification from Gregor Albrecht, Managing Director of DTI, and Derek Huang, Chief Compliance Officer of DEH, executed under penalty of perjury pursuant to 28 U.S.C. § 1746. The certification confirms the following:
(a) Neither DTI nor any other DEH subsidiary conducted any transactions with Caspian Star Commodities DMCC prior to September 12, 2022 (the date of the first subject transaction, corresponding to Invoice CS-DTI-0091) or after January 23, 2023 (the date of the fifth and final subject transaction, corresponding to Invoice CS-DTI-0115). Although Caspian Star was onboarded as a counterparty in July 2021 and a 2021 ISDA Master Agreement was executed at that time, no trade confirmations were issued and no transactions were conducted under the Master Agreement until September 2022.
(b) A comprehensive search of all DEH group trading systems — including DTI's ETRM (Energy Trading and Risk Management) platform, DEH's consolidated accounting system, and the trading systems of all other DEH subsidiaries — has been conducted, covering the period from January 1, 2020 through the date of the certification. The search encompassed all known entities and individuals identified by OFAC as associated with Timur R. Kadyrov, including those listed in OFAC's May 12, 2023 SDN List update and any additional names identified through DTI's enhanced screening procedures. No transactions with any such entity or individual have been identified outside of the five transactions reported in the VSD.
(c) DTI's only contractual relationship with Caspian Star was governed by a 2021 ISDA Master Agreement (International Swaps and Derivatives Association form), together with a Schedule and five trade confirmations corresponding to the five subject transactions. The transactions involved the purchase by DTI of physical low-sulfur fuel oil, 380 CST grade, delivered FOB (free on board) Fujairah, United Arab Emirates, with payment in U.S. dollars by wire transfer to DTI's account at Ridgeline National Bank, N.A. All contractual relationships with Caspian Star have been terminated. DTI blocked all dealings with Caspian Star on June 5, 2023, within three business days of Derek Huang's discovery of the SDN link on June 2, 2023. The blocking was implemented through DTI's ETRM system and was confirmed by DTI's compliance team. Ridgeline National Bank was notified of the blocking on June 6, 2023, and has confirmed that no further transactions involving Caspian Star will be processed through DTI's accounts.
The certification was prepared in coordination with this firm and reflects the results of an extensive internal review conducted by DEH's and DTI's compliance, trading, and legal departments, with the assistance of external forensic accountants engaged by this firm. DEH and DTI stand behind the accuracy of the certification and will promptly notify OFAC if any additional information comes to light that is inconsistent with the representations contained therein.
IV. Remedial Measures Update (Response to OFAC Request No. 4)
OFAC's fourth request sought an update on the status of the remedial compliance measures referenced in Section IV.7 of the original VSD, together with supporting evidence of implementation.
A. Overview
Enclosed at Tab 4 is a detailed remediation status report addressing each compliance enhancement referenced in Section IV.7 of the original VSD. The remediation status report describes the steps that DEH and DTI have taken since the filing of the VSD to strengthen DTI's sanctions compliance program and to prevent the recurrence of the type of conduct reported in the VSD. Supporting evidence of implementation is included as sub-tabs within Tab 4. A summary of the key remedial measures follows.
B. Screening Technology Upgrade
DTI has completed the migration of its sanctions screening platform from HCS ScreenPro Version 4.2.3 to HCS ScreenPro Version 5.0, effective August 1, 2023. The upgrade to Version 5.0 was a critical component of the remedial program described in the VSD and represents a significant enhancement to DTI's screening capabilities. Version 5.0 incorporates an enhanced beneficial ownership module that integrates third-party corporate intelligence data feeds, including data provided by Meridian Corporate intelligence Ltd. ("Meridian"), a leading provider of corporate ownership and beneficial interest data covering more than 300 jurisdictions worldwide. The Meridian data feeds are updated daily and provide DTI's compliance team with access to corporate registry information, shareholder records, and beneficial ownership data that is independently sourced and verified by Meridian's research analysts.
In addition, HCS ScreenPro Version 5.0 provides real-time monitoring and alerting functionality. When the ownership structure of any previously screened entity changes — whether as reflected in corporate registry filings, commercial databases, or sanctions list updates — the system generates an automated alert to DTI's compliance team, triggering an immediate review. The platform independently verifies beneficial ownership claims against the OFAC SDN List, the EU Consolidated Sanctions List, and the UK OFSI Consolidated List of Financial Sanctions Targets, and extends its screening to cover entities subject to the OFAC 50 Percent Rule (31 C.F.R. § 587.309). Confirmation documentation from Harborview Compliance Solutions Inc. regarding the completed migration and the capabilities of Version 5.0 is enclosed at Tab 4.
C. Third-Party Manual Review
DTI has engaged Omnivael Global Advisors LLC ("Overwatch"), a specialized compliance advisory firm headquartered in Arlington, Virginia, to conduct quarterly manual reviews of DTI's counterparty portfolio, effective September 15, 2023. The engagement letter with Overwatch, a copy of which is enclosed at Tab 4, defines the scope of the quarterly reviews to include:
(i) independent verification of the beneficial ownership of all counterparties rated "Elevated Risk" or higher under DTI's risk classification framework, using open-source intelligence, commercial corporate intelligence databases, and non-public intelligence databases maintained by Overwatch;
(ii) comprehensive adverse media screening for all such counterparties, covering English-language and non-English-language media sources, regulatory enforcement actions, and litigation filings;
(iii) cross-referencing of all identified beneficial owners, directors, officers, and key personnel of such counterparties against the OFAC SDN List, the OFAC Sectoral Sanctions Identifications List, the EU Consolidated Sanctions List, the UK OFSI Consolidated List, and additional sanctions and watch lists maintained by the governments of Canada, Australia, Japan, and Switzerland; and
(iv) the preparation of a written report to DTI's compliance team and to DEH's Chief Compliance Officer summarizing the results of each quarterly review, identifying any counterparties for which ownership, sanctions, or adverse media concerns have been identified, and recommending any further investigative or remedial steps.
The first quarterly review cycle under the Overwatch engagement was completed on December 1, 2023. No new sanctions concerns were identified in connection with any of DTI's currently active counterparties. The Overwatch report for the first review cycle is included in the remediation status report at Tab 4.
D. Dedicated Sanctions Compliance Officer
DTI has appointed Kira Petrossian as DTI's dedicated Sanctions Compliance Officer, effective October 2, 2023. Ms. Petrossian is based in DTI's London office at 25 Finsbury Square, London EC2A 1PQ, and has direct reporting lines to both the DTI Managing Director, Gregor Albrecht, and the DEH Chief Compliance Officer, Derek Huang. This dual-reporting structure is designed to ensure that sanctions compliance matters receive appropriate attention at both the subsidiary and parent-company levels and that there is a clear and unimpeded escalation path for any sanctions-related concerns.
Ms. Petrossian brings more than twelve years of experience in sanctions compliance, having previously served as Deputy Head of Financial Sanctions Compliance at a major international bank and as a senior analyst in the UK HM Treasury's Office of Financial Sanctions Implementation. Her responsibilities at DTI include oversight of all sanctions screening and monitoring activities, management of the Overwatch engagement, review and approval of all new counterparty onboardings, and preparation of the quarterly sanctions compliance reports to the DEH Board of Directors described below. Ms. Petrossian's curriculum vitae is enclosed at Tab 4-A.
E. Policy Updates
DTI has adopted an updated version of its Global Sanctions Compliance Policy — Version 4.0, effective November 1, 2023. Policy Version 4.0 was developed with the assistance of this firm and reflects the lessons learned from the matters reported in the VSD. A complete copy of Policy Version 4.0 is enclosed at Tab 4-B. The key changes in Policy Version 4.0, as compared to the prior version (Version 3.2), include the following:
(i) Reduced Re-Screening Interval. The re-screening interval for all active counterparties has been reduced from annual to quarterly. Under Policy Version 4.0, every active counterparty is re-screened against all applicable sanctions lists no less frequently than once every calendar quarter. This is in addition to the real-time monitoring provided by HCS ScreenPro Version 5.0.
(ii) Mandatory Annual Re-Collection of Beneficial Ownership Declarations. Policy Version 4.0 requires mandatory re-collection of beneficial ownership declarations from all counterparties at least annually, regardless of whether the counterparty has reported a change in ownership. This requirement is designed to eliminate the gap identified in the VSD, where DTI's prior policy (Version 3.2) required re-collection only upon a counterparty-reported ownership change, thereby creating undue reliance on counterparty self-reporting.
(iii) Mandatory Escalation Protocol. Policy Version 4.0 introduces a mandatory escalation protocol under which any counterparty flagged by internal auditors, compliance analysts, external compliance advisors (including Overwatch), or any other source for any risk-related reason — including but not limited to sanctions risk, anti-money laundering risk, anti-bribery risk, or adverse media exposure — must undergo an immediate enhanced sanctions review. The enhanced review must be completed within five business days of the initial flag and must be documented in writing with a recommendation for continued engagement, enhanced monitoring, or termination of the counterparty relationship.
(iv) Documentation Requirements. Policy Version 4.0 requires that all screening results — including negative results (i.e., instances where no sanctions matches are identified) — be documented with date and time stamps and analyst sign-off. This requirement ensures a complete audit trail for all screening activities and facilitates regulatory inquiries.
(v) Board-Level Reporting. Policy Version 4.0 establishes a quarterly sanctions compliance reporting obligation to the DEH Board of Directors. The quarterly report, prepared by the Sanctions Compliance Officer (Ms. Petrossian) and reviewed by the Chief Compliance Officer (Mr. Huang), covers the results of all screening and monitoring activities conducted during the quarter, the status of any open sanctions investigations or inquiries, and any changes to the sanctions regulatory landscape that may affect DEH's or DTI's operations.
F. Training
DTI has completed a comprehensive mandatory sanctions compliance training program for all DTI trading and compliance personnel. The training was conducted between August 14, 2023 and October 31, 2023, and was attended by all fifty-six (56) employees identified as within the scope of the training requirement, representing 100% completion. The training was developed and delivered by this firm in collaboration with DTI's compliance team and covered the following topics:
(i) an overview of OFAC's sanctions programs, with particular emphasis on the Russia-related sanctions administered pursuant to Executive Order 14024 (program tag: RUSSIA-EO14024) and the 50 Percent Rule under 31 C.F.R. § 587.309;
(ii) red flags for sanctions evasion in the context of international commodities trading, including the use of nominee shareholders, shell companies, and complex ownership structures to conceal the involvement of designated persons;
(iii) beneficial ownership risks specific to the commodities trading industry, including the challenges associated with verifying ownership in jurisdictions with limited corporate transparency requirements;
(iv) DTI's internal escalation procedures for reporting suspected sanctions violations or compliance concerns, including the role and responsibilities of the newly appointed Sanctions Compliance Officer; and
(v) an overview of the potential civil and criminal penalties for sanctions violations under the International Emergency Economic Powers Act ("IEEPA"), 50 U.S.C. § 1705, and the practical implications of those penalties for individual employees.
A training log documenting attendance, completion dates, and employee sign-off for all fifty-six participants is enclosed at Tab 4-C.
V. Corporate Structure (Response to OFAC Request No. 5)
OFAC's fifth request sought a current organizational chart for DEH showing all direct and indirect subsidiaries, together with information regarding which subsidiaries maintain accounts at U.S. financial institutions and whether any such subsidiaries conducted transactions with Caspian Star or any entity associated with Timur R. Kadyrov.
A. Organizational Chart
Enclosed at Tab 5 is a current organizational chart for DEH showing all direct and indirect subsidiaries, prepared as of the date of this submission. The chart reflects the DEH corporate group as currently constituted and identifies each entity's jurisdiction of formation, principal office address, and primary business activities.
B. DEH Ownership and Principal Offices
DEH is majority-owned (68.4%) by Grandview Capital Partners LLC ("Grandview"), a Delaware limited liability company with principal offices at 600 Lexington Avenue, Suite 2200, New York, New York 10022. Grandview's investment in DEH is held through Grandview Energy Fund IV, LP, a Delaware limited partnership. The remaining 31.6% of DEH's equity is held by a combination of management shareholders and institutional co-investors, as detailed in the organizational chart at Tab 5.
DEH's registered address is 4th Floor, Harbour Place, 103 South Church Street, George Town, Grand Cayman KY1-1002, Cayman Islands. DEH's principal U.S. office is located at 1200 Travis Street, Suite 3400, Houston, Texas 77002. DEH reported fiscal year 2022 annual revenue of approximately $2.14 billion and employs approximately 3,800 individuals worldwide. DEH's operations span multiple business segments, including upstream oil and gas production in the Gulf of Mexico, West Africa, and Southeast Asia; physical commodities trading (through DTI); and renewable energy development (solar and wind) in the U.S. Southwest.
C. DTI
DTI (25 Finsbury Square, London EC2A 1PQ, United Kingdom) is identified on the organizational chart as the sole DEH subsidiary engaged in physical commodities trading. DTI's trading activities encompass crude oil, fuel oil, gasoil, and liquefied natural gas ("LNG"). DTI is the only DEH subsidiary that maintained any contractual or commercial relationship with Caspian Star Commodities DMCC, as confirmed in the certification enclosed at Tab 3.
D. Other DEH Subsidiaries with U.S. Bank Accounts
In addition to DTI, three other DEH subsidiaries maintain accounts at U.S. financial institutions. Each of these entities is identified below, together with a confirmation that none of them has engaged in commodities trading or has conducted any transactions with Caspian Star Commodities DMCC or any other entity associated with Timur R. Kadyrov:
(i) Dunmore upstream LLC — a Delaware limited liability company engaged in upstream oil and gas exploration and production in the Gulf of Mexico. Dunmore upstream LLC maintains an operating account at Ridgeline National Bank, N.A., Houston, Texas. A review of Dunmore upstream LLC's financial records has confirmed that this entity has not conducted any transactions with Caspian Star Commodities DMCC or any entity or individual identified as associated with Timur R. Kadyrov.
(ii) Dunmore Renewables Inc. — a Delaware corporation engaged in renewable energy development (solar and wind projects) in the U.S. Southwest. Dunmore Renewables Inc. maintains an operating account at Ridgeline National Bank, N.A., Houston, Texas. A review of Dunmore Renewables Inc.'s financial records has confirmed that this entity has not conducted any transactions with Caspian Star Commodities DMCC or any entity or individual identified as associated with Timur R. Kadyrov.
(iii) Dunmore Capital Services Ltd. — a Cayman Islands company that serves as the DEH group's centralized treasury and intercompany financing vehicle. Dunmore Capital Services Ltd. maintains a treasury account at Ridgeline National Bank, N.A., Houston, Texas. A review of Dunmore Capital Services Ltd.'s financial records has confirmed that this entity has not conducted any transactions with Caspian Star Commodities DMCC or any entity or individual identified as associated with Timur R. Kadyrov.
None of the three entities described above is engaged in commodities trading, and none has had any commercial relationship — directly or indirectly — with Caspian Star Commodities DMCC, Timur R. Kadyrov, or any entity known to be associated with Mr. Kadyrov.
Conclusion
DEH and DTI respectfully submit that this supplemental submission fully addresses all five categories of information and documentation requested in OFAC's November 29, 2023 letter. The enclosed materials, together with the narrative descriptions provided herein, are intended to give OFAC a comprehensive understanding of the relevant facts and circumstances, as well as the significant remedial steps that DEH and DTI have taken to strengthen their sanctions compliance program.
DEH and DTI wish to reaffirm their commitment to full and transparent cooperation with OFAC's review of this matter. Since the filing of the original VSD on October 6, 2023, DEH and DTI have devoted substantial resources to investigating the apparent violations, implementing comprehensive remedial measures, and responding promptly and thoroughly to OFAC's requests for additional information. DEH and DTI will continue to cooperate fully with OFAC throughout the pendency of this matter and will promptly supplement this submission if any additional information becomes available that is relevant to OFAC's review.
Should OFAC require any further information or documentation, or wish to discuss any aspect of this submission, we respectfully request that all communications regarding this matter be directed to the undersigned:
Priya Anand, Partner Calderwood & Harkness LLP 400 Park Avenue, 28th Floor New York, NY 10022 Telephone: (212) 555-0147
Email: p.anand@calderwoodharkness.com
We are available to meet with OFAC at its convenience to discuss this submission or any related matters.
Respectfully submitted,
CALDERWOOD & HARKNESS LLP
By: ________
Priya Anand Partner
Date: December 22, 2023
Enclosures:
Tab 1: MT103 SWIFT Messages (five transfers: RNB20220912-01, RNB20221003-01, RNB20221114-01, RNB20221219-01, RNB20230123-01)
Tab 1-A: Ridgeline National Bank, N.A. Confirmation Letter, dated December 15, 2023
Tab 2: Beneficial Ownership Diligence Narrative
Tab 2-A: Farid Mammadov Beneficial Ownership Declaration, dated July 6, 2021
Tab 3: Prior Transactions Certification (signed by Gregor Albrecht, Managing Director, DTI, and Derek Huang, Chief Compliance Officer, DEH)
Tab 4: Remediation Status Report
Tab 4-A: Kira Petrossian — Curriculum Vitae
Tab 4-B: DTI Global Sanctions Compliance Policy, Version 4.0 (effective November 1, 2023)
Tab 4-C: Training Log (56 employees; training period: August 14, 2023 – October 31, 2023)
Tab 5: DEH Corporate Organizational Chart (current as of December 22, 2023)
cc: Derek Huang, Chief Compliance Officer, Dunmore Energy Holdings Ltd. Gregor Albrecht, Managing Director, Dunmore Trading International Ltd. Kira Petrossian, Sanctions Compliance Officer, Dunmore Trading International Ltd.
SWIFT Reference No. | Value Date | Amount (USD) | Corresponding Invoice
RNB20220912-01 | September 14, 2022 | $1,135,000.00 | CS-DTI-0091
RNB20221003-01 | October 5, 2022 | $987,500.00 | CS-DTI-0094
RNB20221114-01 | November 16, 2022 | $842,000.00 | CS-DTI-0101
RNB20221219-01 | December 21, 2022 | $1,012,000.00 | CS-DTI-0108
RNB20230123-01 | January 25, 2023 | $750,000.00 | CS-DTI-0115

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