1016-00009 · Dunmore Energy Holdings · Subpoena Response & DOJ Correspondence

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CALDERWOOD & HARKNESS LLP Attorneys at Law

1750 Pennsylvania Avenue NW, Suite 800	Washington, DC 20006 Telephone: (202) 555-7400	Facsimile: (202) 555-7401 www.calderwoodharkness.com
NEW YORK	WASHINGTON, DC	LONDON	HONG KONG	SAN FRANCISCO	HOUSTON

July 15, 2022

CONFIDENTIAL — PROFFER MATERIAL This letter contains information provided pursuant to an oral proffer agreement between Dunmore Energy Holdings Ltd. and the U.S. Department of Justice. The contents of this letter are not to be construed as a waiver of attorney-client privilege or work product protections except as expressly stated herein. This letter is provided solely for the use of the addressee and authorized personnel within the U.S. Department of Justice and may not be disclosed to any third party without the prior written consent of Calderwood & Harkness LLP.

VIA HAND DELIVERY AND EMAIL

Meredith Calloway Assistant United States Attorney National Security Division Counterintelligence and Export Control Section U.S. Department of Justice 950 Pennsylvania Avenue NW Washington, DC 20530

Re: Dunmore Energy Holdings Ltd. — Grand Jury Subpoena No. GJ 22-418; Initial Proffer of Cooperation

Matter No.: 1016-00009

Dear Ms. Calloway:

We write on behalf of our client, Dunmore Energy Holdings Ltd. ("Dunmore" or "DEH"), a Cayman Islands exempted company with limited liability (registration no. MC-334821), with operational headquarters at 1200 McKinney Street, Suite 3400, Houston, Texas 77010, in connection with the inquiry opened by the U.S. Department of Justice ("DOJ") National Security Division on April 19, 2022. Calderwood & Harkness LLP ("Calderwood & Harkness" or the "Firm") serves as counsel to Dunmore in all matters arising from this inquiry.

This letter is submitted in reference to grand jury subpoena GJ No. 22-418, issued by the U.S. District Court for the District of Columbia (Grand Jury 22-2), bearing an original return date of May 19, 2022, which was subsequently extended by mutual agreement to July 19, 2022 to permit orderly collection, review, and production of responsive materials. The purpose of this letter is threefold: (1) to provide an initial proffer of Dunmore's cooperation with the DOJ's investigation; (2) to summarize the preliminary findings of the internal investigation that Calderwood & Harkness has been conducting on behalf of Dunmore since April 2022; and (3) to outline the anticipated next steps in Dunmore's ongoing cooperation.

This proffer is being made voluntarily and in good faith to demonstrate Dunmore's commitment to full cooperation with the DOJ. Dunmore's Board of Directors has authorized Calderwood & Harkness to provide the information set forth herein and to continue cooperating with the DOJ as the investigation proceeds. We emphasize that Dunmore's decision to make this proffer reflects the company's genuine desire to assist the Government in understanding the facts and circumstances surrounding the conduct at issue and to work constructively toward an appropriate resolution.

This proffer is subject to the terms of the oral proffer agreement discussed between the undersigned and you, Ms. Calloway, on June 28, 2022, and confirmed in subsequent communications. Dunmore expressly reserves all rights, including but not limited to the attorney-client privilege and work product protections, except as expressly waived herein. Nothing in this letter is intended to constitute, nor should it be construed as, an admission of liability or wrongdoing by Dunmore or any of its officers, directors, employees, or affiliates.

We note that this letter is being delivered in advance of, and is intended to serve as a framework for, the in-person proffer meeting being held concurrently on this date at the DOJ's offices in Washington, D.C. We look forward to discussing these matters in greater detail during that session with you, Trial Attorneys Samuel Kovacs and Diana Pressman, and Special Agent Paul Reinhardt of the Federal Bureau of Investigation.

I. Background on Dunmore Energy Holdings Ltd.

A. Corporate Overview

Dunmore Energy Holdings Ltd. is an exempted company incorporated with limited liability under the laws of the Cayman Islands. The company's registered office is located at Harbour Place, 4th Floor, 103 South Church Street, George Town, Grand Cayman KY1-1002, Cayman Islands. Dunmore maintains its operational headquarters at 1200 McKinney Street, Suite 3400, Houston, Texas 77010, United States, from which its senior management team directs the company's global operations.

Dunmore operates in the oil and gas exploration, production, and trading sectors, with an expanding portfolio in renewable energy development. The company's activities span multiple continents, including operations in North America, the Middle East, West Africa, and Europe. For fiscal year 2021, Dunmore reported annual revenue of approximately $4.87 billion, as reflected in audited financial statements prepared by Ashford & Whitmore LLP, the company's independent auditor. As of the date of this letter, Dunmore employs approximately 3,200 individuals across its global operations.

B. Ownership Structure

Dunmore's ownership structure is as follows:

• Majority Shareholder: Greystone Capital Partners Fund IV, L.P. holds a 62.5% equity interest in Dunmore. The general partner of Greystone Capital Partners Fund IV, L.P. is Greystone Capital Management LLC, which is managed by Richard Fairbanks, who serves as its Managing Member.

• Management Equity: Approximately 22.5% of Dunmore's equity is held by senior executives through management equity plans and direct ownership interests. The principal holders of management equity include Callum Renshaw (Chief Executive Officer), Sandra Whitfield (Chief Financial Officer), and certain other members of Dunmore's senior management team.

• Minority Shareholder: Thornbury Infrastructure Fund II, L.P. holds a 15% equity interest in Dunmore. Thornbury Infrastructure Fund II, L.P. is managed by Thornbury Asset Management Ltd., of which Helen Cresswell serves as Managing Director.

To our knowledge, neither Greystone Capital Partners Fund IV, L.P. nor Thornbury Infrastructure Fund II, L.P. had any involvement in or knowledge of the transactions that are the subject of this inquiry. Calderwood & Harkness has confirmed this through preliminary interviews with representatives of both funds, and we will supplement this proffer if our understanding changes.

C. Key Subsidiaries Relevant to the Inquiry

Dunmore operates through a number of subsidiaries and affiliated entities worldwide. The following subsidiaries are most directly relevant to the DOJ's inquiry:

1. Dunmore Trading International Ltd. ("DTI") — DTI is a limited company holding DIFC License No. CL-4827, with its principal office at Level 14, Gate Building 3, Dubai International Financial Centre, P.O. Box 506774, Dubai, United Arab Emirates. DTI operates Dunmore's overseas trading desk and is the primary entity involved in the transactions at issue in this inquiry. DTI was established in 2016 to centralize Dunmore's international commodities trading activities and has been responsible for the company's crude oil, refined products, and petrochemical trading operations in the Middle East, Central Asia, and parts of Europe.

2. Dunmore upstream Americas LLC ("DUA") — DUA is a Delaware limited liability company (EIN 84-2937561) with its principal office at 1200 McKinney Street, Suite 3400, Houston, Texas 77010. DUA manages Dunmore's upstream exploration and production activities in North and South America.

3. Dunmore Renewables GmbH — Dunmore Renewables GmbH is a company organized as a Gesellschaft mit beschränkter Haftung (GmbH) registered in Hamburg, Germany, with its office located at Überseeallee 12, 20457 Hamburg, Germany. Dunmore Renewables GmbH manages the company's European renewable energy development portfolio. This entity is tangentially involved in the inquiry due to its role in facilitating one suspect transaction involving oilfield equipment exports, as described in greater detail below.

4. Dunmore Exploration West Africa Ltd. — Dunmore Exploration West Africa Ltd. is a limited company with offices in Lagos, Nigeria, managing Dunmore's exploration and production activities in the West African region. While this entity is not believed to be directly involved in the conduct at issue, certain of its personnel may have peripheral knowledge of DTI's trading activities.

D. Key Individuals

The following individuals are relevant to the DOJ's inquiry and to the internal investigation being conducted by Calderwood & Harkness:

• Callum Renshaw — Chief Executive Officer, Dunmore Energy Holdings Ltd. Mr. Renshaw is based at Dunmore's operational headquarters in Houston, Texas, and has served as CEO since 2017. He has ultimate supervisory authority over all Dunmore operations, including those of DTI.

• Derek Hargrave — President, Dunmore Trading International Ltd. Mr. Hargrave is based in Dubai, UAE, and supervised DTI's trading desk from 2017 through the present. Mr. Hargrave was placed on paid administrative leave effective July 1, 2022, following the identification of his potential involvement in the conduct at issue.

• Natasha Sorokin — Senior Trader, DTI. Ms. Sorokin is a Russian-American dual national based in Dubai, UAE. She is a key individual in the transactions at issue and was placed on paid administrative leave effective May 16, 2022.

• Omar Al-Rashidi — Head of Middle East Operations, DTI. Mr. Al-Rashidi is based in Dubai and has been cooperating internally with the Calderwood & Harkness investigation. He has provided information regarding DTI's counterparty relationships and trading practices.

• Yves Leclerc — Director of Logistics & Shipping, DTI. Mr. Leclerc is a French national based in Dubai. He was responsible for coordinating shipments, including certain oilfield equipment exports that are the subject of this inquiry.

• Gerald Fisk — Former Chief Compliance Officer of DEH. Mr. Fisk initially identified the potential exposure that gave rise to Dunmore's retention of Calderwood & Harkness. Mr. Fisk departed the company on June 10, 2022, and is currently represented by Catherine Blackthorn of Blackthorn & Associates LLP, located at 700 Louisiana Street, Suite 4300, Houston, Texas 77002.

• Marcus Wellbourne — General Counsel, Dunmore Energy Holdings Ltd. Mr. Wellbourne is based in Houston and has been coordinating with Calderwood & Harkness on all aspects of the internal investigation and the DOJ inquiry.

• Sandra Whitfield — Chief Financial Officer, Dunmore Energy Holdings Ltd. Ms. Whitfield is based in Houston and oversees all financial operations, including those of DTI.

• Rajesh Malhotra — Controller, DTI. Mr. Malhotra is based in Dubai and was responsible for processing and approving wire transfers related to DTI's trading activities. His knowledge and role in the suspect transactions are currently being assessed.

• Tobias Engel — Managing Director, Dunmore Renewables GmbH. Mr. Engel is based in Hamburg, Germany, and had a degree of involvement in certain oilfield equipment export transactions that are under review.

II. Dunmore's Commitment to Cooperation

A. Statement of Cooperation Principles

Dunmore is committed to full, timely, and transparent cooperation with the DOJ's National Security Division and with the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") in connection with this inquiry. Dunmore's Board of Directors, with the full support of its majority shareholder, Greystone Capital Partners Fund IV, L.P., has directed Calderwood & Harkness to provide all non-privileged factual information that may be relevant to the Government's investigation.

Dunmore's cooperation is guided by the principles articulated in the DOJ Corporate Enforcement Policy, formerly known as the "Filip Factors," and as reflected in the Department's guidance on the Evaluation of Corporate Compliance Programs (updated June 2020). Dunmore understands that its level of cooperation, including the timeliness, completeness, and quality of its disclosures, will be considered by the DOJ in determining the appropriate resolution of this matter, and Dunmore intends to cooperate voluntarily and proactively beyond the minimum requirements of grand jury subpoena GJ No. 22-418.

To that end, Dunmore has authorized Calderwood & Harkness to share factual information with the DOJ on a rolling basis as the internal investigation progresses, to make witnesses available for Government interviews upon reasonable request, and to disclose the results of the company's forensic accounting analysis as those results become available. Dunmore has further committed to preserving all potentially relevant documents and data and to implementing any remedial measures that may be warranted by the findings of the internal investigation.

B. Steps Taken to Date Demonstrating Cooperation

Since the inception of this matter, Dunmore has taken numerous concrete steps to demonstrate its commitment to cooperation with the DOJ. These steps include the following:

1. Immediate Retention of Counsel. Dunmore retained Calderwood & Harkness LLP as outside counsel on April 14, 2022 — five days before the grand jury subpoena was issued and eight days before any contact from the Government — upon the internal identification of potential exposure by then-Chief Compliance Officer Gerald Fisk on April 11, 2022. Victoria Chambers, Partner in the Firm's Washington, D.C. office, was designated as the responsible partner for this engagement. Howard Quinn, Partner in the Firm's New York office, was designated as the billing partner. The Firm immediately assembled a cross-office team of attorneys with experience in economic sanctions, export controls, and white-collar criminal defense matters.

2. Prompt Litigation Hold. On April 20, 2022, one day after receipt of grand jury subpoena GJ No. 22-418, Calderwood & Harkness issued comprehensive litigation hold notices to all Dunmore entities globally. These notices were disseminated across six jurisdictions — the Cayman Islands, the United Arab Emirates, the United States, Germany, Nigeria, and the United Kingdom — and were directed to all custodians with potential relevant information, including current employees, officers, and directors. The litigation hold notices were issued in English and, where appropriate, in local languages, and were accompanied by detailed preservation instructions regarding both electronic and hard-copy documents.

3. Document Preservation and Collection. To ensure the integrity and completeness of Dunmore's document preservation efforts, Calderwood & Harkness retained Nexagen Analytics Inc. ("Nexagen"), a leading electronic discovery and forensic data analytics firm, to conduct comprehensive e-discovery across all relevant Dunmore entities. This engagement was established under Project No. NX-DEH-2204, with Brian Cavanaugh of Nexagen designated as Project Manager. Nexagen commenced its data preservation and collection activities in late April 2022, and collection remains ongoing across all six jurisdictions. A formal e-discovery protocol and collection plan was finalized as of May 1, 2022, and has been shared with Dunmore's IT personnel in each jurisdiction to ensure consistent and complete preservation.

4. Forensic Accounting Engagement. On May 2, 2022, Calderwood & Harkness retained Ridgeline Advisory Group LLC ("Ridgeline"), a forensic accounting and financial advisory firm, to conduct forensic tracing of suspect transaction flows and comprehensive financial analysis of the transactions at issue. This engagement was established under Engagement No. RAG-2022-0319, with Dr. Margaret Liu, CPA, CFE, designated as Engagement Lead. Ridgeline's team includes specialists in sanctions compliance, trade finance, and cross-border payment tracing. Ridgeline has been working under the direction and supervision of Calderwood & Harkness, and its work product is protected by attorney-client privilege and the work product doctrine.

5. Personnel Actions. Upon identification of the potential involvement of certain individuals in the conduct at issue, Dunmore took prompt personnel actions to preserve the integrity of the investigation. Natasha Sorokin, Senior Trader at DTI, was placed on paid administrative leave effective May 16, 2022. Derek Hargrave, President of DTI, was placed on paid administrative leave effective July 1, 2022, following the completion of his initial interview and the identification of additional information suggesting his awareness of the counterparty relationships at issue. Both individuals have been instructed not to access company systems, communicate with other Dunmore employees regarding the investigation, or travel outside their respective jurisdictions without prior notice to Calderwood & Harkness.

6. Witness Interviews. Calderwood & Harkness commenced the first round of witness interviews on May 18, 2022. Between that date and June 30, 2022, the Firm conducted a total of 22 interviews of Dunmore employees and former employees across three locations: Houston, Texas; Dubai, UAE; and London, United Kingdom. All interviews were conducted pursuant to the Firm's standard Upjohn warning protocol, under which each interviewee was advised that Calderwood & Harkness represents Dunmore and not the individual, that the substance of the interview is protected by the company's attorney-client privilege, and that the company may choose to waive that privilege and disclose the substance of the interview to the Government or other third parties.

7. Subpoena Extension Negotiated in Good Faith. Dunmore timely acknowledged receipt of grand jury subpoena GJ No. 22-418 and, through Calderwood & Harkness, promptly contacted your office to discuss the scope and timeline for compliance. The extension of the return date from May 19, 2022 to July 19, 2022 was negotiated in good faith, with the mutual understanding that Dunmore would commence rolling productions of responsive documents and would provide this initial proffer by the extended return date.

8. Dunmore's Proactive Self-Identification. It bears emphasis that Dunmore identified the potential exposure at issue internally and before any contact from the Government. On April 11, 2022, then-Chief Compliance Officer Gerald Fisk ran a routine OFAC screening refresh as part of Dunmore's standard compliance procedures. This screening refresh was triggered by the April 6, 2022 addition of Volkhov Industrial Group JSC to the OFAC Specially Designated Nationals and blocked Persons List ("SDN List") pursuant to Executive Order 14024. Mr. Fisk's screening identified potential matches between DTI counterparties and entities that appeared to be associated with Volkhov Industrial Group JSC. Mr. Fisk escalated his findings to General Counsel Marcus Wellbourne on the same day, and the decision to retain outside counsel was made within 72 hours. Dunmore's proactive identification of this exposure underscores the company's commitment to compliance and its good faith in addressing the conduct at issue.

III. Summary of Preliminary Findings

The following is a summary of the preliminary findings of Calderwood & Harkness's internal investigation, conducted with the assistance of Ridgeline Advisory Group and Nexagen Analytics. These findings are preliminary in nature and are subject to revision as the investigation continues. Calderwood & Harkness will provide supplemental proffers to the DOJ as additional findings become available.

A. Overview of the Conduct at Issue

Based on the investigation to date, Calderwood & Harkness has identified evidence indicating that between approximately March 2020 and April 2022, DTI's Dubai-based trading desk, under the supervision of Derek Hargrave, President of DTI, and with the direct involvement of Natasha Sorokin, Senior Trader, engaged in a series of crude oil, refined products, and oilfield equipment transactions involving counterparties with undisclosed ties to Volkhov Industrial Group JSC ("Volkhov" or "VIG").

Volkhov Industrial Group JSC is a Russian industrial conglomerate with significant operations in the energy, mining, and industrial equipment sectors. Its Chairman is Arkady Volkhov, and its headquarters are located at 12 Kutuzovsky Prospekt, Moscow 121248, Russia. Volkhov was designated under OFAC Directive 2 (sectoral sanctions applicable to the energy sector of the Russian Federation, under Executive Order 13662) on November 15, 2019, thereby prohibiting certain transactions by U.S. persons involving new debt of greater than 60 days' maturity or new equity of VIG and its property or interests in property. On April 6, 2022, Volkhov was added to the OFAC SDN List under Executive Order 14024, subjecting it to full blocking sanctions.

The transactions identified to date fall into three principal categories: (1) crude oil swap transactions; (2) oilfield equipment exports; and (3) payment structuring involving intermediary accounts. Each category is described in further detail below.

B. Crude Oil Swap Transactions

Between approximately June 2020 and February 2022, DTI executed a series of 14 crude oil swap transactions with a combined notional value of approximately $218.7 million. The counterparties to these transactions were two Dubai-based entities:

• Petronova Trading FZE — a Free Zone Establishment registered in the Jebel Ali Free Zone, Dubai, UAE, with its office at Office 1407, Al Shafar Tower, Dubai Internet City, Dubai. The Managing Director of Petronova Trading FZE is Sergei Volkov.

• Zenith Petroleum DMCC — a company registered in the Dubai Multi Commodities Centre (DMCC), with its office at Unit 2201, Jumeirah Bay Tower X2, Cluster X, Jumeirah Lakes Towers, Dubai, UAE. The Managing Director of Zenith Petroleum DMCC is Farhan Qureshi.

Preliminary analysis conducted by Ridgeline Advisory Group indicates that a substantial portion of these crude oil swap transactions may have involved crude oil ultimately sourced from or destined for entities owned or controlled by Volkhov Industrial Group JSC, or in which Volkhov holds a significant ownership or control interest. If confirmed, these transactions may constitute violations of OFAC Directive 2 under Executive Order 13662, which imposes sectoral sanctions on the energy sector of the Russian Federation. Calderwood & Harkness notes that certain of these transactions may also raise concerns under the full blocking sanctions imposed by Executive Order 14024, to the extent they continued after April 6, 2022, although our preliminary analysis indicates that the last of the 14 identified swap transactions was executed on or about February 14, 2022.

Ridgeline's analysis of the crude oil swap transactions is ongoing. The forensic tracing of crude oil flows, bill of lading analysis, and review of cargo inspection and discharge documentation has not yet been completed. Calderwood & Harkness will share the results of Ridgeline's continuing analysis with the DOJ as they become available.

We note in particular that the beneficial ownership structure of Petronova Trading FZE remains under active investigation. Preliminary review of corporate records obtained from the Jebel Ali Free Zone Authority, together with open-source due diligence conducted by Calderwood & Harkness and Nexagen, suggests that Sergei Volkov, the Managing Director of Petronova Trading FZE, has a familial or close business relationship with Arkady Volkhov, Chairman of Volkhov Industrial Group JSC, and with entities owned or controlled by Volkhov Industrial Group. Analysis under the OFAC 50% Rule — which provides that the property and interests in property of entities owned 50% or more, individually or in the aggregate, by one or more blocked persons are themselves blocked — is continuing, and Calderwood & Harkness anticipates being in a position to provide a more definitive assessment of beneficial ownership in a supplemental proffer.

C. Oilfield Equipment Exports

Between approximately August 2020 and January 2022, DTI facilitated the export of oilfield drilling equipment and components with an aggregate value of approximately $12.4 million to end users in Russia. These shipments were routed through an intermediary entity:

• Caspian Logistik GmbH — a company registered in Hamburg, Germany, with its office at Mönckebergstraße 22, 20095 Hamburg, Germany. The Managing Director of Caspian Logistik GmbH is Klaus Weidemann.

The items exported in these transactions are classified under the Export Administration Regulations ("EAR") at Export Control Classification Numbers ("ECCN") 2B350 (chemical manufacturing equipment and components) and 2B999 (specific processing equipment, not elsewhere specified). Calderwood & Harkness's preliminary review of the export documentation associated with these shipments, including end-user certificates provided by Caspian Logistik GmbH, raises significant concerns regarding the accuracy and authenticity of the end-user certifications. Specifically, the named end users on certain certificates appear to be shell entities or entities with no demonstrable operational capacity at the stated end-use locations, and several certificates contain inconsistencies in formatting, signatory identification, and governmental endorsements that warrant further scrutiny.

Based on our preliminary analysis, these shipments may have violated Section 746.5 of the EAR (15 C.F.R. § 746.5), which imposes licensing requirements and restrictions on exports and reexports to Russia and Belarus, as well as applicable OFAC prohibitions on dealings with blocked persons and entities subject to sectoral sanctions. The potential violations implicate both the EAR's end-use and end-user controls and the broader prohibitions administered by OFAC.

Yves Leclerc, Director of Logistics & Shipping at DTI, had direct operational involvement in coordinating these shipments, including communications with Caspian Logistik GmbH regarding shipping documentation and logistics. Tobias Engel, Managing Director of Dunmore Renewables GmbH, had a more limited but nonetheless identifiable involvement: specifically, certain of the shipments were booked through Dunmore Renewables GmbH's German logistics accounts, and Mr. Engel approved at least two of the relevant purchase orders. Interviews of both Mr. Leclerc and Mr. Engel have been conducted, and Calderwood & Harkness is continuing to assess the scope of their respective knowledge and involvement.

D. Payment Structuring Concerns

In the course of its forensic analysis, Ridgeline Advisory Group has identified preliminary evidence of approximately $34.2 million in payments routed through intermediary accounts at Crescent Commercial Bank PJSC, a financial institution headquartered in Dubai, UAE. The relationship manager at Crescent Commercial Bank PJSC for the relevant accounts is Khalid Mansour.

These payments appear to have been structured across approximately 127 individual wire transactions executed between March 2020 and March 2022. Ridgeline's preliminary analysis indicates that the structuring of these payments — including the use of multiple intermediary accounts, the fragmentation of large-value transactions into smaller transfers, and the interposition of entities with no apparent business purpose — appears designed to obscure the ultimate beneficial ownership of Volkhov-connected entities as recipients or counterparties to the transactions. Ridgeline has identified patterns consistent with layering techniques, including the use of nominee entities in multiple jurisdictions and the circular routing of funds through accounts in the UAE, the Cayman Islands, and the United Kingdom before ultimate disbursement.

Rajesh Malhotra, Controller at DTI, processed and approved a significant number of these wire transfers in the ordinary course of his duties. Calderwood & Harkness is currently assessing the extent of Mr. Malhotra's knowledge regarding the ultimate beneficiaries of these payments and whether his approval of the wire transfers reflected awareness of the potential sanctions implications. Mr. Malhotra has been cooperative in his interview to date and has provided access to his electronic communications and records.

E. Applicable Legal Framework

Calderwood & Harkness has conducted a preliminary analysis of the legal framework applicable to the identified conduct. The principal authorities implicated by the transactions described above include the following:

OFAC-Administered Programs:

• Executive Order 14024 (April 15, 2021), "Blocking Property with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation," which authorizes the blocking of property and interests in property of persons determined to operate or have operated in specified sectors of the Russian Federation economy.

• Directive 2 under Executive Order 13662, which imposes sectoral sanctions on the energy sector of the Russian Federation, prohibiting certain transactions by U.S. persons involving new debt and new equity of identified persons.

• 31 C.F.R. Part 589, the Russian Harmful Foreign Activities Sanctions Regulations, implementing the authorities described above.

Export Administration Regulations:

• 15 C.F.R. Parts 730–774, the Export Administration Regulations, administered by the Bureau of Industry and Security ("BIS") of the U.S. Department of Commerce.

• Specifically, 15 C.F.R. § 746.5, which imposes licensing requirements and restrictions on exports and reexports to Russia and Belarus.

• ECCN 2B350 (chemical manufacturing equipment and components) and ECCN 2B999 (specific processing equipment, not elsewhere specified).

Criminal Statutes Potentially at Issue:

• The International Emergency Economic Powers Act ("IEEPA"), 50 U.S.C. §§ 1701–1706, which authorizes the imposition of economic sanctions and provides criminal penalties for willful violations thereof.

• The Export Control Reform Act of 2018 ("ECRA"), 50 U.S.C. §§ 4801–4852, which provides the statutory authority for the EAR and establishes criminal penalties for violations of export control requirements.

Calderwood & Harkness's preliminary jurisdictional analysis confirms that a sufficient nexus to United States jurisdiction exists with respect to the transactions identified in this proffer. This nexus is established through multiple independent bases, including, inter alia: (a) the denomination of a substantial number of the relevant transactions in U.S. dollars, with corresponding clearing through U.S. financial institutions; (b) the involvement of U.S. persons in the Dunmore corporate chain, including U.S.-resident officers and directors of DEH and its subsidiaries; (c) Dunmore's operational headquarters in Houston, Texas, from which supervisory authority over DTI's activities was exercised; and (d) the incorporation of DUA as a Delaware limited liability company with an EIN assigned by the Internal Revenue Service. Calderwood & Harkness is not aware of any meritorious basis for challenging the DOJ's jurisdiction over this matter, and Dunmore does not intend to raise jurisdictional objections.

IV. Status of the Internal Investigation

A. Document Collection and Review

Calderwood & Harkness and Nexagen Analytics are conducting document collection across six jurisdictions: the Cayman Islands, the United Arab Emirates, the United States, Germany, Nigeria, and the United Kingdom. Collection efforts include the preservation and forensic imaging of email accounts, local and network file stores, instant messaging platforms, mobile devices, and hard-copy documents from Dunmore's offices and operational sites in each jurisdiction.

Collection activities are ongoing and are expected to continue for the foreseeable future. Current projections, based on the volume of data identified and collected to date, suggest a document universe in excess of two million documents. Calderwood & Harkness has deployed technology-assisted review ("TAR") protocols, utilizing predictive coding and concept clustering tools, to identify and prioritize responsive documents for review. The TAR methodology and workflow have been designed to ensure accuracy and defensibility, and Calderwood & Harkness is prepared to discuss the TAR protocol with the DOJ upon request.

Calderwood & Harkness anticipates making the first tranche of document productions to the DOJ on or about August 15, 2022, pursuant to the rolling production protocol agreed upon between the undersigned and your office. Subsequent tranches will follow on a regular schedule as review and privilege analysis are completed. We will coordinate with your office regarding the format, volume, and sequencing of these productions to ensure they are responsive to the Government's investigative priorities.

B. Witness Interviews Completed to Date

As noted above, Calderwood & Harkness conducted the first round of 22 witness interviews between May 18 and June 30, 2022. These interviews were conducted across three locations — Houston, Texas; Dubai, UAE; and London, United Kingdom — and were attended by teams of Calderwood & Harkness attorneys with relevant subject matter expertise.

All interviews were conducted pursuant to the Firm's standard Upjohn warning protocol, as described in Section II.B.6 above. Key interviews completed during the first round include the following:

We note that Gerald Fisk's interview on June 8, 2022 was conducted with his personal counsel, Catherine Blackthorn of Blackthorn & Associates LLP, present throughout. Mr. Fisk departed Dunmore on June 10, 2022, two days after his interview.

Additional rounds of witness interviews are planned for August and September 2022. These interviews are expected to include additional DTI trading desk personnel, Dunmore finance and accounting staff, and selected individuals at counterparty entities who may be willing to cooperate. Calderwood & Harkness will coordinate with the DOJ regarding the timing and scope of Government interviews of Dunmore personnel, and Dunmore has committed to making its employees available for such interviews upon reasonable request.

C. Forensic Accounting Work

Ridgeline Advisory Group's forensic analysis has been ongoing since its engagement on May 2, 2022. Ridgeline has focused its initial efforts on three principal workstreams corresponding to the three categories of conduct identified above: (1) tracing the crude oil flows and financial counterparty relationships associated with the 14 swap transactions; (2) analyzing the oilfield equipment export transactions and the role of Caspian Logistik GmbH as an intermediary; and (3) mapping the payment flows through intermediary accounts at Crescent Commercial Bank PJSC to identify the ultimate beneficial recipients.

The preliminary findings summarized in Section III above reflect Ridgeline's work to date, which remains in progress. The final forensic accounting report has not yet been completed, and certain aspects of the analysis — particularly the beneficial ownership tracing for Petronova Trading FZE and the full reconstruction of payment flows through the 127 identified wire transactions — require additional data and analysis. Calderwood & Harkness will provide supplemental proffers to the DOJ as Ridgeline's findings mature and will make Dr. Liu and her team available to discuss their methodology and findings with the DOJ if requested.

D. Personnel Developments

Since the commencement of the internal investigation, several significant personnel developments have occurred:

• Gerald Fisk, Former Chief Compliance Officer, departed Dunmore on June 10, 2022. The circumstances of Mr. Fisk's departure are under review by Dunmore. Mr. Fisk is now represented by Catherine Blackthorn of Blackthorn & Associates LLP, located at 700 Louisiana Street, Suite 4300, Houston, Texas 77002. Calderwood & Harkness has acknowledged Ms. Blackthorn's representation and has established appropriate information-sharing limitations to ensure that privileged communications are not inadvertently disclosed to Mr. Fisk through his former role at the company.

• Derek Hargrave, President of DTI, was placed on paid administrative leave effective July 1, 2022. Mr. Hargrave has retained personal counsel: James Overstreet of Overstreet & McClain PLLC, located at 2200 Ross Avenue, Suite 3600, Dallas, Texas 75201. Calderwood & Harkness has been in communication with Mr. Overstreet regarding the scope of Mr. Hargrave's administrative leave and the parameters of his continued cooperation.

• Natasha Sorokin, Senior Trader at DTI, has been on paid administrative leave since May 16, 2022. Calderwood & Harkness understands that Ms. Sorokin may be in the process of retaining personal counsel but has not yet received a formal notice of representation. We will advise the DOJ when we are informed of Ms. Sorokin's counsel selection.

• Dunmore is actively engaged in the process of appointing a new Chief Compliance Officer to replace Gerald Fisk. The company is conducting an external search with the assistance of a retained executive search firm, with the objective of hiring an individual with significant experience in sanctions compliance, export controls, and anti-corruption. Dunmore anticipates that the new CCO will be in place by the end of the third quarter of 2022.

V. Anticipated Next Steps and Continued Cooperation

Dunmore and Calderwood & Harkness are committed to the continued pursuit of the internal investigation and to ongoing cooperation with the DOJ. The following are the principal next steps that we anticipate:

1. Supplemental Proffers. Calderwood & Harkness will continue the internal investigation and will provide supplemental proffers to the DOJ on a rolling basis as additional findings become available. We anticipate that additional proffers will address, among other things, the results of Ridgeline's completed forensic accounting analysis, the findings from subsequent rounds of witness interviews, and any additional transactions or conduct identified in the course of the investigation.

2. Rolling Document Productions. Dunmore will make rolling document productions in response to grand jury subpoena GJ No. 22-418, commencing on or about August 15, 2022. Subsequent productions will follow on a regular schedule, which Calderwood & Harkness will coordinate with your office.

3. Second Round of Witness Interviews. A second round of witness interviews is planned for August and September 2022, focusing on additional DTI personnel, Dunmore finance and accounting staff, and other individuals who may have relevant knowledge.

4. Final Forensic Accounting Report. Ridgeline Advisory Group's final forensic accounting report is expected to be completed in the fourth quarter of 2022. Calderwood & Harkness will provide the DOJ with a summary of the report's conclusions, consistent with Dunmore's cooperation commitments, upon completion.

5. Independent Compliance Consultant. Dunmore is actively evaluating the engagement of an independent compliance consultant to conduct a comprehensive assessment of the company's existing sanctions and export controls compliance program, identify deficiencies, and recommend remedial measures. Dunmore views this step as essential to demonstrating its commitment to preventing a recurrence of the conduct at issue and to strengthening its compliance infrastructure going forward.

6. Availability for Meetings. Calderwood & Harkness stands ready to meet with AUSA Calloway, Trial Attorneys Samuel Kovacs and Diana Pressman, and Special Agent Paul Reinhardt of the FBI at any time to discuss any aspect of the investigation. We are committed to maintaining open and constructive lines of communication with the Government throughout this process.

7. OFAC Voluntary Self-Disclosure. Dunmore is currently considering whether to file a voluntary self-disclosure ("VSD") with OFAC regarding the identified transactions. The decision to file a VSD involves a number of considerations, including the preliminary nature of the investigation findings and the interaction between a potential VSD and the pending DOJ inquiry. Calderwood & Harkness will keep the DOJ informed of Dunmore's decision regarding a VSD filing and will coordinate with your office to ensure that any such filing is consistent with the company's cooperation with the DOJ.

VI. Reservation of Rights

This proffer is made voluntarily and in good faith by Dunmore, through its counsel Calderwood & Harkness LLP, as a demonstration of Dunmore's commitment to cooperation with the DOJ. Notwithstanding the foregoing, Dunmore expressly reserves all defenses, rights, and privileges available to it under applicable law, including but not limited to the following:

1. Nothing in this letter constitutes, nor should it be construed as, an admission of liability, wrongdoing, or criminal intent by Dunmore Energy Holdings Ltd. or any of its officers, directors, employees, affiliates, subsidiaries, shareholders, or agents.

2. Dunmore reserves the attorney-client privilege and work product protections with respect to all communications and materials created in connection with the internal investigation, except to the extent expressly and specifically waived herein. The disclosure of factual information in this proffer is limited to the specific facts set forth in this letter and does not constitute a broader waiver of privilege or work product protection as to any other communications, documents, or materials.

3. Information shared in this proffer is provided subject to the terms of the oral proffer agreement discussed between Victoria Chambers and AUSA Calloway on June 28, 2022, and is not to be used against Dunmore in any criminal prosecution, civil enforcement action, or other proceeding, except as permitted under the terms of that agreement.

4. Dunmore expressly does not waive the attorney-client privilege or work product protections as to any third party by virtue of this disclosure to the DOJ. This proffer is made under the common interest doctrine and the selective waiver doctrine, to the extent applicable, and Dunmore reserves the right to assert privilege and work product protections in any proceeding involving third parties.

5. Dunmore reserves all rights to challenge the scope, relevance, or admissibility of any evidence or testimony in any future proceeding, and nothing in this letter constitutes a waiver of any such rights.

VII. Closing

In closing, Dunmore reaffirms its continued commitment to full and transparent cooperation with the DOJ's investigation. Dunmore recognizes the seriousness of the matters under inquiry and is determined to work constructively with the Government to ensure that all relevant facts are brought to light and that appropriate measures are taken to address any compliance deficiencies.

We invite you to contact the undersigned directly at the Calderwood & Harkness Washington, D.C. office, located at 1750 Pennsylvania Avenue NW, Suite 800, Washington, DC 20006, by telephone at (202) 555-7412, or by email at vchambers@calderwoodharkness.com, to discuss any questions that may arise from this proffer or to schedule follow-up meetings at your convenience. Calderwood & Harkness is prepared to provide any additional information the DOJ may require on an expedited basis and to make Dunmore's personnel and advisors available as needed.

We appreciate your consideration of this proffer and look forward to continuing our constructive dialogue with your office.

Respectfully submitted,

CALDERWOOD & HARKNESS LLP

By: ________

Victoria Chambers Partner 1750 Pennsylvania Avenue NW, Suite 800 Washington, DC 20006 Telephone: (202) 555-7412 Facsimile: (202) 555-7401

Email: vchambers@calderwoodharkness.com

cc: (via email)

Howard Quinn, Esq. — Partner, Calderwood & Harkness LLP (New York)

Jasmine Thornton, Esq. — Counsel, Calderwood & Harkness LLP (Washington, D.C.)

Conrad Reeves, Esq. — Associate, Calderwood & Harkness LLP (Washington, D.C.)

Marcus Wellbourne, Esq. — General Counsel, Dunmore Energy Holdings Ltd. (via separate cover under attorney-client privilege)

Note: This letter has been provided to AUSA Meredith Calloway only and has not been filed publicly. Distribution is restricted to authorized personnel within the U.S. Department of Justice in accordance with the terms of the oral proffer agreement. Any further distribution or disclosure requires the prior written consent of Calderwood & Harkness LLP on behalf of Dunmore Energy Holdings Ltd.

Interviewee	Title / Position	Date	Location
Callum Renshaw	CEO, DEH	May 23, 2022	Houston, TX
Derek Hargrave	President, DTI	May 25, 2022	Dubai, UAE
Sandra Whitfield	CFO, DEH	May 30, 2022	Houston, TX
Natasha Sorokin	Senior Trader, DTI	June 2, 2022	Dubai, UAE
Gerald Fisk	Former CCO, DEH	June 8, 2022	Houston, TX
Omar Al-Rashidi	Head of ME Operations, DTI	June 14, 2022	Dubai, UAE
Yves Leclerc	Director of Logistics, DTI	June 22, 2022	Dubai, UAE

CALDERWOOD & HARKNESS LLP Attorneys at Law
1750 Pennsylvania Avenue NW, Suite 800 | Washington, DC 20006 Telephone: (202) 555-7400 | Facsimile: (202) 555-7401 www.calderwoodharkness.com
NEW YORK | WASHINGTON, DC | LONDON | HONG KONG | SAN FRANCISCO | HOUSTON
July 15, 2022
CONFIDENTIAL — PROFFER MATERIAL This letter contains information provided pursuant to an oral proffer agreement between Dunmore Energy Holdings Ltd. and the U.S. Department of Justice. The contents of this letter are not to be construed as a waiver of attorney-client privilege or work product protections except as expressly stated herein. This letter is provided solely for the use of the addressee and authorized personnel within the U.S. Department of Justice and may not be disclosed to any third party without the prior written consent of Calderwood & Harkness LLP.
VIA HAND DELIVERY AND EMAIL
Meredith Calloway Assistant United States Attorney National Security Division Counterintelligence and Export Control Section U.S. Department of Justice 950 Pennsylvania Avenue NW Washington, DC 20530
Re: Dunmore Energy Holdings Ltd. — Grand Jury Subpoena No. GJ 22-418; Initial Proffer of Cooperation
Matter No.: 1016-00009
Dear Ms. Calloway:
We write on behalf of our client, Dunmore Energy Holdings Ltd. ("Dunmore" or "DEH"), a Cayman Islands exempted company with limited liability (registration no. MC-334821), with operational headquarters at 1200 McKinney Street, Suite 3400, Houston, Texas 77010, in connection with the inquiry opened by the U.S. Department of Justice ("DOJ") National Security Division on April 19, 2022. Calderwood & Harkness LLP ("Calderwood & Harkness" or the "Firm") serves as counsel to Dunmore in all matters arising from this inquiry.
This letter is submitted in reference to grand jury subpoena GJ No. 22-418, issued by the U.S. District Court for the District of Columbia (Grand Jury 22-2), bearing an original return date of May 19, 2022, which was subsequently extended by mutual agreement to July 19, 2022 to permit orderly collection, review, and production of responsive materials. The purpose of this letter is threefold: (1) to provide an initial proffer of Dunmore's cooperation with the DOJ's investigation; (2) to summarize the preliminary findings of the internal investigation that Calderwood & Harkness has been conducting on behalf of Dunmore since April 2022; and (3) to outline the anticipated next steps in Dunmore's ongoing cooperation.
This proffer is being made voluntarily and in good faith to demonstrate Dunmore's commitment to full cooperation with the DOJ. Dunmore's Board of Directors has authorized Calderwood & Harkness to provide the information set forth herein and to continue cooperating with the DOJ as the investigation proceeds. We emphasize that Dunmore's decision to make this proffer reflects the company's genuine desire to assist the Government in understanding the facts and circumstances surrounding the conduct at issue and to work constructively toward an appropriate resolution.
This proffer is subject to the terms of the oral proffer agreement discussed between the undersigned and you, Ms. Calloway, on June 28, 2022, and confirmed in subsequent communications. Dunmore expressly reserves all rights, including but not limited to the attorney-client privilege and work product protections, except as expressly waived herein. Nothing in this letter is intended to constitute, nor should it be construed as, an admission of liability or wrongdoing by Dunmore or any of its officers, directors, employees, or affiliates.
We note that this letter is being delivered in advance of, and is intended to serve as a framework for, the in-person proffer meeting being held concurrently on this date at the DOJ's offices in Washington, D.C. We look forward to discussing these matters in greater detail during that session with you, Trial Attorneys Samuel Kovacs and Diana Pressman, and Special Agent Paul Reinhardt of the Federal Bureau of Investigation.
I. Background on Dunmore Energy Holdings Ltd.
A. Corporate Overview
Dunmore Energy Holdings Ltd. is an exempted company incorporated with limited liability under the laws of the Cayman Islands. The company's registered office is located at Harbour Place, 4th Floor, 103 South Church Street, George Town, Grand Cayman KY1-1002, Cayman Islands. Dunmore maintains its operational headquarters at 1200 McKinney Street, Suite 3400, Houston, Texas 77010, United States, from which its senior management team directs the company's global operations.
Dunmore operates in the oil and gas exploration, production, and trading sectors, with an expanding portfolio in renewable energy development. The company's activities span multiple continents, including operations in North America, the Middle East, West Africa, and Europe. For fiscal year 2021, Dunmore reported annual revenue of approximately $4.87 billion, as reflected in audited financial statements prepared by Ashford & Whitmore LLP, the company's independent auditor. As of the date of this letter, Dunmore employs approximately 3,200 individuals across its global operations.
B. Ownership Structure
Dunmore's ownership structure is as follows:
• Majority Shareholder: Greystone Capital Partners Fund IV, L.P. holds a 62.5% equity interest in Dunmore. The general partner of Greystone Capital Partners Fund IV, L.P. is Greystone Capital Management LLC, which is managed by Richard Fairbanks, who serves as its Managing Member.
• Management Equity: Approximately 22.5% of Dunmore's equity is held by senior executives through management equity plans and direct ownership interests. The principal holders of management equity include Callum Renshaw (Chief Executive Officer), Sandra Whitfield (Chief Financial Officer), and certain other members of Dunmore's senior management team.
• Minority Shareholder: Thornbury Infrastructure Fund II, L.P. holds a 15% equity interest in Dunmore. Thornbury Infrastructure Fund II, L.P. is managed by Thornbury Asset Management Ltd., of which Helen Cresswell serves as Managing Director.
To our knowledge, neither Greystone Capital Partners Fund IV, L.P. nor Thornbury Infrastructure Fund II, L.P. had any involvement in or knowledge of the transactions that are the subject of this inquiry. Calderwood & Harkness has confirmed this through preliminary interviews with representatives of both funds, and we will supplement this proffer if our understanding changes.
C. Key Subsidiaries Relevant to the Inquiry
Dunmore operates through a number of subsidiaries and affiliated entities worldwide. The following subsidiaries are most directly relevant to the DOJ's inquiry:
1. Dunmore Trading International Ltd. ("DTI") — DTI is a limited company holding DIFC License No. CL-4827, with its principal office at Level 14, Gate Building 3, Dubai International Financial Centre, P.O. Box 506774, Dubai, United Arab Emirates. DTI operates Dunmore's overseas trading desk and is the primary entity involved in the transactions at issue in this inquiry. DTI was established in 2016 to centralize Dunmore's international commodities trading activities and has been responsible for the company's crude oil, refined products, and petrochemical trading operations in the Middle East, Central Asia, and parts of Europe.
2. Dunmore upstream Americas LLC ("DUA") — DUA is a Delaware limited liability company (EIN 84-2937561) with its principal office at 1200 McKinney Street, Suite 3400, Houston, Texas 77010. DUA manages Dunmore's upstream exploration and production activities in North and South America.
3. Dunmore Renewables GmbH — Dunmore Renewables GmbH is a company organized as a Gesellschaft mit beschränkter Haftung (GmbH) registered in Hamburg, Germany, with its office located at Überseeallee 12, 20457 Hamburg, Germany. Dunmore Renewables GmbH manages the company's European renewable energy development portfolio. This entity is tangentially involved in the inquiry due to its role in facilitating one suspect transaction involving oilfield equipment exports, as described in greater detail below.
4. Dunmore Exploration West Africa Ltd. — Dunmore Exploration West Africa Ltd. is a limited company with offices in Lagos, Nigeria, managing Dunmore's exploration and production activities in the West African region. While this entity is not believed to be directly involved in the conduct at issue, certain of its personnel may have peripheral knowledge of DTI's trading activities.
D. Key Individuals
The following individuals are relevant to the DOJ's inquiry and to the internal investigation being conducted by Calderwood & Harkness:
• Callum Renshaw — Chief Executive Officer, Dunmore Energy Holdings Ltd. Mr. Renshaw is based at Dunmore's operational headquarters in Houston, Texas, and has served as CEO since 2017. He has ultimate supervisory authority over all Dunmore operations, including those of DTI.
• Derek Hargrave — President, Dunmore Trading International Ltd. Mr. Hargrave is based in Dubai, UAE, and supervised DTI's trading desk from 2017 through the present. Mr. Hargrave was placed on paid administrative leave effective July 1, 2022, following the identification of his potential involvement in the conduct at issue.
• Natasha Sorokin — Senior Trader, DTI. Ms. Sorokin is a Russian-American dual national based in Dubai, UAE. She is a key individual in the transactions at issue and was placed on paid administrative leave effective May 16, 2022.
• Omar Al-Rashidi — Head of Middle East Operations, DTI. Mr. Al-Rashidi is based in Dubai and has been cooperating internally with the Calderwood & Harkness investigation. He has provided information regarding DTI's counterparty relationships and trading practices.
• Yves Leclerc — Director of Logistics & Shipping, DTI. Mr. Leclerc is a French national based in Dubai. He was responsible for coordinating shipments, including certain oilfield equipment exports that are the subject of this inquiry.
• Gerald Fisk — Former Chief Compliance Officer of DEH. Mr. Fisk initially identified the potential exposure that gave rise to Dunmore's retention of Calderwood & Harkness. Mr. Fisk departed the company on June 10, 2022, and is currently represented by Catherine Blackthorn of Blackthorn & Associates LLP, located at 700 Louisiana Street, Suite 4300, Houston, Texas 77002.
• Marcus Wellbourne — General Counsel, Dunmore Energy Holdings Ltd. Mr. Wellbourne is based in Houston and has been coordinating with Calderwood & Harkness on all aspects of the internal investigation and the DOJ inquiry.
• Sandra Whitfield — Chief Financial Officer, Dunmore Energy Holdings Ltd. Ms. Whitfield is based in Houston and oversees all financial operations, including those of DTI.
• Rajesh Malhotra — Controller, DTI. Mr. Malhotra is based in Dubai and was responsible for processing and approving wire transfers related to DTI's trading activities. His knowledge and role in the suspect transactions are currently being assessed.
• Tobias Engel — Managing Director, Dunmore Renewables GmbH. Mr. Engel is based in Hamburg, Germany, and had a degree of involvement in certain oilfield equipment export transactions that are under review.
II. Dunmore's Commitment to Cooperation
A. Statement of Cooperation Principles
Dunmore is committed to full, timely, and transparent cooperation with the DOJ's National Security Division and with the U.S. Department of the Treasury's Office of Foreign Assets Control ("OFAC") in connection with this inquiry. Dunmore's Board of Directors, with the full support of its majority shareholder, Greystone Capital Partners Fund IV, L.P., has directed Calderwood & Harkness to provide all non-privileged factual information that may be relevant to the Government's investigation.
Dunmore's cooperation is guided by the principles articulated in the DOJ Corporate Enforcement Policy, formerly known as the "Filip Factors," and as reflected in the Department's guidance on the Evaluation of Corporate Compliance Programs (updated June 2020). Dunmore understands that its level of cooperation, including the timeliness, completeness, and quality of its disclosures, will be considered by the DOJ in determining the appropriate resolution of this matter, and Dunmore intends to cooperate voluntarily and proactively beyond the minimum requirements of grand jury subpoena GJ No. 22-418.
To that end, Dunmore has authorized Calderwood & Harkness to share factual information with the DOJ on a rolling basis as the internal investigation progresses, to make witnesses available for Government interviews upon reasonable request, and to disclose the results of the company's forensic accounting analysis as those results become available. Dunmore has further committed to preserving all potentially relevant documents and data and to implementing any remedial measures that may be warranted by the findings of the internal investigation.
B. Steps Taken to Date Demonstrating Cooperation
Since the inception of this matter, Dunmore has taken numerous concrete steps to demonstrate its commitment to cooperation with the DOJ. These steps include the following:
1. Immediate Retention of Counsel. Dunmore retained Calderwood & Harkness LLP as outside counsel on April 14, 2022 — five days before the grand jury subpoena was issued and eight days before any contact from the Government — upon the internal identification of potential exposure by then-Chief Compliance Officer Gerald Fisk on April 11, 2022. Victoria Chambers, Partner in the Firm's Washington, D.C. office, was designated as the responsible partner for this engagement. Howard Quinn, Partner in the Firm's New York office, was designated as the billing partner. The Firm immediately assembled a cross-office team of attorneys with experience in economic sanctions, export controls, and white-collar criminal defense matters.
2. Prompt Litigation Hold. On April 20, 2022, one day after receipt of grand jury subpoena GJ No. 22-418, Calderwood & Harkness issued comprehensive litigation hold notices to all Dunmore entities globally. These notices were disseminated across six jurisdictions — the Cayman Islands, the United Arab Emirates, the United States, Germany, Nigeria, and the United Kingdom — and were directed to all custodians with potential relevant information, including current employees, officers, and directors. The litigation hold notices were issued in English and, where appropriate, in local languages, and were accompanied by detailed preservation instructions regarding both electronic and hard-copy documents.
3. Document Preservation and Collection. To ensure the integrity and completeness of Dunmore's document preservation efforts, Calderwood & Harkness retained Nexagen Analytics Inc. ("Nexagen"), a leading electronic discovery and forensic data analytics firm, to conduct comprehensive e-discovery across all relevant Dunmore entities. This engagement was established under Project No. NX-DEH-2204, with Brian Cavanaugh of Nexagen designated as Project Manager. Nexagen commenced its data preservation and collection activities in late April 2022, and collection remains ongoing across all six jurisdictions. A formal e-discovery protocol and collection plan was finalized as of May 1, 2022, and has been shared with Dunmore's IT personnel in each jurisdiction to ensure consistent and complete preservation.
4. Forensic Accounting Engagement. On May 2, 2022, Calderwood & Harkness retained Ridgeline Advisory Group LLC ("Ridgeline"), a forensic accounting and financial advisory firm, to conduct forensic tracing of suspect transaction flows and comprehensive financial analysis of the transactions at issue. This engagement was established under Engagement No. RAG-2022-0319, with Dr. Margaret Liu, CPA, CFE, designated as Engagement Lead. Ridgeline's team includes specialists in sanctions compliance, trade finance, and cross-border payment tracing. Ridgeline has been working under the direction and supervision of Calderwood & Harkness, and its work product is protected by attorney-client privilege and the work product doctrine.
5. Personnel Actions. Upon identification of the potential involvement of certain individuals in the conduct at issue, Dunmore took prompt personnel actions to preserve the integrity of the investigation. Natasha Sorokin, Senior Trader at DTI, was placed on paid administrative leave effective May 16, 2022. Derek Hargrave, President of DTI, was placed on paid administrative leave effective July 1, 2022, following the completion of his initial interview and the identification of additional information suggesting his awareness of the counterparty relationships at issue. Both individuals have been instructed not to access company systems, communicate with other Dunmore employees regarding the investigation, or travel outside their respective jurisdictions without prior notice to Calderwood & Harkness.
6. Witness Interviews. Calderwood & Harkness commenced the first round of witness interviews on May 18, 2022. Between that date and June 30, 2022, the Firm conducted a total of 22 interviews of Dunmore employees and former employees across three locations: Houston, Texas; Dubai, UAE; and London, United Kingdom. All interviews were conducted pursuant to the Firm's standard Upjohn warning protocol, under which each interviewee was advised that Calderwood & Harkness represents Dunmore and not the individual, that the substance of the interview is protected by the company's attorney-client privilege, and that the company may choose to waive that privilege and disclose the substance of the interview to the Government or other third parties.
7. Subpoena Extension Negotiated in Good Faith. Dunmore timely acknowledged receipt of grand jury subpoena GJ No. 22-418 and, through Calderwood & Harkness, promptly contacted your office to discuss the scope and timeline for compliance. The extension of the return date from May 19, 2022 to July 19, 2022 was negotiated in good faith, with the mutual understanding that Dunmore would commence rolling productions of responsive documents and would provide this initial proffer by the extended return date.
8. Dunmore's Proactive Self-Identification. It bears emphasis that Dunmore identified the potential exposure at issue internally and before any contact from the Government. On April 11, 2022, then-Chief Compliance Officer Gerald Fisk ran a routine OFAC screening refresh as part of Dunmore's standard compliance procedures. This screening refresh was triggered by the April 6, 2022 addition of Volkhov Industrial Group JSC to the OFAC Specially Designated Nationals and blocked Persons List ("SDN List") pursuant to Executive Order 14024. Mr. Fisk's screening identified potential matches between DTI counterparties and entities that appeared to be associated with Volkhov Industrial Group JSC. Mr. Fisk escalated his findings to General Counsel Marcus Wellbourne on the same day, and the decision to retain outside counsel was made within 72 hours. Dunmore's proactive identification of this exposure underscores the company's commitment to compliance and its good faith in addressing the conduct at issue.
III. Summary of Preliminary Findings
The following is a summary of the preliminary findings of Calderwood & Harkness's internal investigation, conducted with the assistance of Ridgeline Advisory Group and Nexagen Analytics. These findings are preliminary in nature and are subject to revision as the investigation continues. Calderwood & Harkness will provide supplemental proffers to the DOJ as additional findings become available.
A. Overview of the Conduct at Issue
Based on the investigation to date, Calderwood & Harkness has identified evidence indicating that between approximately March 2020 and April 2022, DTI's Dubai-based trading desk, under the supervision of Derek Hargrave, President of DTI, and with the direct involvement of Natasha Sorokin, Senior Trader, engaged in a series of crude oil, refined products, and oilfield equipment transactions involving counterparties with undisclosed ties to Volkhov Industrial Group JSC ("Volkhov" or "VIG").
Volkhov Industrial Group JSC is a Russian industrial conglomerate with significant operations in the energy, mining, and industrial equipment sectors. Its Chairman is Arkady Volkhov, and its headquarters are located at 12 Kutuzovsky Prospekt, Moscow 121248, Russia. Volkhov was designated under OFAC Directive 2 (sectoral sanctions applicable to the energy sector of the Russian Federation, under Executive Order 13662) on November 15, 2019, thereby prohibiting certain transactions by U.S. persons involving new debt of greater than 60 days' maturity or new equity of VIG and its property or interests in property. On April 6, 2022, Volkhov was added to the OFAC SDN List under Executive Order 14024, subjecting it to full blocking sanctions.
The transactions identified to date fall into three principal categories: (1) crude oil swap transactions; (2) oilfield equipment exports; and (3) payment structuring involving intermediary accounts. Each category is described in further detail below.
B. Crude Oil Swap Transactions
Between approximately June 2020 and February 2022, DTI executed a series of 14 crude oil swap transactions with a combined notional value of approximately $218.7 million. The counterparties to these transactions were two Dubai-based entities:
• Petronova Trading FZE — a Free Zone Establishment registered in the Jebel Ali Free Zone, Dubai, UAE, with its office at Office 1407, Al Shafar Tower, Dubai Internet City, Dubai. The Managing Director of Petronova Trading FZE is Sergei Volkov.
• Zenith Petroleum DMCC — a company registered in the Dubai Multi Commodities Centre (DMCC), with its office at Unit 2201, Jumeirah Bay Tower X2, Cluster X, Jumeirah Lakes Towers, Dubai, UAE. The Managing Director of Zenith Petroleum DMCC is Farhan Qureshi.
Preliminary analysis conducted by Ridgeline Advisory Group indicates that a substantial portion of these crude oil swap transactions may have involved crude oil ultimately sourced from or destined for entities owned or controlled by Volkhov Industrial Group JSC, or in which Volkhov holds a significant ownership or control interest. If confirmed, these transactions may constitute violations of OFAC Directive 2 under Executive Order 13662, which imposes sectoral sanctions on the energy sector of the Russian Federation. Calderwood & Harkness notes that certain of these transactions may also raise concerns under the full blocking sanctions imposed by Executive Order 14024, to the extent they continued after April 6, 2022, although our preliminary analysis indicates that the last of the 14 identified swap transactions was executed on or about February 14, 2022.
Ridgeline's analysis of the crude oil swap transactions is ongoing. The forensic tracing of crude oil flows, bill of lading analysis, and review of cargo inspection and discharge documentation has not yet been completed. Calderwood & Harkness will share the results of Ridgeline's continuing analysis with the DOJ as they become available.
We note in particular that the beneficial ownership structure of Petronova Trading FZE remains under active investigation. Preliminary review of corporate records obtained from the Jebel Ali Free Zone Authority, together with open-source due diligence conducted by Calderwood & Harkness and Nexagen, suggests that Sergei Volkov, the Managing Director of Petronova Trading FZE, has a familial or close business relationship with Arkady Volkhov, Chairman of Volkhov Industrial Group JSC, and with entities owned or controlled by Volkhov Industrial Group. Analysis under the OFAC 50% Rule — which provides that the property and interests in property of entities owned 50% or more, individually or in the aggregate, by one or more blocked persons are themselves blocked — is continuing, and Calderwood & Harkness anticipates being in a position to provide a more definitive assessment of beneficial ownership in a supplemental proffer.
C. Oilfield Equipment Exports
Between approximately August 2020 and January 2022, DTI facilitated the export of oilfield drilling equipment and components with an aggregate value of approximately $12.4 million to end users in Russia. These shipments were routed through an intermediary entity:
• Caspian Logistik GmbH — a company registered in Hamburg, Germany, with its office at Mönckebergstraße 22, 20095 Hamburg, Germany. The Managing Director of Caspian Logistik GmbH is Klaus Weidemann.
The items exported in these transactions are classified under the Export Administration Regulations ("EAR") at Export Control Classification Numbers ("ECCN") 2B350 (chemical manufacturing equipment and components) and 2B999 (specific processing equipment, not elsewhere specified). Calderwood & Harkness's preliminary review of the export documentation associated with these shipments, including end-user certificates provided by Caspian Logistik GmbH, raises significant concerns regarding the accuracy and authenticity of the end-user certifications. Specifically, the named end users on certain certificates appear to be shell entities or entities with no demonstrable operational capacity at the stated end-use locations, and several certificates contain inconsistencies in formatting, signatory identification, and governmental endorsements that warrant further scrutiny.
Based on our preliminary analysis, these shipments may have violated Section 746.5 of the EAR (15 C.F.R. § 746.5), which imposes licensing requirements and restrictions on exports and reexports to Russia and Belarus, as well as applicable OFAC prohibitions on dealings with blocked persons and entities subject to sectoral sanctions. The potential violations implicate both the EAR's end-use and end-user controls and the broader prohibitions administered by OFAC.
Yves Leclerc, Director of Logistics & Shipping at DTI, had direct operational involvement in coordinating these shipments, including communications with Caspian Logistik GmbH regarding shipping documentation and logistics. Tobias Engel, Managing Director of Dunmore Renewables GmbH, had a more limited but nonetheless identifiable involvement: specifically, certain of the shipments were booked through Dunmore Renewables GmbH's German logistics accounts, and Mr. Engel approved at least two of the relevant purchase orders. Interviews of both Mr. Leclerc and Mr. Engel have been conducted, and Calderwood & Harkness is continuing to assess the scope of their respective knowledge and involvement.
D. Payment Structuring Concerns
In the course of its forensic analysis, Ridgeline Advisory Group has identified preliminary evidence of approximately $34.2 million in payments routed through intermediary accounts at Crescent Commercial Bank PJSC, a financial institution headquartered in Dubai, UAE. The relationship manager at Crescent Commercial Bank PJSC for the relevant accounts is Khalid Mansour.
These payments appear to have been structured across approximately 127 individual wire transactions executed between March 2020 and March 2022. Ridgeline's preliminary analysis indicates that the structuring of these payments — including the use of multiple intermediary accounts, the fragmentation of large-value transactions into smaller transfers, and the interposition of entities with no apparent business purpose — appears designed to obscure the ultimate beneficial ownership of Volkhov-connected entities as recipients or counterparties to the transactions. Ridgeline has identified patterns consistent with layering techniques, including the use of nominee entities in multiple jurisdictions and the circular routing of funds through accounts in the UAE, the Cayman Islands, and the United Kingdom before ultimate disbursement.
Rajesh Malhotra, Controller at DTI, processed and approved a significant number of these wire transfers in the ordinary course of his duties. Calderwood & Harkness is currently assessing the extent of Mr. Malhotra's knowledge regarding the ultimate beneficiaries of these payments and whether his approval of the wire transfers reflected awareness of the potential sanctions implications. Mr. Malhotra has been cooperative in his interview to date and has provided access to his electronic communications and records.
E. Applicable Legal Framework
Calderwood & Harkness has conducted a preliminary analysis of the legal framework applicable to the identified conduct. The principal authorities implicated by the transactions described above include the following:
OFAC-Administered Programs:
• Executive Order 14024 (April 15, 2021), "Blocking Property with Respect to Specified Harmful Foreign Activities of the Government of the Russian Federation," which authorizes the blocking of property and interests in property of persons determined to operate or have operated in specified sectors of the Russian Federation economy.
• Directive 2 under Executive Order 13662, which imposes sectoral sanctions on the energy sector of the Russian Federation, prohibiting certain transactions by U.S. persons involving new debt and new equity of identified persons.
• 31 C.F.R. Part 589, the Russian Harmful Foreign Activities Sanctions Regulations, implementing the authorities described above.
Export Administration Regulations:
• 15 C.F.R. Parts 730–774, the Export Administration Regulations, administered by the Bureau of Industry and Security ("BIS") of the U.S. Department of Commerce.
• Specifically, 15 C.F.R. § 746.5, which imposes licensing requirements and restrictions on exports and reexports to Russia and Belarus.
• ECCN 2B350 (chemical manufacturing equipment and components) and ECCN 2B999 (specific processing equipment, not elsewhere specified).
Criminal Statutes Potentially at Issue:
• The International Emergency Economic Powers Act ("IEEPA"), 50 U.S.C. §§ 1701–1706, which authorizes the imposition of economic sanctions and provides criminal penalties for willful violations thereof.
• The Export Control Reform Act of 2018 ("ECRA"), 50 U.S.C. §§ 4801–4852, which provides the statutory authority for the EAR and establishes criminal penalties for violations of export control requirements.
Calderwood & Harkness's preliminary jurisdictional analysis confirms that a sufficient nexus to United States jurisdiction exists with respect to the transactions identified in this proffer. This nexus is established through multiple independent bases, including, inter alia: (a) the denomination of a substantial number of the relevant transactions in U.S. dollars, with corresponding clearing through U.S. financial institutions; (b) the involvement of U.S. persons in the Dunmore corporate chain, including U.S.-resident officers and directors of DEH and its subsidiaries; (c) Dunmore's operational headquarters in Houston, Texas, from which supervisory authority over DTI's activities was exercised; and (d) the incorporation of DUA as a Delaware limited liability company with an EIN assigned by the Internal Revenue Service. Calderwood & Harkness is not aware of any meritorious basis for challenging the DOJ's jurisdiction over this matter, and Dunmore does not intend to raise jurisdictional objections.
IV. Status of the Internal Investigation
A. Document Collection and Review
Calderwood & Harkness and Nexagen Analytics are conducting document collection across six jurisdictions: the Cayman Islands, the United Arab Emirates, the United States, Germany, Nigeria, and the United Kingdom. Collection efforts include the preservation and forensic imaging of email accounts, local and network file stores, instant messaging platforms, mobile devices, and hard-copy documents from Dunmore's offices and operational sites in each jurisdiction.
Collection activities are ongoing and are expected to continue for the foreseeable future. Current projections, based on the volume of data identified and collected to date, suggest a document universe in excess of two million documents. Calderwood & Harkness has deployed technology-assisted review ("TAR") protocols, utilizing predictive coding and concept clustering tools, to identify and prioritize responsive documents for review. The TAR methodology and workflow have been designed to ensure accuracy and defensibility, and Calderwood & Harkness is prepared to discuss the TAR protocol with the DOJ upon request.
Calderwood & Harkness anticipates making the first tranche of document productions to the DOJ on or about August 15, 2022, pursuant to the rolling production protocol agreed upon between the undersigned and your office. Subsequent tranches will follow on a regular schedule as review and privilege analysis are completed. We will coordinate with your office regarding the format, volume, and sequencing of these productions to ensure they are responsive to the Government's investigative priorities.
B. Witness Interviews Completed to Date
As noted above, Calderwood & Harkness conducted the first round of 22 witness interviews between May 18 and June 30, 2022. These interviews were conducted across three locations — Houston, Texas; Dubai, UAE; and London, United Kingdom — and were attended by teams of Calderwood & Harkness attorneys with relevant subject matter expertise.
All interviews were conducted pursuant to the Firm's standard Upjohn warning protocol, as described in Section II.B.6 above. Key interviews completed during the first round include the following:
We note that Gerald Fisk's interview on June 8, 2022 was conducted with his personal counsel, Catherine Blackthorn of Blackthorn & Associates LLP, present throughout. Mr. Fisk departed Dunmore on June 10, 2022, two days after his interview.
Additional rounds of witness interviews are planned for August and September 2022. These interviews are expected to include additional DTI trading desk personnel, Dunmore finance and accounting staff, and selected individuals at counterparty entities who may be willing to cooperate. Calderwood & Harkness will coordinate with the DOJ regarding the timing and scope of Government interviews of Dunmore personnel, and Dunmore has committed to making its employees available for such interviews upon reasonable request.
C. Forensic Accounting Work
Ridgeline Advisory Group's forensic analysis has been ongoing since its engagement on May 2, 2022. Ridgeline has focused its initial efforts on three principal workstreams corresponding to the three categories of conduct identified above: (1) tracing the crude oil flows and financial counterparty relationships associated with the 14 swap transactions; (2) analyzing the oilfield equipment export transactions and the role of Caspian Logistik GmbH as an intermediary; and (3) mapping the payment flows through intermediary accounts at Crescent Commercial Bank PJSC to identify the ultimate beneficial recipients.
The preliminary findings summarized in Section III above reflect Ridgeline's work to date, which remains in progress. The final forensic accounting report has not yet been completed, and certain aspects of the analysis — particularly the beneficial ownership tracing for Petronova Trading FZE and the full reconstruction of payment flows through the 127 identified wire transactions — require additional data and analysis. Calderwood & Harkness will provide supplemental proffers to the DOJ as Ridgeline's findings mature and will make Dr. Liu and her team available to discuss their methodology and findings with the DOJ if requested.
D. Personnel Developments
Since the commencement of the internal investigation, several significant personnel developments have occurred:
• Gerald Fisk, Former Chief Compliance Officer, departed Dunmore on June 10, 2022. The circumstances of Mr. Fisk's departure are under review by Dunmore. Mr. Fisk is now represented by Catherine Blackthorn of Blackthorn & Associates LLP, located at 700 Louisiana Street, Suite 4300, Houston, Texas 77002. Calderwood & Harkness has acknowledged Ms. Blackthorn's representation and has established appropriate information-sharing limitations to ensure that privileged communications are not inadvertently disclosed to Mr. Fisk through his former role at the company.
• Derek Hargrave, President of DTI, was placed on paid administrative leave effective July 1, 2022. Mr. Hargrave has retained personal counsel: James Overstreet of Overstreet & McClain PLLC, located at 2200 Ross Avenue, Suite 3600, Dallas, Texas 75201. Calderwood & Harkness has been in communication with Mr. Overstreet regarding the scope of Mr. Hargrave's administrative leave and the parameters of his continued cooperation.
• Natasha Sorokin, Senior Trader at DTI, has been on paid administrative leave since May 16, 2022. Calderwood & Harkness understands that Ms. Sorokin may be in the process of retaining personal counsel but has not yet received a formal notice of representation. We will advise the DOJ when we are informed of Ms. Sorokin's counsel selection.
• Dunmore is actively engaged in the process of appointing a new Chief Compliance Officer to replace Gerald Fisk. The company is conducting an external search with the assistance of a retained executive search firm, with the objective of hiring an individual with significant experience in sanctions compliance, export controls, and anti-corruption. Dunmore anticipates that the new CCO will be in place by the end of the third quarter of 2022.
V. Anticipated Next Steps and Continued Cooperation
Dunmore and Calderwood & Harkness are committed to the continued pursuit of the internal investigation and to ongoing cooperation with the DOJ. The following are the principal next steps that we anticipate:
1. Supplemental Proffers. Calderwood & Harkness will continue the internal investigation and will provide supplemental proffers to the DOJ on a rolling basis as additional findings become available. We anticipate that additional proffers will address, among other things, the results of Ridgeline's completed forensic accounting analysis, the findings from subsequent rounds of witness interviews, and any additional transactions or conduct identified in the course of the investigation.
2. Rolling Document Productions. Dunmore will make rolling document productions in response to grand jury subpoena GJ No. 22-418, commencing on or about August 15, 2022. Subsequent productions will follow on a regular schedule, which Calderwood & Harkness will coordinate with your office.
3. Second Round of Witness Interviews. A second round of witness interviews is planned for August and September 2022, focusing on additional DTI personnel, Dunmore finance and accounting staff, and other individuals who may have relevant knowledge.
4. Final Forensic Accounting Report. Ridgeline Advisory Group's final forensic accounting report is expected to be completed in the fourth quarter of 2022. Calderwood & Harkness will provide the DOJ with a summary of the report's conclusions, consistent with Dunmore's cooperation commitments, upon completion.
5. Independent Compliance Consultant. Dunmore is actively evaluating the engagement of an independent compliance consultant to conduct a comprehensive assessment of the company's existing sanctions and export controls compliance program, identify deficiencies, and recommend remedial measures. Dunmore views this step as essential to demonstrating its commitment to preventing a recurrence of the conduct at issue and to strengthening its compliance infrastructure going forward.
6. Availability for Meetings. Calderwood & Harkness stands ready to meet with AUSA Calloway, Trial Attorneys Samuel Kovacs and Diana Pressman, and Special Agent Paul Reinhardt of the FBI at any time to discuss any aspect of the investigation. We are committed to maintaining open and constructive lines of communication with the Government throughout this process.
7. OFAC Voluntary Self-Disclosure. Dunmore is currently considering whether to file a voluntary self-disclosure ("VSD") with OFAC regarding the identified transactions. The decision to file a VSD involves a number of considerations, including the preliminary nature of the investigation findings and the interaction between a potential VSD and the pending DOJ inquiry. Calderwood & Harkness will keep the DOJ informed of Dunmore's decision regarding a VSD filing and will coordinate with your office to ensure that any such filing is consistent with the company's cooperation with the DOJ.
VI. Reservation of Rights
This proffer is made voluntarily and in good faith by Dunmore, through its counsel Calderwood & Harkness LLP, as a demonstration of Dunmore's commitment to cooperation with the DOJ. Notwithstanding the foregoing, Dunmore expressly reserves all defenses, rights, and privileges available to it under applicable law, including but not limited to the following:
1. Nothing in this letter constitutes, nor should it be construed as, an admission of liability, wrongdoing, or criminal intent by Dunmore Energy Holdings Ltd. or any of its officers, directors, employees, affiliates, subsidiaries, shareholders, or agents.
2. Dunmore reserves the attorney-client privilege and work product protections with respect to all communications and materials created in connection with the internal investigation, except to the extent expressly and specifically waived herein. The disclosure of factual information in this proffer is limited to the specific facts set forth in this letter and does not constitute a broader waiver of privilege or work product protection as to any other communications, documents, or materials.
3. Information shared in this proffer is provided subject to the terms of the oral proffer agreement discussed between Victoria Chambers and AUSA Calloway on June 28, 2022, and is not to be used against Dunmore in any criminal prosecution, civil enforcement action, or other proceeding, except as permitted under the terms of that agreement.
4. Dunmore expressly does not waive the attorney-client privilege or work product protections as to any third party by virtue of this disclosure to the DOJ. This proffer is made under the common interest doctrine and the selective waiver doctrine, to the extent applicable, and Dunmore reserves the right to assert privilege and work product protections in any proceeding involving third parties.
5. Dunmore reserves all rights to challenge the scope, relevance, or admissibility of any evidence or testimony in any future proceeding, and nothing in this letter constitutes a waiver of any such rights.
VII. Closing
In closing, Dunmore reaffirms its continued commitment to full and transparent cooperation with the DOJ's investigation. Dunmore recognizes the seriousness of the matters under inquiry and is determined to work constructively with the Government to ensure that all relevant facts are brought to light and that appropriate measures are taken to address any compliance deficiencies.
We invite you to contact the undersigned directly at the Calderwood & Harkness Washington, D.C. office, located at 1750 Pennsylvania Avenue NW, Suite 800, Washington, DC 20006, by telephone at (202) 555-7412, or by email at vchambers@calderwoodharkness.com, to discuss any questions that may arise from this proffer or to schedule follow-up meetings at your convenience. Calderwood & Harkness is prepared to provide any additional information the DOJ may require on an expedited basis and to make Dunmore's personnel and advisors available as needed.
We appreciate your consideration of this proffer and look forward to continuing our constructive dialogue with your office.
Respectfully submitted,
CALDERWOOD & HARKNESS LLP
By: ________
Victoria Chambers Partner 1750 Pennsylvania Avenue NW, Suite 800 Washington, DC 20006 Telephone: (202) 555-7412 Facsimile: (202) 555-7401
Email: vchambers@calderwoodharkness.com
cc: (via email)
Howard Quinn, Esq. — Partner, Calderwood & Harkness LLP (New York)
Jasmine Thornton, Esq. — Counsel, Calderwood & Harkness LLP (Washington, D.C.)
Conrad Reeves, Esq. — Associate, Calderwood & Harkness LLP (Washington, D.C.)
Marcus Wellbourne, Esq. — General Counsel, Dunmore Energy Holdings Ltd. (via separate cover under attorney-client privilege)
Note: This letter has been provided to AUSA Meredith Calloway only and has not been filed publicly. Distribution is restricted to authorized personnel within the U.S. Department of Justice in accordance with the terms of the oral proffer agreement. Any further distribution or disclosure requires the prior written consent of Calderwood & Harkness LLP on behalf of Dunmore Energy Holdings Ltd.
Interviewee | Title / Position | Date | Location
Callum Renshaw | CEO, DEH | May 23, 2022 | Houston, TX
Derek Hargrave | President, DTI | May 25, 2022 | Dubai, UAE
Sandra Whitfield | CFO, DEH | May 30, 2022 | Houston, TX
Natasha Sorokin | Senior Trader, DTI | June 2, 2022 | Dubai, UAE
Gerald Fisk | Former CCO, DEH | June 8, 2022 | Houston, TX
Omar Al-Rashidi | Head of ME Operations, DTI | June 14, 2022 | Dubai, UAE
Yves Leclerc | Director of Logistics, DTI | June 22, 2022 | Dubai, UAE

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