Dear Meredith,
I am writing in connection with In re Dunmore Energy Holdings Ltd. (GJ No. 22-418) and on behalf of our client, Dunmore Energy Holdings Ltd. This email follows up on our discussion earlier this week regarding the Department's request to conduct a follow-up interview of Omar Al-Rashidi, Head of Middle East Operations at Dunmore Trading International Ltd.
**Proposed Date and Location**
We would like to propose **Wednesday, July 12, 2023** for the interview. We are happy to host the session at our Washington, D.C. office at 1750 Pennsylvania Avenue NW, Suite 800, Washington, DC 20006. We would suggest a 10:00 a.m. EDT start time, though we are flexible and can adjust to accommodate the government's schedule. We will arrange a conference room that provides appropriate privacy for the discussion.
**Participants — Defense Side**
I will attend as Responsible Partner, and Jasmine Thornton, our Lead Associate on this matter, will also be present and may ask follow-up questions as needed. As you are aware, Mr. Al-Rashidi is a current employee of Dunmore Trading International Ltd. and is represented in this matter by Calderwood & Harkness as counsel for the company. Mr. Al-Rashidi has been advised of the Upjohn distinction and understands the nature of the firm's representation.
I want to confirm that Mr. Al-Rashidi has been cooperative throughout the course of this investigation and remains willing to provide full and candid responses to the government's questions.
**Participants — Government Side**
Could you please confirm who from the government team will attend? We anticipate that you and Trial Attorney Kovacs will be present. We would also appreciate knowing whether Special Agent Paul Reinhardt (FBI Counterintelligence Division, Washington Field Office) or any other agents will participate, and whether Trial Attorney Diana Pressman will be joining as well.
**Logistical Considerations**
As you know, Mr. Al-Rashidi is currently based in Dubai, where he works out of Dunmore Trading International's offices at Level 14, Gate Building 3, DIFC. He will need to travel to Washington, D.C. for this interview, so we would appreciate confirmation of the proposed date as soon as practicable so that we can arrange his travel accordingly. We are prepared to coordinate his availability for a full day if the government anticipates that the session may require additional time.
**Anticipated Scope and Topics**
We understand the government wishes to follow up on topics covered during the internal investigation, including Mr. Al-Rashidi's knowledge of the trading desk operations, his observations regarding transactions with Petronova Trading FZE and Zenith Petroleum DMCC, and the counterparty relationships maintained by Derek Hargrave and Natasha Sorokin. Dunmore continues to cooperate fully, consistent with the cooperation framework established since the initial proffer on July 15, 2022. We will prepare Mr. Al-Rashidi for the interview in advance and are available to discuss any specific areas of inquiry the government would like to cover, should that be helpful.
**Ground Rules**
We would appreciate confirmation of the customary ground rules — namely, that the interview will be voluntary, not under oath (unless the government indicates otherwise), and that counsel for the company will be present throughout. For our part, the firm will not assert any privilege to obstruct the interview, and Dunmore has waived privilege selectively as previously agreed for purposes of cooperation with the Department.
**Investigation Status**
By way of brief update, as you are aware, we submitted the comprehensive 176-page internal investigation report to the Department on May 15, 2023, and the OFAC voluntary self-disclosure was filed on June 1, 2023. Dunmore's remediation efforts are ongoing under the supervision of Priya Nayar, who was appointed Chief Compliance Officer in August 2022, and with the assistance of Pemberton Investors Solutions LLC.
**Next Steps**
We would be grateful if you or Sam could confirm the July 12 date at your earliest convenience so that we can finalize Mr. Al-Rashidi's travel arrangements. Please do not hesitate to reach me directly at (202) 555-0143 if you would like to discuss any preliminary matters by phone.
Thank you, Meredith. We look forward to continuing to work with your team on this matter.
Best regards,
Victoria Chambers Partner, White Collar & Investigations Calderwood & Harkness LLP 1750 Pennsylvania Avenue NW, Suite 800 Washington, DC 20006 Tel: (202) 555-0143 vchambers@calderwoodharkness.com
Matter No. 1016-00009
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