ATTORNEY-CLIENT PRIVILEGED / ATTORNEY WORK PRODUCT / CONFIDENTIAL
CALDERWOOD & HARKNESS LLP 1750 Pennsylvania Avenue NW, Suite 800 Washington, DC 20006, USA
Matter No.: 1016-00009
MEMORANDUM
TO: Victoria Chambers, Responsible Partner; Howard Quinn, Billing Partner; Conrad Reeves, Senior Counsel
FROM: Jasmine Thornton, Lead Associate; Liam Donahue, Working Associate
DATE: June 2, 2022
RE: Interview of Natasha Sorokin — Senior Trader, Dunmore Trading International Ltd. — Interview Conducted June 2, 2022
SUBJECT MATTER: DOJ Inquiry Regarding Potential Violations of U.S. Sanctions Laws (including OFAC-administered programs) and Export Control Regulations — Dunmore Energy Holdings Ltd.
CLIENT: Dunmore Energy Holdings Ltd. ("Dunmore" or "DEH")
INTERVIEW LOCATION: Calderwood & Harkness LLP, 1750 Pennsylvania Avenue NW, Suite 800, Washington, DC 20006
INTERVIEW DATE AND TIME: June 2, 2022, 9:30 a.m. – 4:15 p.m. (with breaks)
INTERVIEWERS: Jasmine Thornton; Liam Donahue
ALSO PRESENT: Nicholas Ferreira (notetaker, Calderwood & Harkness LLP, Houston office)
NOTE RE PERSONAL COUNSEL: As of the date of this interview, Ms. Sorokin had not yet retained personal counsel. Philip Keane of Wexford Keane LLP, 2000 K Street NW, Suite 650, Washington, DC 20006, subsequently entered an appearance on her behalf in September 2022. Ms. Sorokin was advised at the outset of the interview that she had the right to retain personal counsel prior to and during the interview.
ATTORNEY-CLIENT PRIVILEGED / ATTORNEY WORK PRODUCT / CONFIDENTIAL
I. Upjohn / Corporate Miranda Warning
At the outset of the interview, at approximately 9:30 a.m., Jasmine Thornton administered the Upjohn corporate Miranda warning to Ms. Sorokin in accordance with the Witness Interview Protocol dated April 18, 2022, prepared by Victoria Chambers. The warning was delivered orally and Ms. Sorokin was provided with a written copy of the warning for her reference. Ms. Sorokin was given time to read the written copy and was invited to ask questions before proceeding.
Ms. Sorokin was advised of the following points, and confirmed her understanding of each:
1. Calderwood & Harkness LLP represents Dunmore Energy Holdings Ltd. and its subsidiaries — not Ms. Sorokin individually. The firm's duties of loyalty and confidentiality run to the corporate client, and not to any individual employee, officer, or director.
2. The purpose of the interview is to gather facts in connection with the firm's internal investigation on behalf of Dunmore related to the DOJ inquiry concerning potential violations of U.S. sanctions laws and export control regulations. The interview is part of a broader fact-gathering effort and Ms. Sorokin's cooperation is requested in connection with that effort.
3. Communications during the interview are protected by Dunmore's attorney-client privilege, which belongs to Dunmore (not to Ms. Sorokin personally), and Dunmore may choose to waive that privilege and disclose the substance of the interview to the DOJ, OFAC, or other third parties at any time and in its sole discretion. Ms. Sorokin was advised that she should not assume that anything she says during the interview will remain confidential as between herself and the company.
4. Ms. Sorokin has the right to retain her own personal attorney at her own expense. Calderwood & Harkness cannot provide her with individual legal advice and is not in a position to advise her regarding any personal legal exposure she may have. She was encouraged to consider whether she wished to consult with personal counsel before or during the interview.
5. Dunmore expects Ms. Sorokin's full cooperation and truthful responses to all questions posed during the interview. Providing false or misleading information could have consequences including, but not limited to, disciplinary action up to and including termination of her employment.
Ms. Sorokin stated that she understood all of the foregoing points. She confirmed that she wished to proceed with the interview without personal counsel present. She did not pose any questions regarding the Upjohn warning, the nature of the privilege, or the scope of the investigation before agreeing to proceed.
ATTORNEY-CLIENT PRIVILEGED / ATTORNEY WORK PRODUCT / CONFIDENTIAL
II. Background and Employment History
Ms. Sorokin provided the following background and employment information in response to preliminary questions.
Full Name: Natasha Sorokin.
Citizenship: Russian-American dual national. Ms. Sorokin stated that she was born in St. Petersburg, Russia, and emigrated to the United States for university education. She became a naturalized United States citizen in approximately 2014. She retains her Russian passport and stated she uses it for travel to the Russian Federation and certain CIS countries. She stated she uses her U.S. passport for all other international travel.
Current Status at Dunmore: Ms. Sorokin confirmed that she was placed on paid administrative leave on May 16, 2022, approximately two and a half weeks prior to this interview. She stated she received a letter from Marcus Wellbourne, General Counsel of Dunmore Energy Holdings Ltd., informing her of the leave and instructing her not to access company systems, communicate with counterparties on behalf of DTI, or destroy any documents or communications. She confirmed that she remains an employee of Dunmore Trading International Ltd. as of the date of the interview.
Position: Senior Trader, Dunmore Trading International Ltd. ("DTI"), a wholly-owned subsidiary of Dunmore Energy Holdings Ltd. DTI is organized under the laws of the Cayman Islands and maintains its principal trading operations from its Dubai office.
Office Location: Level 14, Gate Building 3, Dubai International Financial Centre, P.O. Box 506774, Dubai, UAE. Ms. Sorokin stated that this is DTI's principal office and the location from which substantially all of the trading desk's operations are conducted.
Date of Hire: Approximately January 2018. Ms. Sorokin stated she was recruited by a headhunter retained by DTI and that she interviewed with Derek Hargrave and one other individual whose name she could not recall. She stated she received a formal offer in late 2017 and began working at the DTI Dubai office in January 2018.
Reporting Line: Ms. Sorokin stated that she reports directly to Derek Hargrave, President of DTI, who is based in Dubai and oversees all trading desk operations.
Educational Background: Ms. Sorokin stated that she holds a Bachelor of Science degree in Finance and Economics from a U.S. university. She did not specify the institution during the interview, but indicated it was located in the northeastern United States. Prior to joining DTI, she was employed at commodity trading firms not affiliated with Dunmore, working in Geneva, Switzerland, for approximately four years and in London, England, for approximately two years. She stated her prior roles involved physical commodity trading in crude oil and petroleum products, with a focus on CIS-origin and Russian-origin crude oil markets.
Role Description: Ms. Sorokin described her role at DTI as follows: she was responsible for executing crude oil and refined products trades on behalf of DTI, managing counterparty relationships for the Dubai trading desk, negotiating deal terms (including price, volume, grade, delivery window, and payment terms), and liaising with the logistics and finance teams to ensure successful trade execution and settlement. She stated she was one of three senior traders on the Dubai trading desk and that, among the three, she handled the largest share of Russian-origin and CIS-origin crude oil transactions. She described this focus as a natural function of her language skills (fluent in Russian and English), her prior professional experience in the Russian crude oil market, and her established network of contacts in the CIS commodity trading community.
Compensation: Ms. Sorokin did not provide exact compensation figures. She acknowledged that her compensation consisted of a base salary plus a performance-based bonus that was linked to the profitability of the trading desk. She stated that the bonus was determined annually based on a combination of the desk's overall performance and her individual contribution to trading profits. She did not disclose whether her bonus was calculated as a percentage of trading profits or on some other basis.
ATTORNEY-CLIENT PRIVILEGED / ATTORNEY WORK PRODUCT / CONFIDENTIAL
III. Organizational Structure and Reporting at DTI
Ms. Sorokin was asked to describe the organizational and reporting structure at DTI's Dubai trading desk, with a particular focus on the individuals who were involved in or had visibility into the transactions at issue in the investigation. She described the following key individuals and their roles:
• Derek Hargrave, President, DTI: Mr. Hargrave is the most senior executive at DTI and exercises overall supervision of all trading, logistics, and back-office functions. Ms. Sorokin stated that Hargrave was intimately involved in the day-to-day operations of the trading desk, maintained direct relationships with key counterparties, and personally approved significant transactions. She described him as a "hands-on" manager who was aware of the material terms of all significant trades executed by the desk.
• Omar Al-Rashidi, Head of Middle East Operations: Mr. Al-Rashidi is responsible for regional business development and client relationships throughout the Middle East. Ms. Sorokin stated that Al-Rashidi's role was primarily focused on origination — identifying new business opportunities, cultivating relationships with potential counterparties, and introducing the trading desk to new market participants. She stated that Al-Rashidi did not approve individual trades but had visibility into counterparty selection and participated in introductory meetings with potential trading partners.
• Yves Leclerc, Director of Logistics & Shipping: Mr. Leclerc is responsible for coordinating physical delivery, shipping arrangements, and documentation for all physical cargo trades, including crude oil shipments and, as discussed below, oilfield equipment shipments. Ms. Sorokin stated that Leclerc handled all logistical aspects of trade execution once a deal was confirmed, including chartering vessels, arranging port nominations, and managing bills of lading, certificates of origin, and other shipping documentation.
• Rajesh Malhotra, Controller, DTI: Mr. Malhotra oversees invoicing, payment processing, and the booking of trades in DTI's financial and trade capture systems. Ms. Sorokin stated that Malhotra reported to the President of DTI (Hargrave) on a direct-line basis for DTI operational matters and to Sandra Whitfield (Chief Financial Officer, Dunmore Energy Holdings Ltd.) on a dotted-line basis for financial reporting, consolidation, and audit purposes.
Ms. Sorokin stated that all trades above a certain notional threshold required sign-off from Derek Hargrave. She believed the threshold was approximately $10 million in notional value, though she was not certain of the exact figure and stated it may have been adjusted at various points. Trades below that threshold could be executed at the senior trader's discretion, subject to the requirement that the counterparty appear on an approved counterparty list maintained by the compliance function. She stated she did not recall ever executing a trade with a counterparty that had not been "at least submitted" to compliance for review.
Ms. Sorokin stated that compliance matters were escalated to Gerald Fisk, then-Chief Compliance Officer of Dunmore Energy Holdings Ltd., who was based in Houston, Texas, at the company's principal U.S. office at 1200 McKinney Street, Suite 3400, Houston, TX 77010. She described having "very limited" direct interaction with Fisk. She stated that compliance oversight was generally handled at the Houston level rather than on the trading desk in Dubai, and that there was no dedicated compliance officer or compliance function embedded within DTI's Dubai office. She characterized the compliance function's presence in Dubai as "remote" and stated that the trading desk's primary point of contact for compliance was email-based correspondence with Fisk's team in Houston.
ATTORNEY-CLIENT PRIVILEGED / ATTORNEY WORK PRODUCT / CONFIDENTIAL
IV. Relationship with Petronova Trading FZE and Sergei Volkov
A. Introduction to Petronova
Ms. Sorokin was asked to describe how DTI's business relationship with Petronova Trading FZE came about and the circumstances of her initial introduction to the entity.
Ms. Sorokin stated that she first became aware of Petronova Trading FZE in approximately late 2019 or early 2020. Petronova is registered at Office 1407, Al Shafar Tower, Dubai Internet City, Dubai, UAE, and holds a trade license issued by the Jebel Ali Free Zone Authority. She stated the introduction to Petronova came through Sergei Volkov, who presented himself as the Managing Director of Petronova Trading FZE.
Ms. Sorokin described Sergei Volkov as a Russian national who is resident in Dubai. She acknowledged that she and Volkov were acquaintances prior to the commencement of any business relationship between DTI and Petronova. She stated they had met at industry events and conferences in Dubai — she specifically mentioned an energy trading conference at the Atlantis hotel but could not recall the exact date — and that they shared a common social circle within the Russian-speaking expatriate community in Dubai. She described these initial interactions as "networking" and stated that the social acquaintance evolved naturally into a business relationship over the course of several months.
She stated that Volkov approached her about the possibility of DTI entering into crude oil swap transactions with Petronova, presenting the company as a commodity trading intermediary with access to competitively priced Russian-origin and Caspian-origin crude oil. Volkov described Petronova as having established relationships with upstream producers and reliable access to volumes that DTI could profitably trade. Ms. Sorokin stated that the initial conversations were informal and exploratory, and that Volkov was "persuasive" in his characterization of the commercial opportunity.
B. Nature and Scope of Dealings
Ms. Sorokin confirmed that she was the primary point of contact at DTI for all transactions with Petronova Trading FZE throughout the duration of the business relationship. She stated that no other trader on the DTI desk maintained a direct relationship with Volkov or Petronova, and that all communications between DTI and Petronova were channeled through her.
When asked about the number and scope of transactions, Ms. Sorokin estimated that she personally executed or was directly involved in "approximately a dozen or so" crude oil swap transactions with Petronova between approximately mid-2020 and early 2022. She was not able to provide a precise count from memory. This estimate is broadly consistent with the 14 total crude oil swap transactions identified through the investigation, of which 9 have been determined by Ridgeline Advisory Group LLC (Engagement No. RAG-2022-0319) to involve Volkhov-connected entities. The 9 Volkhov-connected transactions total approximately $156.3 million in notional value, out of an overall $218.7 million across all 14 transactions.
Ms. Sorokin described the typical transaction structure as follows: Petronova would source crude oil — primarily Urals-grade and CPC Blend — and deliver it to DTI for resale or swap into other grades. She stated that DTI would typically resell the crude to downstream buyers at a markup or would enter into swap arrangements that allowed DTI to profit from grade differentials and pricing spreads. She described the pricing terms offered by Petronova as "competitive" and stated that the transactions generated "attractive margins for DTI." She stated that the Petronova relationship was viewed favorably by the desk because it provided reliable access to volume at favorable pricing.
Ms. Sorokin also confirmed dealings with a second entity, Zenith Petroleum DMCC, registered at Unit 2201, Jumeirah Bay Tower X2, Cluster X, Jumeirah Lakes Towers, Dubai, UAE. She identified the principal contact at Zenith Petroleum as Farhan Qureshi, who she described as a Pakistani national based in Dubai. She stated that Zenith was involved in "a couple" of the crude oil swap transactions, typically participating as a co-counterparty or intermediary alongside Petronova. She described the arrangement as one in which Zenith provided additional logistical or commercial support for certain deals, though she was vague on the precise nature of Zenith's role. She stated that Farhan Qureshi was someone she dealt with less frequently than Volkov, and that Qureshi was "brought in by Sergei" on certain deals. She stated she understood Volkov and Qureshi to have a pre-existing business relationship, though she did not know the details.
C. Due Diligence and Counterparty Onboarding
Ms. Sorokin was questioned in detail about the counterparty onboarding and due diligence process that was followed in connection with Petronova Trading FZE's establishment as an approved DTI counterparty.
Ms. Sorokin stated that she submitted Petronova's corporate documentation — including its trade license, certificate of incorporation from the Jebel Ali Free Zone Authority, and a corporate profile — to the compliance team in Houston, specifically to Gerald Fisk's office, for review and approval. She stated that she sent these documents by email, though she could not identify the specific date or locate the email from memory. She stated she believed the submission occurred in late 2019 or early 2020, in advance of the first transaction.
When asked whether she personally conducted any beneficial ownership analysis of Petronova Trading FZE, Ms. Sorokin stated that she did not. She stated that she believed the compliance team in Houston was responsible for conducting OFAC screening, sanctions checks, and beneficial ownership verification as part of the counterparty approval process. She described this as the standard division of responsibilities between the trading desk and the compliance function.
Ms. Sorokin was asked whether she received any specific compliance clearance documentation, written approval memorandum, or formal sign-off confirming that Petronova had been vetted and approved as a DTI counterparty. She stated that she could not recall receiving any such documentation. Rather, she stated that the absence of an objection from the compliance function was treated as implicit approval to proceed with the counterparty relationship. She described this practice as "how things worked on the desk" — a trader would submit counterparty documentation to compliance, and if compliance did not raise a red flag or object within a reasonable period, the desk would proceed on the assumption that the counterparty had been cleared.
She stated that similar processes were followed for Zenith Petroleum DMCC. She stated she submitted Zenith's documentation to compliance in the same manner and did not receive a formal written approval or rejection.
ATTORNEY-CLIENT PRIVILEGED / ATTORNEY WORK PRODUCT / CONFIDENTIAL
V. Knowledge of Volkhov Industrial Group JSC Connections
A. Direct Questions Regarding Volkhov
Ms. Sorokin was asked directly whether she was aware of any connection — corporate, financial, or otherwise — between Petronova Trading FZE and Volkhov Industrial Group JSC, a Russian energy conglomerate headquartered at 12 Kutuzovsky Prospekt, Moscow 121248, Russia, and chaired by Arkady Volkhov.
Ms. Sorokin initially stated that she was "not aware of any formal corporate relationship" between Petronova and Volkhov Industrial Group. She stated that Petronova presented itself as an independent trading house, and that Sergei Volkov represented it as such. She stated that Petronova's corporate documentation did not, to her recollection, reference Volkhov Industrial Group.
When pressed further on this point, and specifically asked whether she had any reason to suspect or believe that Petronova might be connected to Volkhov Industrial Group, Ms. Sorokin acknowledged the following:
• She was aware that Sergei Volkov — the Managing Director of Petronova — shared a surname similarity with Arkady Volkhov, the chairman of Volkhov Industrial Group. However, she stated that she "assumed it was coincidence" and did not investigate further. She noted that "Volkov" and "Volkhov" are "common enough Russian names" and that the similarity did not strike her as dispositive of any corporate affiliation.
• She acknowledged that in approximately mid-2021, she became aware through what she described as "market chatter" and a specific comment from Omar Al-Rashidi that Petronova might have some upstream sourcing relationship with Volkhov-affiliated entities. She stated she did not verify this information and did not escalate it to the compliance function or to Derek Hargrave. Her explanation for not following up was that she considered the information to be unverified market speculation rather than a factual assertion requiring action.
• She acknowledged that certain crude oil cargoes transacted through Petronova were loaded at terminals historically associated with Volkhov-controlled operations. When presented with this observation, she stated that she was aware of the loading terminals from the bills of lading and shipping documentation but that she relied on the documentation provided by Petronova — including bills of lading, certificates of origin, and quality certificates — and did not independently verify the ultimate provenance of the crude oil or the ownership of the terminal facilities.
B. Awareness of OFAC Designations
Ms. Sorokin was questioned regarding her awareness of the Office of Foreign Assets Control (OFAC) sanctions designations applicable to Volkhov Industrial Group JSC. Two specific designations were addressed:
• Directive 2 Sectoral Sanctions (November 15, 2019, under Executive Order 13662): Ms. Sorokin stated that she was "generally aware" that certain Russian energy-sector entities had been subjected to sectoral sanctions by OFAC, but she stated that she did not know whether Volkhov Industrial Group was specifically designated under Directive 2. She stated that the responsibility for sanctions screening and monitoring of OFAC designations belonged to the compliance function in Houston, and that she relied on Gerald Fisk and his team to conduct such screening. She stated she did not independently monitor the SDN List, the Sectoral Sanctions Identifications (SSI) List, or any other OFAC sanctions list.
• SDN Listing (April 6, 2022, under Executive Order 14024): Ms. Sorokin stated that she first learned of the full blocking designation of Volkhov Industrial Group JSC as a Specially Designated National (SDN) when she was placed on administrative leave on May 16, 2022. She stated she was informed of the designation at that time by Marcus Wellbourne (General Counsel, Dunmore Energy Holdings Ltd.) and by members of the investigation team. She stated she had no prior awareness that Volkhov Industrial Group had been elevated from the SSI List to the SDN List.
Ms. Sorokin denied ever receiving training from Dunmore's compliance team or from any other source within the organization specifically addressing the Directive 2 sectoral sanctions or how those sanctions applied to transactions involving intermediaries sourcing crude oil from sanctioned entities. She stated that no one at Dunmore ever explained to her the specific prohibitions under Directive 2 or how they might bear on the types of intermediary trading arrangements DTI maintained with entities such as Petronova.
Ms. Sorokin denied any intent to evade or circumvent U.S. sanctions. She stated that she believed in good faith that the transactions with Petronova were compliant because the compliance function had not raised any objections. She stated, "If compliance had told me there was a problem, I would have stopped immediately."
C. OFAC 50% Rule
Ms. Sorokin was asked whether she understood the OFAC "50% Rule" — the principle, articulated in OFAC's Revised Guidance on Entities Owned by Persons Whose Property and Interests in Property are blocked (August 13, 2014), under which entities owned 50% or more, individually or in the aggregate, by one or more blocked persons are themselves treated as blocked property regardless of whether the entity itself is named on the SDN List.
Ms. Sorokin stated that she was "vaguely familiar" with the general concept of the 50% Rule but stated that she had not applied it in practice to the Petronova relationship or to any other counterparty relationship she managed. She stated she did not know the beneficial ownership percentages of Petronova Trading FZE, and had not asked Sergei Volkov about the ownership structure of the company. She stated that she understood beneficial ownership verification to be a compliance function responsibility, not a trader responsibility, and that she had never been instructed by anyone at Dunmore to conduct a 50% Rule analysis.
ATTORNEY-CLIENT PRIVILEGED / ATTORNEY WORK PRODUCT / CONFIDENTIAL
VI. The 14 Crude Oil Swap Transactions
Ms. Sorokin was shown a schedule of the 14 crude oil swap transactions executed between June 2020 and February 2022 involving Petronova Trading FZE and Zenith Petroleum DMCC as counterparties. The schedule was prepared by Ridgeline Advisory Group LLC (Engagement No. RAG-2022-0319) and reflected a total notional value of approximately $218.7 million across the 14 transactions. Ms. Sorokin was asked to review the schedule and comment on each transaction.
Ms. Sorokin confirmed her involvement in all 14 transactions as the executing trader. She stated that she was the trader of record for each deal and that no other DTI trader participated in the negotiation or execution of any of these trades. She stated that Derek Hargrave approved each transaction above the notional threshold and that she recalled obtaining his verbal or email approval for every major deal. She stated that for the larger transactions — which constituted the majority of the 14 — she typically presented the proposed terms to Hargrave in a brief summary (either in person or via email) and received his authorization before confirming the trade with Volkov.
For the 9 transactions subsequently identified by Ridgeline Advisory Group as involving Volkhov-connected crude oil — representing approximately $156.3 million in notional value — Ms. Sorokin stated that the crude sourcing details, including the grade, origin, loading terminal, and delivery window, were provided by Petronova and Sergei Volkov. She stated that she did not conduct independent due diligence on the ultimate origin of the crude oil and relied on the representations and documentation provided by Petronova.
Ms. Sorokin described the typical deal flow as follows:
1. Volkov would initiate contact and propose a deal, identifying the crude oil grade, approximate volume, proposed price or pricing formula, and delivery window. These initial contacts typically occurred via phone call or Meridian Services Inc. message.
2. Sorokin would assess prevailing market conditions, evaluate the proposed pricing against benchmark levels and DTI's current trading book, and negotiate specific terms with Volkov, including adjustments to price, volume, delivery dates, and demurrage provisions.
3. If the proposed terms were commercially attractive, Sorokin would present the deal to Derek Hargrave for approval. For transactions above the $10 million notional threshold, Hargrave's sign-off was required before the trade could be confirmed. Sorokin stated she presented the terms to Hargrave either verbally (in the office) or via a brief email summarizing the key commercial parameters.
4. Upon receiving Hargrave's approval, Sorokin would confirm the trade with Volkov and initiate the documentation process.
5. Deal confirmations, formal trade documentation, invoices, and shipping documents were handled by Yves Leclerc (logistics) and Rajesh Malhotra (finance/controller) in coordination with Petronova's back-office team.
Ms. Sorokin stated that this deal flow was consistent across substantially all of the 14 transactions. She noted that some of the smaller transactions may have proceeded without formal email documentation of Hargrave's approval, as the approval was given verbally in the office. She stated she could not recall the precise approval mechanism for each individual transaction but was confident that Hargrave was aware of and authorized all 14 deals.
ATTORNEY-CLIENT PRIVILEGED / ATTORNEY WORK PRODUCT / CONFIDENTIAL
VII. Use of Encrypted Messaging and Personal Communications
Ms. Sorokin was asked about her use of communication channels for business purposes, with particular focus on the use of encrypted messaging applications and personal devices.
Ms. Sorokin confirmed that she regularly communicated with Sergei Volkov via Meridian Services Inc., which is an end-to-end encrypted messaging application, in addition to DTI's official email system. She stated that the use of Meridian Services Inc. for business communications was "standard practice in the Dubai trading market" and was prevalent among traders, counterparties, and market participants in the region. She stated that her use of Meridian Services Inc. was not intended to evade monitoring, circumvent Dunmore's compliance systems, or conceal communications from oversight.
She acknowledged, however, that some deal-related discussions with Volkov — including pricing negotiations, preliminary deal terms, volume indications, and delivery scheduling — took place via Meridian Services Inc. and were not captured in DTI's official email system, trade capture platform, or any other corporate communication system subject to routine compliance monitoring or archival. She stated that while key terms were ultimately documented in formal trade confirmations and deal tickets entered into DTI's trade capture system, the informal preliminary discussions leading up to the trade were often conducted via Meridian Services Inc. and were not memorialized elsewhere.
Ms. Sorokin stated that she also used Meridian Services Inc. to communicate with Farhan Qureshi of Zenith Petroleum DMCC and with other market participants and counterparties in the ordinary course of business. She described this as unremarkable and consistent with prevailing market practice.
When asked whether she was aware of any Dunmore corporate policy regarding the use of personal messaging applications for business purposes, Ms. Sorokin stated she was "not sure there was a clear policy" on the subject. She stated that "everyone on the desk used Meridian Services Inc." and that she was not aware of any instruction, directive, or training from Dunmore's compliance function or management that prohibited or restricted the use of Meridian Services Inc. or similar platforms for business communications. She stated she had not received any communication from the compliance team regarding record-keeping obligations as they related to personal messaging platforms.
Ms. Sorokin confirmed that she had turned over her personal mobile phone to Calderwood & Harkness LLP and Nexagen Analytics Inc. (Project No. NX-DEH-2204) as part of the document collection process following the litigation hold notice issued by Dunmore on April 20, 2022. She stated that the phone was collected from her in Dubai by a Nexagen representative and that she was provided with a temporary replacement device for personal use during the pendency of the forensic review. She stated she had not deleted any Meridian Services Inc. messages or other data from the phone prior to its collection.
ATTORNEY-CLIENT PRIVILEGED / ATTORNEY WORK PRODUCT / CONFIDENTIAL
VIII. Oilfield Equipment Exports and Caspian Logistik GmbH
Ms. Sorokin was asked about the oilfield equipment exports identified in the investigation, valued at approximately $12.4 million, which were facilitated through Caspian Logistik GmbH, a German logistics company registered at Mönckebergstraße 22, 20095 Hamburg, Germany, and managed by Klaus Weidemann.
Ms. Sorokin stated that she was "peripherally aware" of some equipment transactions associated with the DTI trading desk but that these transactions were handled primarily by Yves Leclerc (Director of Logistics & Shipping). She stated that, in at least one instance, the equipment transactions involved coordination with Dunmore Renewables GmbH, a Dunmore subsidiary registered at Überseeallee 12, 20457 Hamburg, Germany, under the direction of Tobias Engel. She stated she did not have direct visibility into the operational details of these transactions.
Ms. Sorokin denied personally executing, approving, or negotiating any oilfield equipment transactions. She stated that her role at DTI was exclusively focused on crude oil and refined products trading, and that equipment transactions fell outside her area of responsibility and expertise. She stated she had no involvement in the procurement, logistics, or documentation of any oilfield equipment shipments.
She stated that she was aware that Caspian Logistik GmbH was a logistics provider used by the desk, as its name appeared in certain correspondence and documentation she had seen, but that she had no detailed knowledge of the company's operations, the nature of its engagement by DTI, or the specific services it provided. She stated she had no knowledge of end-user certifications associated with the equipment shipments and did not know the ultimate destination or end-use of the equipment.
Ms. Sorokin stated that she had no knowledge of Export Control Classification Numbers (ECCNs), specifically ECCN 2B350 and ECCN 2B999, which have been identified as potentially applicable to the exported equipment. She stated she had no familiarity with the requirements of EAR §746.5 or other export control regulations administered by the Bureau of Industry and Security (BIS), as these regulatory areas were entirely outside the scope of her job function. She stated she had never received training on export control compliance from Dunmore or any prior employer.
ATTORNEY-CLIENT PRIVILEGED / ATTORNEY WORK PRODUCT / CONFIDENTIAL
IX. Payment Structuring and Crescent Commercial Bank
Ms. Sorokin was asked about the payment flows identified by Ridgeline Advisory Group LLC in connection with the Petronova and Zenith Petroleum transactions. Specifically, she was asked about $34.2 million in payments across 127 individual transactions that were routed through intermediary accounts held at Crescent Commercial Bank PJSC (Al Maktoum Tower, DIFC, P.O. Box 335102, Dubai, UAE) between approximately March 2020 and March 2022. The forensic accounting analysis conducted by Ridgeline has indicated that the payment structuring was designed to obscure the beneficial ownership interest of Volkhov Industrial Group JSC and its principals in the underlying funds.
Ms. Sorokin stated that she was not involved in payment routing, payment structuring, or the processing of wire transfers in connection with the Petronova or Zenith Petroleum transactions, or in connection with any other DTI trades. She stated that payment instructions were provided by Petronova (specifically by Volkov) and were processed by Rajesh Malhotra (Controller, DTI) and the DTI finance team. She described her role as limited to trade execution and confirmation and stated that once a trade was confirmed, the payment and settlement process was handled entirely by the finance function.
Ms. Sorokin was shown specific wire transfer records referencing intermediary entities that received or transmitted funds in connection with the transactions at issue. She stated that she did not recognize several of the intermediary account holders listed in the wire transfer records and had not been copied on payment instruction communications or wire transfer confirmation emails. She stated she had no visibility into the specific bank accounts or entities through which funds flowed.
When asked whether Volkov ever made specific requests regarding payment routing, Ms. Sorokin acknowledged that Volkov "occasionally" requested that payments be directed to entities other than Petronova Trading FZE itself. She stated she was aware of these requests because Volkov communicated them to her, and she passed them along to Rajesh Malhotra or the finance team. She stated that she assumed this practice was "normal for multi-entity trading groups" and did not consider it unusual or suspicious. She stated she did not raise concerns about the payment routing with Hargrave, Fisk, or anyone else at Dunmore.
Ms. Sorokin denied any knowledge that the payment routing was designed to obscure connections to Volkhov Industrial Group JSC or to circumvent sanctions. She stated she had no understanding of the beneficial ownership of the intermediary entities and had not inquired into their identities or corporate structures.
ATTORNEY-CLIENT PRIVILEGED / ATTORNEY WORK PRODUCT / CONFIDENTIAL
X. Interactions with Gerald Fisk (Former CCO) and Compliance Function
Ms. Sorokin was asked in detail about her interactions with Gerald Fisk, then-Chief Compliance Officer of Dunmore Energy Holdings Ltd. Mr. Fisk departed Dunmore on June 10, 2022, approximately one week after this interview. He subsequently retained Catherine Blackthorn of Blackthorn & Associates LLP, 700 Louisiana Street, Suite 4300, Houston, TX 77002, as personal counsel.
Ms. Sorokin stated that she had "very few" direct interactions with Fisk during her tenure at DTI. She stated that the compliance function was based in Houston and operated at a significant geographic and operational remove from the Dubai trading desk. She recalled one specific phone call with Fisk in approximately the third quarter of 2020 (Q3 2020), during which Fisk asked general questions about the Dubai desk's active counterparty list. She understood this conversation to be part of an annual compliance review or audit process. She stated she provided Fisk with a list of DTI's active counterparties, including Petronova Trading FZE, and "assumed that was sufficient" to satisfy any compliance review requirements. She did not recall Fisk asking follow-up questions about any specific counterparty during that call.
Ms. Sorokin stated that she did not recall Fisk or any member of the Houston compliance team ever flagging Petronova Trading FZE or Zenith Petroleum DMCC as presenting sanctions risk, requiring enhanced due diligence, or being subject to any trading restrictions or limitations. She stated she received no written or verbal communication from the compliance function indicating that either entity had been identified as a potential concern.
Ms. Sorokin stated that she never received any written compliance guidance, alerts, advisories, or training materials from Fisk or anyone in the compliance function specifically addressing any of the following topics:
(a) The Directive 2 sectoral sanctions under Executive Order 13662 and their application to intermediary trading transactions, including transactions in which a sanctioned entity's crude oil is sourced through an intermediary not itself named on a sanctions list;
(b) The OFAC 50% Rule and its application to entities that may be owned or controlled by SDN-listed persons or by persons on the Sectoral Sanctions Identifications (SSI) List; or
(c) Red flags or indicators of potential sanctions evasion in the commodity trading context, including the use of intermediary entities, opaque payment structures, or the loading of cargo at terminals associated with sanctioned operations.
Ms. Sorokin stated that compliance training at DTI was "minimal." She stated that the only compliance training she recalled receiving consisted of an online training module that she completed at the time of her onboarding in January 2018. She stated that this module covered general topics such as anti-money laundering, anti-bribery, and broad sanctions awareness, but did not address the specific sanctions programs or risk factors relevant to DTI's trading activities. She stated there were no annual refreshers, no desk-specific training, and no targeted training on Russian sanctions or the specific regulatory risks associated with intermediary crude oil trading.
ATTORNEY-CLIENT PRIVILEGED / ATTORNEY WORK PRODUCT / CONFIDENTIAL
XI. Interactions with Derek Hargrave
Ms. Sorokin was asked about Derek Hargrave's involvement in and knowledge of the Petronova Trading FZE and Zenith Petroleum DMCC transactions.
Ms. Sorokin stated that Hargrave approved all of the transactions at issue, either verbally or via email. She reiterated that transactions above the notional threshold required Hargrave's express sign-off, and she stated that she recalled presenting each of the Petronova transactions to Hargrave for approval. She was firm in her statement that Hargrave was "fully aware" of the Petronova relationship, the nature and scope of the transactions, and the identity of the counterparty.
Ms. Sorokin stated that Hargrave had met Sergei Volkov in person on multiple occasions. She described at least two business dinners in Dubai at which Hargrave and Volkov were both present, though she could not recall exact dates. She stated that Hargrave and Volkov appeared to have a cordial professional relationship and that Hargrave was familiar with Volkov's role at Petronova and with Petronova's position in the market.
Notably, Ms. Sorokin stated that it was Hargrave who "encouraged" her to develop and expand the Petronova relationship. She stated that Hargrave viewed the Petronova business as a significant opportunity to increase DTI's trading volume and profitability, and that he was actively supportive of growing the account. She stated that Hargrave expressed satisfaction with the margins generated by the Petronova transactions and encouraged her to explore additional trading opportunities with Volkov.
Ms. Sorokin stated that Hargrave never expressed concern about sanctions risk related to Petronova, Volkov, or Petronova's crude oil sourcing arrangements. She stated she was not aware of any instance in which Hargrave raised sanctions concerns with the compliance function or with any other individual at Dunmore in connection with the Petronova relationship.
She stated that she was unaware of whether Hargrave conducted any independent due diligence on Petronova Trading FZE, on Volkov personally, or on the ultimate provenance of the crude oil sourced through Petronova. She stated that Hargrave did not, to her knowledge, request a compliance review of Petronova beyond whatever review may have been conducted as part of the standard counterparty onboarding process.
Note: Derek Hargrave was placed on administrative leave on July 1, 2022, approximately one month after this interview, and was separated from Dunmore on October 1, 2022. He retained James Overstreet of Overstreet & McClain PLLC, 2200 Ross Avenue, Suite 3600, Dallas, TX 75201, as personal counsel. His interview, conducted on May 25, 2022, is separately memorialized.
ATTORNEY-CLIENT PRIVILEGED / ATTORNEY WORK PRODUCT / CONFIDENTIAL
XII. Interactions with Omar Al-Rashidi
Ms. Sorokin was asked about Omar Al-Rashidi's involvement in and knowledge of the Petronova Trading FZE relationship and the transactions at issue.
Ms. Sorokin stated that Al-Rashidi, in his capacity as Head of Middle East Operations, was aware of the Petronova relationship. She stated that Al-Rashidi participated in some introductory meetings with Sergei Volkov, consistent with his role in regional business development and counterparty relationship management. She described his involvement as primarily occurring at the origination stage and stated that he did not participate in the negotiation or execution of individual trades.
Significantly, Ms. Sorokin stated that Al-Rashidi made a comment to her in approximately mid-2021 suggesting that "Petronova's oil was Volkhov oil," or words to that effect. Ms. Sorokin stated this comment was made in a casual, conversational context — she believed it occurred during a discussion on the trading floor — and that she interpreted it as market speculation or gossip rather than a factual assertion based on verified information. She stated that Al-Rashidi did not present the statement as the result of any independent research or due diligence, and she described his tone as "offhand" rather than urgent or alarmed.
When asked why she did not follow up on Al-Rashidi's comment, escalate it to the compliance function, or raise it with Derek Hargrave, Ms. Sorokin stated that she did not consider it credible enough to warrant action. She stated that "people on the trading floor say a lot of things" and that she did not treat every piece of market speculation as a compliance matter. She acknowledged, however, that in retrospect, the comment should have prompted further inquiry.
Ms. Sorokin stated that she did not know whether Al-Rashidi reported his concern to anyone else at Dunmore — including Hargrave, Fisk, Wellbourne, or any other individual.
Note: Omar Al-Rashidi was subsequently identified as a cooperating witness in the investigation. He participated in a DOJ follow-up interview on July 12, 2023, which is separately documented.
ATTORNEY-CLIENT PRIVILEGED / ATTORNEY WORK PRODUCT / CONFIDENTIAL
XIII. Sorokin's Assessment of Her Own Conduct
At the conclusion of the substantive questioning, Ms. Sorokin was asked for her overall assessment of her conduct in connection with the Petronova and Zenith Petroleum transactions.
Ms. Sorokin maintained that she acted in good faith throughout the relevant period and consistent with the prevailing practices on the DTI trading desk. She stated that she carried out her trading responsibilities diligently and in the manner she understood to be expected by DTI management. She stated that at no time did she believe she was engaging in transactions that violated U.S. sanctions or any other applicable law.
She stated that she relied on the compliance function — specifically Gerald Fisk and his team in Houston — to conduct sanctions screening, OFAC list checks, and beneficial ownership verification of DTI's counterparties. She stated that she was not trained or equipped to independently assess sanctions risk, and that the organizational structure at Dunmore placed responsibility for compliance oversight with the Houston compliance team rather than with individual traders on the Dubai desk. She stated that the compliance function was the designated gatekeeper for sanctions compliance, and that its failure to flag the Petronova relationship gave her confidence that the transactions were permissible.
Ms. Sorokin acknowledged, however, that in hindsight, she "should have asked more questions" about Petronova's beneficial ownership structure and about the sourcing arrangements through which Petronova obtained its crude oil supply. She acknowledged that the mid-2021 comment from Omar Al-Rashidi — that "Petronova's oil was Volkhov oil" — was a potential red flag that she should have investigated or escalated, even if she considered it to be unverified market speculation at the time.
She denied any intent to violate U.S. sanctions, to assist Volkhov Industrial Group JSC in evading sanctions, or to structure transactions for the purpose of circumventing OFAC-administered programs. She stated emphatically that she did not act with knowledge that the transactions involved sanctioned parties or sanctioned-origin crude oil.
Ms. Sorokin expressed her willingness to continue cooperating with the internal investigation and stated that she would make herself available for follow-up interviews as requested. She reiterated her understanding that cooperation was expected by Dunmore and stated that she intended to comply fully.
ATTORNEY-CLIENT PRIVILEGED / ATTORNEY WORK PRODUCT / CONFIDENTIAL
XIV. Documents Referenced and Reviewed During Interview
The following documents were referenced and/or reviewed by Ms. Sorokin during the course of the interview:
1. Schedule of 14 crude oil swap transactions (June 2020 – February 2022), reflecting a total notional value of approximately $218.7 million, prepared by Ridgeline Advisory Group LLC, Engagement No. RAG-2022-0319.
2. Select email correspondence between Natasha Sorokin and Sergei Volkov (Petronova Trading FZE), extracted from DTI's email systems and produced as part of the internal investigation document collection.
3. Select Meridian Services Inc. message exports from Ms. Sorokin's personal mobile device, collected pursuant to the litigation hold notice issued by Dunmore on April 20, 2022, and processed by Nexagen Analytics Inc. (Project No. NX-DEH-2204).
4. Petronova Trading FZE corporate documentation, including trade license and certificate of incorporation from the Jebel Ali Free Zone Authority.
5. Select wire transfer records from Crescent Commercial Bank PJSC, reflecting payments in connection with the transactions at issue.
6. Select bills of lading and cargo documentation for crude oil shipments associated with the Petronova and Zenith Petroleum transactions.
Ms. Sorokin reviewed each document when presented and was asked questions based on the documents' contents. Her responses to document-specific questions are reflected in the substantive sections of this memorandum.
ATTORNEY-CLIENT PRIVILEGED / ATTORNEY WORK PRODUCT / CONFIDENTIAL
XV. Credibility Assessment and Open Questions
Credibility Observations
Ms. Sorokin was generally responsive throughout the interview and provided detailed, coherent accounts of deal execution, the organizational structure at DTI, and the counterparty relationships at issue. She appeared to have a strong recollection of the trading mechanics and the commercial terms of the transactions, consistent with her role as the executing trader. She was forthcoming in acknowledging her use of Meridian Services Inc. for business communications and in describing the informal compliance processes that prevailed on the Dubai trading desk.
However, her claimed lack of awareness regarding connections between Petronova Trading FZE and Volkhov Industrial Group JSC is at tension with several facts established during the interview and through the broader investigation:
(a) The surname similarity between "Volkov" (Petronova's Managing Director) and "Volkhov" (chairman of Volkhov Industrial Group), which, while not conclusive, is a natural basis for inquiry, particularly given Ms. Sorokin's Russian-language fluency and familiarity with the Russian energy market;
(b) The mid-2021 comment from Omar Al-Rashidi that "Petronova's oil was Volkhov oil," which, regardless of Ms. Sorokin's characterization of it as unverified market speculation, should have triggered further inquiry or escalation, particularly in the context of a compliance environment in which the trader bore some responsibility for identifying and surfacing potential red flags;
(c) The loading of crude oil cargoes at terminals historically associated with Volkhov-controlled operations, which Ms. Sorokin acknowledged she was aware of from bills of lading and shipping documentation but did not independently investigate; and
(d) Volkov's requests that payments be directed to entities other than Petronova itself, which Ms. Sorokin acknowledged but dismissed as "normal for multi-entity trading groups."
Ms. Sorokin's description of her reliance on the compliance function, while potentially factually accurate as a description of the organizational division of labor at DTI, also suggests a conscious decision not to inquire further into matters that a reasonably situated trader — particularly one with her background, language skills, and market expertise — might have found warranting additional scrutiny. Her posture throughout the interview was consistent with a narrative of organizational dysfunction and inadequate compliance infrastructure, which, if credited, would tend to shift responsibility from individual traders to the compliance function and to management.
Open Questions for Further Investigation
The following questions remain open and should be addressed through further investigative steps:
1. Meridian Services Inc. Message Review: Full review of Meridian Services Inc. messages between Sorokin and Volkov to determine whether Volkhov Industrial Group connections, beneficial ownership, or sourcing arrangements were discussed directly in private communications. The messages processed by Nexagen Analytics Inc. (Project No. NX-DEH-2204) should be reviewed in their entirety, with particular attention to messages exchanged around the mid-2021 time frame, when Al-Rashidi's comment was made.
2. Cross-Reference with Hargrave Interview: Cross-referencing Ms. Sorokin's account — including her statements regarding Hargrave's approval of all transactions, his encouragement of the Petronova relationship, and his meetings with Volkov — with Derek Hargrave's interview memorandum (conducted May 25, 2022, separately memorialized) to identify any inconsistencies or corroborative details.
3. Counterparty Onboarding Verification: Verification of Ms. Sorokin's claim that she submitted Petronova Trading FZE's corporate documentation to Gerald Fisk and the Houston compliance team for review and approval. This should include a search of Fisk's email records and the compliance function's files for any record of receipt, review, or clearance of Petronova documentation.
4. Zenith Petroleum / Farhan Qureshi Analysis: Further analysis of the specific transactions that Ms. Sorokin identified as involving Zenith Petroleum DMCC, and determination of Farhan Qureshi's relationship with Volkov, including any corporate, financial, or familial connections between Qureshi, Zenith Petroleum, and Volkhov-connected entities.
5. Al-Rashidi Debriefing Cross-Reference: Cross-referencing with Omar Al-Rashidi's debriefing and any subsequent DOJ interview to determine what he communicated regarding his mid-2021 statement about "Petronova's oil" being "Volkhov oil," whether he escalated the concern to anyone at Dunmore, and whether his account is consistent with Ms. Sorokin's recollection.
6. Trade Capture System Records: Review of DTI's trade capture system records to verify Hargrave's approval of each of the 14 transactions above the $10 million notional threshold, including whether approval was documented in the system or only communicated verbally.
7. Sorokin's Role Selection: Whether Ms. Sorokin's dual Russian-American nationality, her Russian-language fluency, and her prior professional experience in the Russian crude oil market played a role in her selection as the primary point of contact with Russian-origin counterparties, and whether this selection was a deliberate management decision by Hargrave or arose organically.
ATTORNEY-CLIENT PRIVILEGED / ATTORNEY WORK PRODUCT / CONFIDENTIAL
XVI. Next Steps
Based on the information obtained during this interview, the following next steps are recommended:
1. Second-Round Interview of Ms. Sorokin: A second-round interview of Ms. Sorokin is recommended after the completion of the full Meridian Services Inc. message review (Nexagen Analytics Inc., Project No. NX-DEH-2204) and the ongoing forensic accounting analysis by Ridgeline Advisory Group LLC (Engagement No. RAG-2022-0319). The second interview should focus on any communications or financial records that are inconsistent with Ms. Sorokin's statements during this initial interview, and should probe more deeply into her knowledge of Petronova's beneficial ownership and Volkhov connections.
2. Jurisdictional Nexus Analysis: Coordinate with Conrad Reeves on whether Ms. Sorokin's specific trading activities — as a United States citizen — independently establish the jurisdictional nexus required for potential violations of the International Emergency Economic Powers Act, 50 U.S.C. §§ 1701–1706, regardless of DTI's Cayman Islands incorporation and UAE operational domicile. As a U.S. person, Ms. Sorokin is subject to OFAC regulations wherever she is located and regardless of the nationality or domicile of her employer. This analysis should be cross-referenced with Jasmine Thornton's corporate structure and U.S. person analysis memorandum dated May 10, 2022, which addresses the broader question of Dunmore's U.S. person connections and IEEPA jurisdictional exposure.
3. Personal Counsel Advisory: It is recommended that Ms. Sorokin be advised, through appropriate channels, that she may wish to retain personal counsel in light of the investigation's potential trajectory. Given the nature of the facts disclosed during this interview — including her role as the executing trader on all 14 transactions, her status as a U.S. citizen, and her acknowledged awareness of potential Volkhov connections — the possibility of individual liability exposure cannot be excluded. (Note: Ms. Sorokin subsequently retained Philip Keane of Wexford Keane LLP, 2000 K Street NW, Suite 650, Washington, DC 20006, in September 2022. She was separated from Dunmore on September 15, 2022.)
4. Privilege and Distribution: This interview memorandum is to be maintained under attorney-client privilege and attorney work product protection. Distribution is limited to the Calderwood & Harkness LLP investigation team — specifically, Victoria Chambers, Howard Quinn, Conrad Reeves, Jasmine Thornton, Liam Donahue, and Nicholas Ferreira — and to Marcus Wellbourne, General Counsel of Dunmore Energy Holdings Ltd. It is noted that Dunmore may elect to waive privilege and disclose the substance of this memorandum to the DOJ as part of its cooperation strategy, and that any such waiver decision should be made at the direction of Victoria Chambers and Marcus Wellbourne in consultation with the full investigation team.
ATTORNEY-CLIENT PRIVILEGED / ATTORNEY WORK PRODUCT / CONFIDENTIAL
XVII. Signatures / Distribution
This memorandum was prepared by the undersigned and has been reviewed by the Responsible Partner prior to distribution.
Prepared by:
________________________________________
Jasmine Thornton Lead Associate Calderwood & Harkness LLP
________________________________________
Liam Donahue Working Associate Calderwood & Harkness LLP
Reviewed and Approved by:
________________________________________
Victoria Chambers Responsible Partner Calderwood & Harkness LLP
Date: ________