interview-memo-omar-al-rashidi.docx

1016-00009 · Dunmore Energy Holdings · Witness Interviews

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PRIVILEGED AND CONFIDENTIAL ATTORNEY-CLIENT PRIVILEGE / ATTORNEY WORK PRODUCT PREPARED IN ANTICIPATION OF LITIGATION — DO NOT DISTRIBUTE

This memorandum is a privileged and confidential communication prepared by Calderwood & Harkness LLP in the course of its representation of Dunmore Energy Holdings Ltd. and its subsidiaries, including Dunmore Trading International Ltd. This document was prepared at the direction of counsel in anticipation of litigation and in connection with the provision of legal advice. It is protected from disclosure by the attorney-client privilege, the work product doctrine, and all other applicable privileges. This memorandum should not be disclosed to any person outside the Calderwood & Harkness investigation team without the express written authorization of Victoria Chambers, Responsible Partner.

CALDERWOOD & HARKNESS LLP White Collar Defense & Investigations Practice Group

Matter: Dunmore Energy Holdings Ltd. — DOJ Sanctions & Export Controls Inquiry Matter No.: 1016-00009 Document Type: Witness Interview Memorandum Date of Memorandum: June 14, 2022

Prepared By: Jasmine Thornton, Lead Associate, White Collar & Investigations, Calderwood & Harkness LLP (Washington, D.C.)

Reviewed By: Victoria Chambers, Responsible Partner, White Collar & Investigations, Calderwood & Harkness LLP (Washington, D.C.)

WITNESS INTERVIEW MEMORANDUM

Interview of Omar Al-Rashidi

Head of Middle East Operations, Dunmore Trading International Ltd.

June 14, 2022

I. Interview Logistics

Witness: Omar Al-Rashidi, Head of Middle East Operations, Dunmore Trading International Ltd. ("DTI"), a wholly-owned subsidiary of Dunmore Energy Holdings Ltd. ("Dunmore" or the "Company").

Date of Interview: June 14, 2022.

Time: 9:00 a.m. to 1:45 p.m. Gulf Standard Time (GST). The interview lasted approximately four hours and forty-five minutes, including one fifteen-minute break taken at approximately 11:15 a.m. GST.

Location: Calderwood & Harkness LLP conference room (Conference Room 14-C), Level 14, Gate Building 3, Dubai International Financial Centre ("DIFC"), Dubai, United Arab Emirates. This conference room is co-located with, and situated on the same floor as, DTI's principal office at the same address.

Interviewer(s):

• Jasmine Thornton, Lead Associate, White Collar & Investigations, Calderwood & Harkness LLP, Washington, D.C. (lead interviewer)

• Amara Osei, Associate, White Collar & Investigations, Calderwood & Harkness LLP, London (second chair and primary notetaker)

Counsel for Witness: None. Mr. Al-Rashidi was not represented by personal counsel during this interview and did not request the presence or assistance of personal counsel. At the outset of the interview, Mr. Al-Rashidi was advised of his right to retain personal counsel at his own expense, or to seek advancement of legal fees under Dunmore's existing indemnification obligations as set forth in the DTI Employee Handbook and applicable subsidiary organizational documents. Mr. Al-Rashidi acknowledged this advisement and affirmatively stated that he did not wish to retain personal counsel at this time.

Court Reporter / Recording: No court reporter was present and no audio or video recording of the interview was made. Detailed contemporaneous handwritten notes were taken by Amara Osei throughout the duration of the interview. These notes have been maintained in the privileged investigation files and are available for review by the investigation team.

Status of Witness: Mr. Al-Rashidi is a current employee of DTI in good standing. He has been identified as a cooperating witness for purposes of the internal investigation. Mr. Al-Rashidi has been cooperative since the outset of the internal investigation initiated in April 2022 and has voluntarily provided information and access to his business files and records without reservation or objection. There is no indication at this time that Mr. Al-Rashidi is a subject or target of the DOJ inquiry.

Interview Number: This is Mr. Al-Rashidi's first formal interview in connection with this investigation. He is witness number 18 of 22 witnesses identified for first-round interviews scheduled during the period of May 18, 2022 through June 30, 2022, pursuant to the Witness Interview Schedule approved by Victoria Chambers on May 10, 2022.

II. Upjohn Warnings Administered

At the outset of the interview, prior to any substantive questioning, Jasmine Thornton administered the standard Upjohn corporate Miranda warning to Mr. Al-Rashidi. The warnings were delivered in accordance with the Witness Interview Protocol dated April 18, 2022, which was prepared by Victoria Chambers and distributed to all members of the Calderwood & Harkness investigation team. The warnings were delivered orally in English, which Mr. Al-Rashidi confirmed is one of his primary business languages and the language in which he is fully fluent.

The following key points were communicated to Mr. Al-Rashidi:

1. Identity of the Client. Calderwood & Harkness LLP represents Dunmore Energy Holdings Ltd. and its subsidiaries, including Dunmore Trading International Ltd. Calderwood & Harkness does not represent Mr. Al-Rashidi in his personal capacity. The firm's obligations of loyalty, confidentiality, and advocacy run to the Company, not to Mr. Al-Rashidi individually.

2. Purpose of the Interview. The purpose of this interview is to gather facts in connection with an internal investigation being conducted by Calderwood & Harkness at the direction of Dunmore's General Counsel, Marcus Wellbourne, in connection with a United States Department of Justice inquiry concerning potential violations of U.S. sanctions laws and export control regulations. The investigation is being conducted to enable the Company to obtain legal advice and to assess the Company's legal position and obligations.

3. Ownership of the Privilege. The attorney-client privilege applicable to the communications in this interview belongs to Dunmore Energy Holdings Ltd. and its subsidiaries, not to Mr. Al-Rashidi personally. Mr. Al-Rashidi does not have the right to assert or waive the privilege with respect to the substance of this interview.

4. Potential Waiver and Disclosure to Government. Dunmore may, at its sole discretion, choose to waive the attorney-client privilege and disclose the substance of this interview, including Mr. Al-Rashidi's statements, to the U.S. Department of Justice, the Office of Foreign Assets Control ("OFAC") of the U.S. Department of the Treasury, or other government agencies. Such a decision would be made by the Company's authorized representatives, in consultation with counsel, as part of the Company's response to the government inquiry.

5. Obligation of Truthfulness. Mr. Al-Rashidi is expected to be truthful and complete in his responses to all questions posed during this interview. Providing false or misleading information could have serious consequences, including potential adverse employment actions and potential legal liability.

6. Right to Personal Counsel. Mr. Al-Rashidi has the right to retain personal legal counsel at his own expense. He may also seek advancement of legal fees under Dunmore's existing indemnification obligations, subject to the terms and conditions of the applicable corporate documents and policies. Mr. Al-Rashidi acknowledged that he understood this right and affirmatively stated that he did not wish to retain personal counsel at this time. He indicated that he was comfortable proceeding with the interview without personal representation.

7. Confidentiality of Interview. Mr. Al-Rashidi was instructed not to discuss the substance of this interview, the questions asked, or his responses with other Dunmore or DTI employees, former employees, or any third parties. He was advised that unauthorized disclosure of the contents of this interview could compromise the integrity of the investigation and could result in adverse consequences.

Mr. Al-Rashidi confirmed orally that he understood each of the foregoing points. He did not raise any questions or objections. He stated, in substance: "I understand. I am happy to cooperate fully and answer your questions." He agreed to proceed with the interview on the terms described.

III. Background and Role at DTI

A. Personal Background

Mr. Al-Rashidi provided the following personal background information. His full name is Omar Al-Rashidi. He is a national of the United Arab Emirates (Emirati citizen). He is approximately 41 years of age at the time of this interview. He holds a Bachelor's degree in Business Administration from a university in the UAE and a Master of Business Administration (MBA) from a university in the United Kingdom. The specific institutions were noted but are not considered material to the investigation and are not reproduced here. Mr. Al-Rashidi currently resides in Dubai, United Arab Emirates, and has resided in the UAE for the entirety of his professional career.

B. Employment History at Dunmore

Mr. Al-Rashidi stated that he joined Dunmore Trading International Ltd. in 2015 in the capacity of Senior Business Development Manager. In this initial role, his responsibilities included identifying and cultivating new business relationships with counterparties throughout the Middle East region, with a particular focus on crude oil and refined products trading opportunities in the Arabian Gulf states.

In early 2018, Mr. Al-Rashidi was promoted to the position of Head of Middle East Operations at DTI. This promotion reflected his expanded responsibilities, which encompassed oversight of DTI's entire portfolio of relationships with Middle Eastern counterparties, supervision of a regional business development team, coordination with DTI's trading desk on regional deal execution, and liaison with regional banking and logistics partners.

From the time of his promotion in 2018 through June 2022, Mr. Al-Rashidi reported directly to Derek Hargrave, President of DTI. This reporting relationship was in place continuously from early 2018 until Hargrave's placement on administrative leave effective July 1, 2022. Mr. Al-Rashidi confirmed that he was informed of Hargrave's administrative leave status and that, following Hargrave's leave, he currently reports to interim management designated by Callum Renshaw, Chief Executive Officer of Dunmore Energy Holdings Ltd., based in Houston, Texas.

Mr. Al-Rashidi described his current responsibilities as follows:

• Oversight of DTI's relationships with Middle Eastern counterparties across the crude oil, refined products, and oilfield services sectors.

• Business development for crude oil and refined products trading in the Gulf region, including the identification of new trading opportunities and the management of existing counterparty relationships.

• Liaison with regional banking partners, principally Crescent Commercial Bank PJSC, on trade finance matters.

• Liaison with regional logistics partners on transportation and shipment coordination.

• Coordination with DTI's traders and the trading desk on deal execution for transactions involving Middle Eastern counterparties.

• General management and supervision of the Middle East Operations team based in DTI's Dubai office.

C. Team Structure

Mr. Al-Rashidi stated that his Middle East Operations team consists of approximately eight staff members, all of whom are based in DTI's Dubai office at Level 14, Gate Building 3, DIFC. The team includes business development professionals, a regional coordinator, and administrative support staff. Mr. Al-Rashidi described his team as primarily focused on relationship management and business development rather than trade execution.

Mr. Al-Rashidi confirmed that his team interfaces directly with several other key DTI personnel whose roles are relevant to this investigation:

• Natasha Sorokin (Senior Trader, DTI): Ms. Sorokin was the most active trader on the DTI trading desk and served as the primary point of contact with many of DTI's counterparties in the region. Mr. Al-Rashidi confirmed that he did not have direct supervisory authority over Ms. Sorokin; she reported to Hargrave on all trading matters. Ms. Sorokin was placed on administrative leave on May 16, 2022, in connection with the ongoing investigation.

• Yves Leclerc (Director of Logistics & Shipping, DTI): Mr. Leclerc was responsible for coordinating the logistics, shipping, and transportation aspects of DTI's trading and equipment export activities. Mr. Al-Rashidi's team coordinated with Leclerc on regional logistics matters, including port and terminal arrangements.

• Rajesh Malhotra (Controller, DTI): Mr. Malhotra served as DTI's controller and was responsible for financial recordkeeping, payment processing, and wire transfer execution for the Dubai office. Mr. Al-Rashidi stated that Malhotra handled the operational aspects of payment flows for the trading desk.

Mr. Al-Rashidi further identified his primary external banking relationship for the region as being with Crescent Commercial Bank PJSC. He stated that DTI's relationship manager at Crescent Commercial Bank was Khalid Mansour, with whom Mr. Al-Rashidi had regular contact regarding trade finance facilities, letters of credit, and general banking services.

IV. Knowledge of Key Counterparties

A. Petronova Trading FZE

Mr. Al-Rashidi stated that he first became aware of Petronova Trading FZE ("Petronova") in approximately early 2020, which he estimated as around March 2020. This timeframe is consistent with the earliest suspect transaction in the investigation timeline identified by the Calderwood & Harkness team and the Ridgeline Advisory Group forensic analysis.

Mr. Al-Rashidi described Petronova as a commodity trading firm registered in the Jebel Ali Free Zone in Dubai, with its registered office located at Office 1407, Al Shafar Tower, Dubai Internet City. He understood Petronova to be a trading intermediary engaged in crude oil and petroleum products trading, primarily in the Middle East and CIS markets.

Mr. Al-Rashidi stated that the primary relationship with Petronova was managed by Natasha Sorokin, who introduced the counterparty to DTI's trading desk. Mr. Al-Rashidi recalled that Sorokin presented Petronova as a well-connected trading house with access to desirable crude oil parcels and swap counterparties. He did not recall the specific circumstances of the introduction but stated that Sorokin appeared to have a pre-existing familiarity with Petronova's principals.

Mr. Al-Rashidi stated that he personally met Sergei Volkov, Managing Director of Petronova, on approximately two occasions:

1. First Meeting (estimated late 2020): A business dinner in Dubai arranged by Sorokin. Mr. Al-Rashidi recalled that the dinner took place at a restaurant in the DIFC area and was attended by Sorokin, Volkov, Al-Rashidi, and possibly one or two other DTI staff members. He described the dinner as primarily social and relationship-building in nature. He stated that Volkov was cordial and presented himself as an experienced commodities trader.

2. Second Meeting (estimated mid-2021): A meeting at DTI's offices in the DIFC. Mr. Al-Rashidi believed this meeting was arranged by Sorokin to discuss ongoing trading activity. He recalled that Hargrave may also have attended this meeting, but he was not entirely certain of Hargrave's presence.

Mr. Al-Rashidi described Volkov as a Russian national residing in the United Arab Emirates who presented himself as a commodities trader with extensive connections in the CIS markets, including Russia, Kazakhstan, and Azerbaijan. Mr. Al-Rashidi did not recall Volkov providing detailed information about Petronova's ownership structure or its relationships with upstream counterparties during either of their meetings.

When asked whether he was aware of any connection between Petronova or Sergei Volkov and Volkhov Industrial Group JSC ("VIG" or "Volkhov"), Mr. Al-Rashidi stated unequivocally that he had no knowledge of any such connection at the time the relevant transactions were conducted. He stated that he first learned of the potential connection between Petronova and Volkhov Industrial Group in April 2022, when Gerald Fisk, then-Chief Compliance Officer of Dunmore, circulated an internal alert regarding the designation of Volkhov Industrial Group on the OFAC Specially Designated Nationals and blocked Persons List ("SDN List") on April 6, 2022, pursuant to Executive Order 14024. Mr. Al-Rashidi stated that the internal alert prompted him to revisit his understanding of the Petronova relationship and that, upon reflection, the potential connection was deeply concerning.

Mr. Al-Rashidi made an additional, unsolicited observation on this point. He noted that the surname similarity between "Volkov" (the managing director of Petronova) and "Volkhov" (the sanctioned Russian industrial conglomerate and its chairman, Arkady Volkhov) did not register with him as significant at the time of the transactions. He acknowledged, however, that in hindsight this similarity should have been recognized as a potential red flag warranting additional due diligence. He characterized this as an oversight and stated that he took responsibility for not having been more attentive to this detail.

B. Zenith Petroleum DMCC

Mr. Al-Rashidi stated that he was familiar with Zenith Petroleum DMCC ("Zenith Petroleum"), a petroleum trading company registered in the Dubai Multi Commodities Centre ("DMCC"). He identified Zenith Petroleum's registered address as Unit 2201, Jumeirah Bay Tower X2, Cluster X, Jumeirah Lakes Towers, Dubai.

He identified Farhan Qureshi as the Managing Director of Zenith Petroleum. Mr. Al-Rashidi described Qureshi as a Pakistani national residing in the United Arab Emirates. He stated that he had limited personal interaction with Qureshi and described their contact as infrequent and primarily limited to a small number of introductory or social exchanges in the context of DTI's broader counterparty relationships.

Mr. Al-Rashidi described Zenith Petroleum as a smaller, Dubai-based petroleum trading company that DTI had engaged in what he characterized as "a handful" of crude oil swap transactions. He did not recall the precise number of transactions with Zenith Petroleum but indicated it was a less active counterparty relationship than DTI's relationship with Petronova.

He stated that Zenith Petroleum was introduced to DTI by Natasha Sorokin, in a manner similar to the introduction of Petronova. He did not recall the specific timeline of the introduction but believed it was sometime in 2020, following the establishment of the Petronova relationship.

Mr. Al-Rashidi stated that he was not directly involved in negotiating the specific commercial terms of the Zenith Petroleum transactions. His awareness of these transactions was based on his general oversight of regional counterparty activity and his review of periodic trading desk reports, rather than direct participation in deal structuring or execution.

When asked whether Zenith Petroleum had any ties or connections to Volkhov Industrial Group, Mr. Al-Rashidi stated that he was unable to confirm or deny the existence of any such ties based on his own knowledge. He deferred to the findings of the forensic investigation being conducted by the Ridgeline Advisory Group and the Calderwood & Harkness team.

C. Volkhov Industrial Group JSC

Mr. Al-Rashidi confirmed that he was generally aware of Volkhov Industrial Group JSC as a major Russian industrial conglomerate. He identified the company as being chaired by Arkady Volkhov and headquartered at 12 Kutuzovsky Prospekt, Moscow, Russia. He described Volkhov Industrial Group as a diversified conglomerate with significant operations in the Russian energy, metals, and industrial sectors.

Mr. Al-Rashidi stated that he was generally aware that Volkhov Industrial Group had been subject to OFAC sectoral sanctions under Directive 2 of Executive Order 13662 since approximately November 15, 2019. However, he stated that he was "not closely tracking" OFAC designation lists on a regular basis, as he considered sanctions screening and list monitoring to be the responsibility of Dunmore's compliance function, which was managed by Gerald Fisk and his team in Houston. Mr. Al-Rashidi stated that he relied on the Houston compliance team to flag any counterparty issues arising from sanctions designations and that he did not independently consult the OFAC SDN List or other sanctions lists as part of his day-to-day responsibilities.

Mr. Al-Rashidi was unequivocal in stating that he was not aware of any direct transactions between DTI and Volkhov Industrial Group. He stated that all of DTI's dealings, to his knowledge, were conducted with intermediary counterparties, specifically Petronova Trading FZE and Zenith Petroleum DMCC, and that he had no reason to believe at the time that these intermediaries were connected to or acting on behalf of Volkhov Industrial Group or any sanctioned entity.

D. Caspian Logistik GmbH

Mr. Al-Rashidi stated that he had limited involvement with Caspian Logistik GmbH ("Caspian Logistik"), a logistics company registered at Mönckebergstraße 22, 20095 Hamburg, Germany, and managed by Klaus Weidemann. He described Caspian Logistik as a logistics and freight forwarding company that he understood to have been used for the shipment of oilfield equipment and related components.

Mr. Al-Rashidi stated that the coordination of logistics and shipping arrangements, including the engagement of Caspian Logistik, was primarily managed by Yves Leclerc, Director of Logistics & Shipping at DTI. He stated that Leclerc reported to Hargrave on these matters and that the specific details of shipping arrangements, freight forwarding contracts, and related documentation were handled by Leclerc's team.

Mr. Al-Rashidi recalled that some equipment shipments were arranged through Caspian Logistik at Hargrave's direction, but he stated that he was not involved in the specifics of these arrangements, including end-user certifications, export licensing applications, or shipping documentation. He characterized his awareness of the Caspian Logistik relationship as general and peripheral.

When asked about the approximately $12.4 million in oilfield equipment exports that have been identified as potentially problematic in the investigation, Mr. Al-Rashidi deferred all detailed knowledge on this topic to Leclerc and Hargrave. He stated that he did not have sufficient information to address the specifics of these transactions.

V. Description of Trading Desk Operations and Transaction Approval Process

A. General Trading Desk Structure

Mr. Al-Rashidi provided a description of DTI's Dubai trading desk operations that is relevant to understanding the context in which the transactions at issue were executed. He described the DTI Dubai trading desk as a relatively small operation, comprising approximately 15 to 20 staff members in total, including traders, support staff, and operations personnel. The desk operated under DTI's DIFC license (License No. CL-4827).

The trading desk's primary activities included crude oil and refined products trading, consisting of spot purchases and sales, forward contracts, and swap transactions. In addition, the desk facilitated some procurement of oilfield equipment and services for DTI's counterparties and affiliates. Mr. Al-Rashidi described the desk as an active but not unusually large trading operation by Dubai standards.

Derek Hargrave, as President of DTI, had ultimate authority over all transactions executed by the trading desk. Mr. Al-Rashidi was clear that Hargrave was the final decision-maker on all material trading decisions and that no significant transaction was executed without Hargrave's knowledge and approval.

Natasha Sorokin was the most active trader on the desk. Mr. Al-Rashidi described her as a highly skilled trader who generated a significant portion of the desk's revenue. According to Mr. Al-Rashidi, Sorokin had significant autonomy in identifying counterparties and structuring transactions, subject to Hargrave's approval. He stated that Sorokin operated with a degree of independence that, while not unusual in the commodities trading industry, was notable within the context of DTI's relatively small operation.

B. Transaction Approval Workflow

Mr. Al-Rashidi described the standard transaction approval workflow for the DTI trading desk as follows:

1. Deal Identification: Traders, primarily Sorokin, would identify a transaction opportunity through counterparty outreach, market monitoring, or inbound inquiries. The trader would conduct initial discussions with the counterparty to establish the basic commercial terms.

2. Deal Ticket Preparation: Upon reaching preliminary agreement on commercial terms, the trader would prepare a deal ticket summarizing the key terms of the transaction, including the counterparty identity, the commodity involved, the notional value, pricing terms, delivery or settlement terms, and any other material provisions.

3. Counterparty Screening: Prior to execution, the counterparty was supposed to be screened against OFAC sanctions lists and other applicable restricted party lists using Dunmore's sanctions screening software. This screening was administered from Houston by the compliance team under Gerald Fisk. A screening request would be submitted, and the compliance team would return a clearance or flag any potential matches.

4. Approval by Hargrave: For transactions above a certain threshold, which Mr. Al-Rashidi believed to be $10 million in notional value, Hargrave was required to approve the deal in writing, typically via email. For transactions below this threshold, Mr. Al-Rashidi was less certain of the formal approval requirements but stated that Hargrave was generally informed of all transactions.

5. Execution: Upon receipt of Hargrave's approval (and, nominally, compliance clearance), the trader would execute the transaction with the counterparty.

Mr. Al-Rashidi noted, however, that the described workflow was the nominal or intended process. In practice, he observed several departures from this process that he considered significant in the context of the current investigation.

Specifically, Mr. Al-Rashidi stated that compliance screening of counterparties was "not always timely." He explained that the screening process was managed by the Houston compliance team, which operated in a time zone eight to nine hours behind Dubai. This time zone differential created practical delays in obtaining screening results, particularly for transactions that arose during the Dubai business day when the Houston office was closed or operating at reduced capacity.

As a result, Mr. Al-Rashidi stated, Sorokin and Hargrave sometimes executed transactions before receiving compliance clearance from Houston. This was particularly common when market conditions were time-sensitive — for example, when a crude oil parcel was available at a favorable price and required rapid commitment. In these situations, Mr. Al-Rashidi stated, traders would execute the deal and submit the screening request simultaneously or after execution, with the expectation that any compliance issues would be identified and addressed retroactively.

Mr. Al-Rashidi expressed concern, in hindsight, about this practice. He stated that the compliance function in Houston had limited visibility into the Dubai desk's day-to-day activities and that the screening protocols, as implemented, were "more reactive than proactive." He acknowledged that this created a vulnerability in Dunmore's sanctions compliance framework that could have allowed problematic transactions to be executed without adequate pre-transaction screening.

C. Crude Oil Swap Transactions with Petronova and Zenith Petroleum

Mr. Al-Rashidi confirmed his general awareness of crude oil swap transactions conducted between DTI and Petronova Trading FZE and Zenith Petroleum DMCC during the approximate period of June 2020 through February 2022. He described these as commodity swap transactions in which DTI and the counterparty would exchange cash flows based on the price differential of specified crude oil benchmarks, with settlement typically occurring through physical delivery or financial settlement depending on the specific terms of each transaction.

When asked to estimate the number of transactions with Petronova, Mr. Al-Rashidi stated that there were "roughly a dozen, maybe more." This estimate is broadly consistent with the 14 flagged crude oil swap transactions with Petronova totaling approximately $218.7 million in aggregate notional value that have been identified as part of the investigation's forensic review.

Mr. Al-Rashidi confirmed that Sorokin was the primary negotiator and point of contact for the Petronova and Zenith Petroleum transactions. Hargrave approved each transaction, consistent with the standard approval workflow described above. Mr. Al-Rashidi stated that his own role in these specific transactions was largely peripheral. While he was involved in broader regional relationship management and general oversight of counterparty activity in the Middle East, he did not negotiate the commercial terms of the individual swap transactions with Petronova or Zenith Petroleum.

Mr. Al-Rashidi recalled that some of the transactions involved crude oil sourced from or destined for entities in Russia or the Commonwealth of Independent States ("CIS"), which he described as consistent with the general trading patterns of the Dubai-based commodities market. However, he stated that he was not aware of the specific counterparty chains beyond Petronova and Zenith Petroleum — that is, he did not know the identity of the ultimate counterparties or beneficiaries on the other side of Petronova's or Zenith Petroleum's trades.

When asked specifically about the nine transactions later identified in the forensic analysis as "tainted" — meaning those with an aggregate notional value of approximately $156.3 million that have been identified as involving Volkhov-connected entities on the other side of the intermediary chain — Mr. Al-Rashidi stated that he could not distinguish which specific transactions involved Volkhov-connected entities without the benefit of reviewing the forensic analysis. He stated that the transactions appeared, from his vantage point, to be routine commodity swap transactions with Dubai-based counterparties and that nothing in the commercial terms or documentation that he reviewed flagged a connection to Volkhov Industrial Group.

VI. Knowledge of Payment Structuring

A. Awareness of Crescent Commercial Bank Payment Flows

Mr. Al-Rashidi confirmed that Crescent Commercial Bank PJSC ("Crescent Bank") was DTI's primary trade finance bank in the Dubai region. He identified the bank's head office as located in Al Maktoum Tower, DIFC, and confirmed that DTI's relationship manager at Crescent Bank was Khalid Mansour. Mr. Al-Rashidi described Crescent Bank as a well-established regional bank with which DTI maintained letters of credit, trade finance facilities, and transactional banking accounts.

Mr. Al-Rashidi stated that payment processing and wire transfers for the trading desk were primarily handled by Rajesh Malhotra, DTI's Controller. He stated that Malhotra was responsible for the operational mechanics of processing payment instructions, initiating wire transfers, and reconciling trade settlements. Mr. Al-Rashidi stated that he was not directly involved in the preparation or execution of payment instructions or wire transfers on a transaction-by-transaction basis.

The interviewing team presented Mr. Al-Rashidi with a general description of the structured payment flows identified in the forensic analysis: approximately $34.2 million routed through intermediary accounts at Crescent Commercial Bank across 127 individual transactions during the period from March 2020 through March 2022. Mr. Al-Rashidi was not shown specific documents at this stage but was asked whether he was aware of this payment activity.

Mr. Al-Rashidi stated that he was aware, in general terms, that payments to Petronova Trading FZE and Zenith Petroleum DMCC were processed through DTI's accounts at Crescent Bank. This was consistent with his understanding of DTI's standard payment processing procedures. However, he stated that he was not aware that payments were being structured through intermediary accounts, as described in the forensic analysis. He stated that he understood the payments to be direct transfers to the counterparties' accounts and that he had no knowledge of layered or intermediary payment routing.

Mr. Al-Rashidi expressed visible surprise at the volume of transactions — 127 individual wire transfers — and stated that this number "seemed unusual" given the relatively limited number of underlying commercial transactions with Petronova and Zenith Petroleum. He stated that if the underlying commercial transactions numbered approximately 14 to 20, a volume of 127 wire transfers suggested a degree of fragmentation or structuring that would warrant closer examination.

Mr. Al-Rashidi confirmed that he did not have authority to approve wire transfers. He stated that approval authority for wire transfers rested with Hargrave for amounts above a certain threshold (which Mr. Al-Rashidi did not specify precisely) and with Malhotra for routine payments within established parameters.

B. Observations Regarding Unusual Payment Patterns

Mr. Al-Rashidi volunteered a specific observation that he acknowledged could be relevant to the investigation's analysis of payment structuring. He stated that on at least one occasion, which he estimated to have occurred sometime in late 2021, he observed Malhotra at his workstation processing what appeared to be multiple smaller wire transfers to the same beneficiary account on the same day. Mr. Al-Rashidi described this activity as "splitting payments" — that is, breaking a larger payment amount into several smaller individual transfers.

Mr. Al-Rashidi stated that he asked Malhotra about this practice informally. He characterized the conversation as brief and casual, not a formal inquiry. According to Mr. Al-Rashidi, Malhotra explained the practice as "standard practice to comply with bank processing limits." Mr. Al-Rashidi stated that Malhotra's explanation seemed plausible to him at the time and that he did not probe further or seek independent verification of whether Crescent Bank imposed processing limits that would necessitate the splitting of payments.

Mr. Al-Rashidi acknowledged that he did not escalate this observation to the compliance function in Houston (Gerald Fisk) or to Hargrave. He stated that, in hindsight, the practice of splitting payments into multiple smaller transfers is a recognized indicator of potential structuring activity and that he should have raised it as a potential red flag warranting investigation by the compliance team. He stated that his failure to escalate was not motivated by any intent to conceal the activity but rather by his assumption that Malhotra's explanation was adequate and that payment processing matters fell outside the scope of his direct responsibilities.

VII. Knowledge of Derek Hargrave's and Natasha Sorokin's Activities

A. Derek Hargrave

Mr. Al-Rashidi provided substantive observations regarding Derek Hargrave's management style, involvement with key counterparties, and conduct during the relevant period. These observations are relevant to the investigation's assessment of Hargrave's role in the transactions at issue.

Mr. Al-Rashidi described Hargrave as a "hands-on" manager who was deeply involved in the trading desk's day-to-day activities. He stated that Hargrave took a personal interest in the commercial details of significant transactions and that he personally cultivated relationships with key counterparties. This management style, according to Mr. Al-Rashidi, was characteristic of Hargrave throughout his tenure as President of DTI and was generally viewed within the organization as a reflection of his experience and industry knowledge.

Mr. Al-Rashidi stated that Hargrave traveled frequently, both within the UAE and internationally, to meet with counterparties and business partners. He stated that some of these trips were, to his belief, related to the Petronova and/or Zenith Petroleum relationships, although he could not identify specific trip dates or destinations without reference to Hargrave's travel records. He recalled that Hargrave occasionally mentioned meetings or dinners with counterparties that he associated with the Petronova relationship.

Mr. Al-Rashidi made a significant observation regarding Hargrave's attitude toward the Petronova relationship. He stated that Hargrave was "very protective" of the Petronova relationship and that he discouraged other DTI staff from conducting independent due diligence on Petronova beyond what was required by the standard compliance checklist. Mr. Al-Rashidi described this as unusual. He stated that, while Hargrave was generally hands-on with respect to important counterparties, the degree of protectiveness he exhibited toward Petronova was more pronounced than with other counterparty relationships. Mr. Al-Rashidi interpreted this at the time as Hargrave's desire to manage the relationship personally and to avoid disrupting a profitable trading channel, rather than as evidence of any improper motive.

Mr. Al-Rashidi further recalled a specific instance in which the compliance team in Houston, under Gerald Fisk's direction, raised questions about a Petronova-related transaction. Mr. Al-Rashidi estimated that this occurred in approximately mid-2021, although he could not provide a precise date without reference to email records. He stated that Fisk or a member of Fisk's team communicated concerns to the DTI office regarding certain aspects of a Petronova transaction, the details of which Mr. Al-Rashidi could not recall specifically. Hargrave "handled it directly," according to Mr. Al-Rashidi, and subsequently informed Al-Rashidi and other DTI staff that the matter was "resolved." Mr. Al-Rashidi stated that Hargrave did not share the specifics of his communications with Fisk or the Houston compliance team, and that Mr. Al-Rashidi did not inquire further. He accepted Hargrave's representation that the compliance issue had been satisfactorily addressed.

Mr. Al-Rashidi did not have visibility into the substance of Hargrave's communications with Fisk or the Houston compliance team regarding this incident, and he was unable to assess whether Hargrave's characterization of the matter as "resolved" was accurate.

B. Natasha Sorokin

Mr. Al-Rashidi also provided observations regarding Natasha Sorokin that are relevant to the investigation's understanding of her role and activities.

Mr. Al-Rashidi described Sorokin as a "highly skilled" but "independent" trader who operated with significant latitude from Hargrave. He stated that Sorokin was widely regarded within DTI as one of the desk's top performers and that her trading activity generated significant revenue for the company. He noted, however, that her independence — her ability to identify counterparties, structure transactions, and manage relationships with relatively limited oversight beyond Hargrave's approval — was greater than that of other traders on the desk.

Mr. Al-Rashidi stated that Sorokin is a Russian-American dual national. He observed that she appeared to have pre-existing personal or professional connections with Sergei Volkov, the Managing Director of Petronova Trading FZE. He recalled that when the Petronova relationship was first established, Sorokin referenced "old contacts" in explaining how she had identified Petronova as a potential counterparty. Mr. Al-Rashidi did not inquire further into the nature of these pre-existing connections at the time.

Mr. Al-Rashidi raised an additional observation regarding Sorokin's communications practices. He stated that Sorokin communicated with counterparties using both her official DTI email (the Company's standard email platform) and, he believed, personal encrypted messaging applications. He stated that on multiple occasions during office hours, he observed Sorokin using what appeared to be an encrypted messaging application on her personal mobile phone. He was unable to identify the specific application but described it as appearing to be an end-to-end encrypted messaging platform. He stated that he did not know the content of these communications and could not confirm whether the communications were business-related, personal, or both.

Mr. Al-Rashidi stated that he did not raise the issue of Sorokin's use of personal encrypted messaging for business purposes with Hargrave, Fisk, or any other individual within the organization. He acknowledged that the use of personal encrypted messaging for business communications, if such communications related to DTI's trading activity, would be inconsistent with the Company's records retention policies and could impede the ability of the compliance function to monitor counterparty communications.

Mr. Al-Rashidi confirmed that he was aware Sorokin was placed on administrative leave effective May 16, 2022, and that he had been informed this action was related to the ongoing investigation. He stated that he has had no communications with Sorokin since her placement on leave and that he understood he should not contact her or discuss the investigation with her.

VIII. Knowledge of Compliance Function and Gerald Fisk

A. Pre-Existing Compliance Program

Mr. Al-Rashidi provided his assessment of Dunmore's pre-existing sanctions compliance program as it operated during the period relevant to this investigation. His observations are relevant to the investigation's evaluation of the adequacy of the Company's compliance infrastructure and any potential defenses based on the existence or quality of the compliance program.

Mr. Al-Rashidi described Dunmore's sanctions compliance program as "basic" and "Houston-centric." He stated that the program was designed and administered from the Company's headquarters in Houston, Texas, under the direction of Gerald Fisk, who held the title of Chief Compliance Officer. The program's primary mechanism for sanctions compliance was a screening software system that checked counterparty names against the OFAC SDN List and other relevant sanctions lists.

Mr. Al-Rashidi noted several structural features of the compliance program that he considered relevant:

• Centralized Administration: OFAC screening and sanctions compliance were conducted by the compliance team in Houston. The Dubai office, despite being the location of DTI's trading desk and the site of the Company's most active counterparty relationships, did not have a dedicated compliance officer or compliance function. All compliance matters originating in Dubai were routed to Houston for processing and review.

• Time Zone Challenges: The time zone difference between Dubai (GST, UTC+4) and Houston (CST/CDT, UTC-6/-5) created a gap of approximately eight to nine hours. This differential resulted in practical delays in the turnaround of counterparty screening requests submitted by the Dubai desk. Screening requests submitted during the Dubai business day often could not be processed until the following Houston business day, by which time market conditions may have changed or the transaction may have already been executed.

• Software-Based Screening: The compliance program relied primarily on automated name-matching software to screen counterparties against sanctions lists. Mr. Al-Rashidi did not have detailed knowledge of the software's capabilities, configuration, or limitations, but he observed that the screening appeared to be a name-based matching exercise without more comprehensive due diligence (such as beneficial ownership analysis or network mapping).

Mr. Al-Rashidi stated that the combination of centralized Houston-based administration, time zone delays, and limited on-the-ground compliance presence in Dubai contributed to the practice, described above, of traders executing transactions before receiving compliance clearance.

B. Gerald Fisk

Mr. Al-Rashidi described his interactions with Gerald Fisk, DTI's Chief Compliance Officer, as occurring primarily via email and occasional video calls. These interactions typically related to counterparty screening requests submitted by the Dubai office or to periodic compliance updates disseminated by Fisk's team.

Mr. Al-Rashidi described Fisk as "responsive but stretched thin." He stated that Fisk appeared to be managing compliance responsibilities across all Dunmore entities globally — not only DTI but also Dunmore Energy Holdings Ltd. and its other subsidiaries — with a limited staff. Mr. Al-Rashidi's impression was that Fisk was personally dedicated to his compliance responsibilities but that the resources allocated to the compliance function were insufficient for the scope and complexity of Dunmore's global operations.

Mr. Al-Rashidi stated that he was aware Gerald Fisk departed Dunmore on June 10, 2022. He was told by management that Fisk's departure was voluntary, although he stated he was not aware of the specific circumstances surrounding the departure. He confirmed that he had been notified that Catherine Blackthorn, of the law firm Blackthorn & Associates LLP in Houston, had been retained as Fisk's personal counsel in connection with matters related to this investigation. Mr. Al-Rashidi stated he had no contact with Fisk or Fisk's counsel since Fisk's departure.

C. Red Flags and Escalation

In a portion of the interview that the investigation team considers particularly significant, Mr. Al-Rashidi was asked to identify, with the benefit of hindsight, any red flags that he observed during the relevant period that he now believes should have been escalated to the compliance function, to legal counsel, or to senior management.

Mr. Al-Rashidi acknowledged that, in retrospect, several red flags were present that should have prompted more aggressive inquiry and escalation. He identified the following:

1. Introduction of Petronova through Personal Connections: Petronova Trading FZE was introduced to DTI's trading desk by Natasha Sorokin through what appeared to be her personal or pre-existing professional connections, rather than through DTI's standard counterparty onboarding process. Mr. Al-Rashidi acknowledged that the use of personal connections to introduce a counterparty, while not inherently improper, should have prompted enhanced due diligence to verify the counterparty's bona fides and to assess any potential conflicts of interest.

2. Surname Similarity Between "Volkov" and "Volkhov." The similarity between the surname of Petronova's Managing Director (Sergei Volkov) and the name of the sanctioned Russian conglomerate (Volkhov Industrial Group / Arkady Volkhov) should have been recognized as a potential indicator of a relationship between the two entities. Mr. Al-Rashidi acknowledged that this similarity did not register with him at the time and that, in hindsight, it should have triggered additional screening and investigation.

3. Volume and Pattern of Payments Through Crescent Commercial Bank. The volume of individual wire transfers (127 transactions for $34.2 million) relative to the number of underlying commercial transactions was disproportionate and suggestive of payment structuring. Mr. Al-Rashidi acknowledged that his observation of Malhotra "splitting payments" was consistent with this concern and should have been escalated.

4. Hargrave's Protectiveness Over the Petronova Relationship. Hargrave's discouragement of independent due diligence on Petronova and his insistence on personally managing compliance inquiries related to Petronova were unusual and should have been recognized as potential indicators that Hargrave was seeking to limit scrutiny of the relationship.

5. Sorokin's Use of Personal Encrypted Messaging. The use of personal encrypted messaging applications for what may have been business communications with counterparties was inconsistent with the Company's records retention policies and could have been motivated by a desire to avoid corporate oversight of those communications.

Mr. Al-Rashidi stated that he did not escalate any of these concerns during the relevant period. He offered the following explanation for his failure to do so: at the time, he believed that Hargrave, as President of DTI, and the Houston compliance team under Fisk were handling matters appropriately and that the compliance process, while imperfect, was functioning within acceptable parameters. He also stated that he "did not want to overstep" his role, given that Hargrave was his direct supervisor and that compliance matters were formally the responsibility of Fisk's team in Houston. He acknowledged that this reasoning was inadequate and that he should have been more assertive in raising concerns, regardless of his position in the organizational hierarchy.

IX. Knowledge of Oilfield Equipment Exports

Mr. Al-Rashidi stated that the oilfield equipment export activities under investigation were primarily managed by Yves Leclerc, Director of Logistics & Shipping at DTI, under the direction of Derek Hargrave. Mr. Al-Rashidi's involvement in these activities was minimal.

He stated that he was generally aware that DTI facilitated shipments of oilfield drilling equipment and related components to various destinations as part of its broader business activities. However, he was not involved in the specifics of these activities, including export licensing, export classification, end-user certification, or the preparation of export documentation.

When asked about specific Export Administration Regulations ("EAR") classifications, including Export Control Classification Numbers ("ECCNs") 2B350 and 2B999, Mr. Al-Rashidi stated that he was not familiar with these specific classifications and that export control compliance was not part of his responsibilities or area of expertise. He stated that matters related to EAR compliance and export licensing were handled by Leclerc's team and, to his understanding, were subject to oversight by the compliance function in Houston.

Mr. Al-Rashidi deferred all questions regarding the approximately $12.4 million in oilfield equipment exports that have been identified as potentially problematic, including shipments arranged through Caspian Logistik GmbH, to Leclerc and Hargrave as the individuals with direct knowledge and responsibility for these transactions.

X. Knowledge of Tobias Engel and Dunmore Renewables GmbH Transaction

When asked about any knowledge of transactions involving Dunmore Renewables GmbH, a Dunmore subsidiary based in Hamburg, Germany, and managed by Tobias Engel, Mr. Al-Rashidi stated that he had no knowledge of any such transactions.

Specifically, he stated that he was not aware of any transaction between Dunmore Renewables GmbH and Caspian Logistik GmbH. He confirmed that he had never met, spoken with, or communicated with Tobias Engel in any capacity. He further stated that the renewables business operated by Dunmore Renewables GmbH was entirely separate from DTI's trading operations and that he had no visibility into or involvement with the activities of that subsidiary.

XI. Post-April 2022 Events and Cooperation

A. Discovery of Potential Volkhov Exposure

Mr. Al-Rashidi provided the following account of the events following the discovery of DTI's potential exposure to Volkhov Industrial Group.

He confirmed that on or about April 11, 2022, Gerald Fisk sent an internal email to Dunmore personnel, including recipients at the DTI Dubai office, alerting them that a routine OFAC screening refresh had identified potential historical exposure to Volkhov Industrial Group through Petronova Trading FZE. This alert was precipitated by the addition of Volkhov Industrial Group JSC to the OFAC SDN List on April 6, 2022, pursuant to Executive Order 14024, which expanded the scope of Russian sanctions in response to Russia's further invasion of Ukraine.

Mr. Al-Rashidi stated that he reviewed Fisk's internal alert and that it caused him significant concern regarding DTI's historical transactions with Petronova. He stated that the alert was the first time he became aware of a potential connection between Petronova and Volkhov Industrial Group.

He stated that Marcus Wellbourne, General Counsel of Dunmore Energy Holdings Ltd. (Houston), contacted the DTI office shortly after the circulation of Fisk's alert and instructed all staff to preserve all records, documents, and communications that could be relevant to the matter. Mr. Al-Rashidi stated that he understood the seriousness of the instruction and immediately took steps to ensure that his files and records were preserved.

Mr. Al-Rashidi confirmed that he received a formal litigation hold notice from Calderwood & Harkness LLP, dated April 20, 2022, which directed him to preserve all documents and communications potentially relevant to the investigation. He stated that he has complied with all preservation obligations set forth in the litigation hold notice, including the preservation of emails, electronic files, calendar entries, and any handwritten notes within his possession or control.

B. Willingness to Cooperate

Mr. Al-Rashidi affirmatively stated his willingness to cooperate fully with the internal investigation being conducted by Calderwood & Harkness on behalf of Dunmore Energy Holdings Ltd. and its subsidiaries. He stated that he understands the importance of the investigation and is committed to providing complete and truthful information to the investigation team.

He further stated that he is prepared to be interviewed by the U.S. Department of Justice if such an interview is requested by Dunmore and Calderwood & Harkness. He indicated that he understands that such an interview may be appropriate as part of the Company's cooperation with the government and that he is willing to participate, subject to any advice he receives from counsel.

Mr. Al-Rashidi confirmed the following additional points:

• He has not destroyed, altered, concealed, or disposed of any documents, communications, files, or other records related to the matters under investigation, whether in physical or electronic form.

• He has not communicated with Derek Hargrave, Natasha Sorokin, or any counsel representing those individuals since they were placed on administrative leave. He understands that any such communication would be inappropriate and potentially harmful to the investigation.

• He is willing to make himself available for further interviews by the Calderwood & Harkness investigation team, at times and locations that are mutually convenient, and to provide any additional documents or information within his possession or control that may be relevant to the investigation.

XII. Documents Identified / Requested for Follow-Up

During the course of the interview, the investigation team identified several categories of documents and materials that Mr. Al-Rashidi agreed to provide access to for purposes of the investigation:

1. DTI Email Archive: Mr. Al-Rashidi agreed to provide access to his complete DTI email archive for the period from January 2019 to the present. This collection will be performed by Nexagen Analytics Inc. (Project No. NX-DEH-2204), the e-discovery vendor engaged by Calderwood & Harkness for this matter. Mr. Al-Rashidi stated that he will cooperate with Nexagen's technical team to facilitate the collection process.

2. Personal Notes and Files Relating to Petronova: Mr. Al-Rashidi agreed to identify and produce any personal notes, memoranda, or files in his possession relating to meetings with Sergei Volkov, other Petronova representatives, or the Petronova counterparty relationship generally.

3. Calendar Entries: Mr. Al-Rashidi agreed to provide access to his electronic calendar entries for the period 2020 through 2022, with particular attention to entries reflecting meetings with counterparties, including Petronova, Zenith Petroleum, Crescent Commercial Bank, and any other relevant third parties.

4. Personal Device Communications: Mr. Al-Rashidi agreed to provide access to any text or messaging communications on his personal devices that relate to DTI business. He stated that he primarily used his DTI-issued devices (laptop, mobile phone) for business communications and that he did not use personal encrypted messaging applications for DTI matters. This stands in contrast to the reported practices of Natasha Sorokin, as described above. Nonetheless, Mr. Al-Rashidi consented to a review of his personal devices to confirm the absence of relevant business communications.

XIII. Credibility and Cooperation Assessment

Overall Assessment: Mr. Al-Rashidi was forthcoming, composed, and detailed in his responses throughout the approximately four hours and forty-five minutes of the interview. He answered questions directly and, where he did not have specific knowledge, clearly delineated the boundaries of his awareness without attempting to speculate or fill gaps with conjecture. He did not appear evasive, defensive, or inclined to minimize his awareness of relevant events. His demeanor was consistent and professional throughout, and he did not exhibit signs of deception or discomfort when addressing sensitive topics.

Credibility Indicators: Mr. Al-Rashidi's account is internally consistent and does not contain contradictions or material inconsistencies. His recollections regarding timelines, personnel, and counterparty interactions are generally aligned with the documentary record that the investigation team has reviewed to date, including email communications, deal tickets, and organizational charts. Notably, his admissions regarding red flags that should have been escalated — including his own failure to escalate concerns about payment structuring, Hargrave's protectiveness over the Petronova relationship, and Sorokin's use of encrypted messaging — enhance his credibility. Witnesses who acknowledge their own shortcomings and mistakes are generally viewed as more reliable by government investigators than those who present themselves as wholly blameless.

Potential Vulnerabilities: Notwithstanding the positive credibility assessment, the investigation team notes that Mr. Al-Rashidi's failure to escalate observed red flags could present vulnerabilities in a government interview or enforcement context. Specifically, his failure to report the payment structuring activity he observed (Malhotra "splitting payments"), his failure to flag the surname similarity between Volkov and Volkhov, and his failure to question Hargrave's protectiveness over the Petronova relationship could be characterized by government investigators as negligent or, under an aggressive theory, as evidence of willful blindness — particularly given his seniority and his position as Head of Middle East Operations. However, the balance of evidence reviewed to date suggests that Mr. Al-Rashidi's inaction was passive in nature — attributable to deference to his supervisor and to the designated compliance function — rather than the product of deliberate intent to facilitate or conceal sanctions violations.

Recommendation: Based on the foregoing assessment, Mr. Al-Rashidi is a strong candidate for presentation to the DOJ as a cooperating witness. His willingness to cooperate, his candid acknowledgment of missed red flags, and his positioning as a current employee (not a subject or target of the inquiry) make him a valuable resource for demonstrating Dunmore's cooperation with the government under the DOJ Corporate Enforcement Policy (formerly the Principles of Federal Prosecution of Business Organizations). Victoria Chambers shou

PRIVILEGED AND CONFIDENTIAL ATTORNEY-CLIENT PRIVILEGE / ATTORNEY WORK PRODUCT PREPARED IN ANTICIPATION OF LITIGATION — DO NOT DISTRIBUTE
This memorandum is a privileged and confidential communication prepared by Calderwood & Harkness LLP in the course of its representation of Dunmore Energy Holdings Ltd. and its subsidiaries, including Dunmore Trading International Ltd. This document was prepared at the direction of counsel in anticipation of litigation and in connection with the provision of legal advice. It is protected from disclosure by the attorney-client privilege, the work product doctrine, and all other applicable privileges. This memorandum should not be disclosed to any person outside the Calderwood & Harkness investigation team without the express written authorization of Victoria Chambers, Responsible Partner.
CALDERWOOD & HARKNESS LLP White Collar Defense & Investigations Practice Group
Matter: Dunmore Energy Holdings Ltd. — DOJ Sanctions & Export Controls Inquiry Matter No.: 1016-00009 Document Type: Witness Interview Memorandum Date of Memorandum: June 14, 2022
Prepared By: Jasmine Thornton, Lead Associate, White Collar & Investigations, Calderwood & Harkness LLP (Washington, D.C.)
Reviewed By: Victoria Chambers, Responsible Partner, White Collar & Investigations, Calderwood & Harkness LLP (Washington, D.C.)
WITNESS INTERVIEW MEMORANDUM
Interview of Omar Al-Rashidi
Head of Middle East Operations, Dunmore Trading International Ltd.
June 14, 2022
I. Interview Logistics
Witness: Omar Al-Rashidi, Head of Middle East Operations, Dunmore Trading International Ltd. ("DTI"), a wholly-owned subsidiary of Dunmore Energy Holdings Ltd. ("Dunmore" or the "Company").
Date of Interview: June 14, 2022.
Time: 9:00 a.m. to 1:45 p.m. Gulf Standard Time (GST). The interview lasted approximately four hours and forty-five minutes, including one fifteen-minute break taken at approximately 11:15 a.m. GST.
Location: Calderwood & Harkness LLP conference room (Conference Room 14-C), Level 14, Gate Building 3, Dubai International Financial Centre ("DIFC"), Dubai, United Arab Emirates. This conference room is co-located with, and situated on the same floor as, DTI's principal office at the same address.
Interviewer(s):
• Jasmine Thornton, Lead Associate, White Collar & Investigations, Calderwood & Harkness LLP, Washington, D.C. (lead interviewer)
• Amara Osei, Associate, White Collar & Investigations, Calderwood & Harkness LLP, London (second chair and primary notetaker)
Counsel for Witness: None. Mr. Al-Rashidi was not represented by personal counsel during this interview and did not request the presence or assistance of personal counsel. At the outset of the interview, Mr. Al-Rashidi was advised of his right to retain personal counsel at his own expense, or to seek advancement of legal fees under Dunmore's existing indemnification obligations as set forth in the DTI Employee Handbook and applicable subsidiary organizational documents. Mr. Al-Rashidi acknowledged this advisement and affirmatively stated that he did not wish to retain personal counsel at this time.
Court Reporter / Recording: No court reporter was present and no audio or video recording of the interview was made. Detailed contemporaneous handwritten notes were taken by Amara Osei throughout the duration of the interview. These notes have been maintained in the privileged investigation files and are available for review by the investigation team.
Status of Witness: Mr. Al-Rashidi is a current employee of DTI in good standing. He has been identified as a cooperating witness for purposes of the internal investigation. Mr. Al-Rashidi has been cooperative since the outset of the internal investigation initiated in April 2022 and has voluntarily provided information and access to his business files and records without reservation or objection. There is no indication at this time that Mr. Al-Rashidi is a subject or target of the DOJ inquiry.
Interview Number: This is Mr. Al-Rashidi's first formal interview in connection with this investigation. He is witness number 18 of 22 witnesses identified for first-round interviews scheduled during the period of May 18, 2022 through June 30, 2022, pursuant to the Witness Interview Schedule approved by Victoria Chambers on May 10, 2022.
II. Upjohn Warnings Administered
At the outset of the interview, prior to any substantive questioning, Jasmine Thornton administered the standard Upjohn corporate Miranda warning to Mr. Al-Rashidi. The warnings were delivered in accordance with the Witness Interview Protocol dated April 18, 2022, which was prepared by Victoria Chambers and distributed to all members of the Calderwood & Harkness investigation team. The warnings were delivered orally in English, which Mr. Al-Rashidi confirmed is one of his primary business languages and the language in which he is fully fluent.
The following key points were communicated to Mr. Al-Rashidi:
1. Identity of the Client. Calderwood & Harkness LLP represents Dunmore Energy Holdings Ltd. and its subsidiaries, including Dunmore Trading International Ltd. Calderwood & Harkness does not represent Mr. Al-Rashidi in his personal capacity. The firm's obligations of loyalty, confidentiality, and advocacy run to the Company, not to Mr. Al-Rashidi individually.
2. Purpose of the Interview. The purpose of this interview is to gather facts in connection with an internal investigation being conducted by Calderwood & Harkness at the direction of Dunmore's General Counsel, Marcus Wellbourne, in connection with a United States Department of Justice inquiry concerning potential violations of U.S. sanctions laws and export control regulations. The investigation is being conducted to enable the Company to obtain legal advice and to assess the Company's legal position and obligations.
3. Ownership of the Privilege. The attorney-client privilege applicable to the communications in this interview belongs to Dunmore Energy Holdings Ltd. and its subsidiaries, not to Mr. Al-Rashidi personally. Mr. Al-Rashidi does not have the right to assert or waive the privilege with respect to the substance of this interview.
4. Potential Waiver and Disclosure to Government. Dunmore may, at its sole discretion, choose to waive the attorney-client privilege and disclose the substance of this interview, including Mr. Al-Rashidi's statements, to the U.S. Department of Justice, the Office of Foreign Assets Control ("OFAC") of the U.S. Department of the Treasury, or other government agencies. Such a decision would be made by the Company's authorized representatives, in consultation with counsel, as part of the Company's response to the government inquiry.
5. Obligation of Truthfulness. Mr. Al-Rashidi is expected to be truthful and complete in his responses to all questions posed during this interview. Providing false or misleading information could have serious consequences, including potential adverse employment actions and potential legal liability.
6. Right to Personal Counsel. Mr. Al-Rashidi has the right to retain personal legal counsel at his own expense. He may also seek advancement of legal fees under Dunmore's existing indemnification obligations, subject to the terms and conditions of the applicable corporate documents and policies. Mr. Al-Rashidi acknowledged that he understood this right and affirmatively stated that he did not wish to retain personal counsel at this time. He indicated that he was comfortable proceeding with the interview without personal representation.
7. Confidentiality of Interview. Mr. Al-Rashidi was instructed not to discuss the substance of this interview, the questions asked, or his responses with other Dunmore or DTI employees, former employees, or any third parties. He was advised that unauthorized disclosure of the contents of this interview could compromise the integrity of the investigation and could result in adverse consequences.
Mr. Al-Rashidi confirmed orally that he understood each of the foregoing points. He did not raise any questions or objections. He stated, in substance: "I understand. I am happy to cooperate fully and answer your questions." He agreed to proceed with the interview on the terms described.
III. Background and Role at DTI
A. Personal Background
Mr. Al-Rashidi provided the following personal background information. His full name is Omar Al-Rashidi. He is a national of the United Arab Emirates (Emirati citizen). He is approximately 41 years of age at the time of this interview. He holds a Bachelor's degree in Business Administration from a university in the UAE and a Master of Business Administration (MBA) from a university in the United Kingdom. The specific institutions were noted but are not considered material to the investigation and are not reproduced here. Mr. Al-Rashidi currently resides in Dubai, United Arab Emirates, and has resided in the UAE for the entirety of his professional career.
B. Employment History at Dunmore
Mr. Al-Rashidi stated that he joined Dunmore Trading International Ltd. in 2015 in the capacity of Senior Business Development Manager. In this initial role, his responsibilities included identifying and cultivating new business relationships with counterparties throughout the Middle East region, with a particular focus on crude oil and refined products trading opportunities in the Arabian Gulf states.
In early 2018, Mr. Al-Rashidi was promoted to the position of Head of Middle East Operations at DTI. This promotion reflected his expanded responsibilities, which encompassed oversight of DTI's entire portfolio of relationships with Middle Eastern counterparties, supervision of a regional business development team, coordination with DTI's trading desk on regional deal execution, and liaison with regional banking and logistics partners.
From the time of his promotion in 2018 through June 2022, Mr. Al-Rashidi reported directly to Derek Hargrave, President of DTI. This reporting relationship was in place continuously from early 2018 until Hargrave's placement on administrative leave effective July 1, 2022. Mr. Al-Rashidi confirmed that he was informed of Hargrave's administrative leave status and that, following Hargrave's leave, he currently reports to interim management designated by Callum Renshaw, Chief Executive Officer of Dunmore Energy Holdings Ltd., based in Houston, Texas.
Mr. Al-Rashidi described his current responsibilities as follows:
• Oversight of DTI's relationships with Middle Eastern counterparties across the crude oil, refined products, and oilfield services sectors.
• Business development for crude oil and refined products trading in the Gulf region, including the identification of new trading opportunities and the management of existing counterparty relationships.
• Liaison with regional banking partners, principally Crescent Commercial Bank PJSC, on trade finance matters.
• Liaison with regional logistics partners on transportation and shipment coordination.
• Coordination with DTI's traders and the trading desk on deal execution for transactions involving Middle Eastern counterparties.
• General management and supervision of the Middle East Operations team based in DTI's Dubai office.
C. Team Structure
Mr. Al-Rashidi stated that his Middle East Operations team consists of approximately eight staff members, all of whom are based in DTI's Dubai office at Level 14, Gate Building 3, DIFC. The team includes business development professionals, a regional coordinator, and administrative support staff. Mr. Al-Rashidi described his team as primarily focused on relationship management and business development rather than trade execution.
Mr. Al-Rashidi confirmed that his team interfaces directly with several other key DTI personnel whose roles are relevant to this investigation:
• Natasha Sorokin (Senior Trader, DTI): Ms. Sorokin was the most active trader on the DTI trading desk and served as the primary point of contact with many of DTI's counterparties in the region. Mr. Al-Rashidi confirmed that he did not have direct supervisory authority over Ms. Sorokin; she reported to Hargrave on all trading matters. Ms. Sorokin was placed on administrative leave on May 16, 2022, in connection with the ongoing investigation.
• Yves Leclerc (Director of Logistics & Shipping, DTI): Mr. Leclerc was responsible for coordinating the logistics, shipping, and transportation aspects of DTI's trading and equipment export activities. Mr. Al-Rashidi's team coordinated with Leclerc on regional logistics matters, including port and terminal arrangements.
• Rajesh Malhotra (Controller, DTI): Mr. Malhotra served as DTI's controller and was responsible for financial recordkeeping, payment processing, and wire transfer execution for the Dubai office. Mr. Al-Rashidi stated that Malhotra handled the operational aspects of payment flows for the trading desk.
Mr. Al-Rashidi further identified his primary external banking relationship for the region as being with Crescent Commercial Bank PJSC. He stated that DTI's relationship manager at Crescent Commercial Bank was Khalid Mansour, with whom Mr. Al-Rashidi had regular contact regarding trade finance facilities, letters of credit, and general banking services.
IV. Knowledge of Key Counterparties
A. Petronova Trading FZE
Mr. Al-Rashidi stated that he first became aware of Petronova Trading FZE ("Petronova") in approximately early 2020, which he estimated as around March 2020. This timeframe is consistent with the earliest suspect transaction in the investigation timeline identified by the Calderwood & Harkness team and the Ridgeline Advisory Group forensic analysis.
Mr. Al-Rashidi described Petronova as a commodity trading firm registered in the Jebel Ali Free Zone in Dubai, with its registered office located at Office 1407, Al Shafar Tower, Dubai Internet City. He understood Petronova to be a trading intermediary engaged in crude oil and petroleum products trading, primarily in the Middle East and CIS markets.
Mr. Al-Rashidi stated that the primary relationship with Petronova was managed by Natasha Sorokin, who introduced the counterparty to DTI's trading desk. Mr. Al-Rashidi recalled that Sorokin presented Petronova as a well-connected trading house with access to desirable crude oil parcels and swap counterparties. He did not recall the specific circumstances of the introduction but stated that Sorokin appeared to have a pre-existing familiarity with Petronova's principals.
Mr. Al-Rashidi stated that he personally met Sergei Volkov, Managing Director of Petronova, on approximately two occasions:
1. First Meeting (estimated late 2020): A business dinner in Dubai arranged by Sorokin. Mr. Al-Rashidi recalled that the dinner took place at a restaurant in the DIFC area and was attended by Sorokin, Volkov, Al-Rashidi, and possibly one or two other DTI staff members. He described the dinner as primarily social and relationship-building in nature. He stated that Volkov was cordial and presented himself as an experienced commodities trader.
2. Second Meeting (estimated mid-2021): A meeting at DTI's offices in the DIFC. Mr. Al-Rashidi believed this meeting was arranged by Sorokin to discuss ongoing trading activity. He recalled that Hargrave may also have attended this meeting, but he was not entirely certain of Hargrave's presence.
Mr. Al-Rashidi described Volkov as a Russian national residing in the United Arab Emirates who presented himself as a commodities trader with extensive connections in the CIS markets, including Russia, Kazakhstan, and Azerbaijan. Mr. Al-Rashidi did not recall Volkov providing detailed information about Petronova's ownership structure or its relationships with upstream counterparties during either of their meetings.
When asked whether he was aware of any connection between Petronova or Sergei Volkov and Volkhov Industrial Group JSC ("VIG" or "Volkhov"), Mr. Al-Rashidi stated unequivocally that he had no knowledge of any such connection at the time the relevant transactions were conducted. He stated that he first learned of the potential connection between Petronova and Volkhov Industrial Group in April 2022, when Gerald Fisk, then-Chief Compliance Officer of Dunmore, circulated an internal alert regarding the designation of Volkhov Industrial Group on the OFAC Specially Designated Nationals and blocked Persons List ("SDN List") on April 6, 2022, pursuant to Executive Order 14024. Mr. Al-Rashidi stated that the internal alert prompted him to revisit his understanding of the Petronova relationship and that, upon reflection, the potential connection was deeply concerning.
Mr. Al-Rashidi made an additional, unsolicited observation on this point. He noted that the surname similarity between "Volkov" (the managing director of Petronova) and "Volkhov" (the sanctioned Russian industrial conglomerate and its chairman, Arkady Volkhov) did not register with him as significant at the time of the transactions. He acknowledged, however, that in hindsight this similarity should have been recognized as a potential red flag warranting additional due diligence. He characterized this as an oversight and stated that he took responsibility for not having been more attentive to this detail.
B. Zenith Petroleum DMCC
Mr. Al-Rashidi stated that he was familiar with Zenith Petroleum DMCC ("Zenith Petroleum"), a petroleum trading company registered in the Dubai Multi Commodities Centre ("DMCC"). He identified Zenith Petroleum's registered address as Unit 2201, Jumeirah Bay Tower X2, Cluster X, Jumeirah Lakes Towers, Dubai.
He identified Farhan Qureshi as the Managing Director of Zenith Petroleum. Mr. Al-Rashidi described Qureshi as a Pakistani national residing in the United Arab Emirates. He stated that he had limited personal interaction with Qureshi and described their contact as infrequent and primarily limited to a small number of introductory or social exchanges in the context of DTI's broader counterparty relationships.
Mr. Al-Rashidi described Zenith Petroleum as a smaller, Dubai-based petroleum trading company that DTI had engaged in what he characterized as "a handful" of crude oil swap transactions. He did not recall the precise number of transactions with Zenith Petroleum but indicated it was a less active counterparty relationship than DTI's relationship with Petronova.
He stated that Zenith Petroleum was introduced to DTI by Natasha Sorokin, in a manner similar to the introduction of Petronova. He did not recall the specific timeline of the introduction but believed it was sometime in 2020, following the establishment of the Petronova relationship.
Mr. Al-Rashidi stated that he was not directly involved in negotiating the specific commercial terms of the Zenith Petroleum transactions. His awareness of these transactions was based on his general oversight of regional counterparty activity and his review of periodic trading desk reports, rather than direct participation in deal structuring or execution.
When asked whether Zenith Petroleum had any ties or connections to Volkhov Industrial Group, Mr. Al-Rashidi stated that he was unable to confirm or deny the existence of any such ties based on his own knowledge. He deferred to the findings of the forensic investigation being conducted by the Ridgeline Advisory Group and the Calderwood & Harkness team.
C. Volkhov Industrial Group JSC
Mr. Al-Rashidi confirmed that he was generally aware of Volkhov Industrial Group JSC as a major Russian industrial conglomerate. He identified the company as being chaired by Arkady Volkhov and headquartered at 12 Kutuzovsky Prospekt, Moscow, Russia. He described Volkhov Industrial Group as a diversified conglomerate with significant operations in the Russian energy, metals, and industrial sectors.
Mr. Al-Rashidi stated that he was generally aware that Volkhov Industrial Group had been subject to OFAC sectoral sanctions under Directive 2 of Executive Order 13662 since approximately November 15, 2019. However, he stated that he was "not closely tracking" OFAC designation lists on a regular basis, as he considered sanctions screening and list monitoring to be the responsibility of Dunmore's compliance function, which was managed by Gerald Fisk and his team in Houston. Mr. Al-Rashidi stated that he relied on the Houston compliance team to flag any counterparty issues arising from sanctions designations and that he did not independently consult the OFAC SDN List or other sanctions lists as part of his day-to-day responsibilities.
Mr. Al-Rashidi was unequivocal in stating that he was not aware of any direct transactions between DTI and Volkhov Industrial Group. He stated that all of DTI's dealings, to his knowledge, were conducted with intermediary counterparties, specifically Petronova Trading FZE and Zenith Petroleum DMCC, and that he had no reason to believe at the time that these intermediaries were connected to or acting on behalf of Volkhov Industrial Group or any sanctioned entity.
D. Caspian Logistik GmbH
Mr. Al-Rashidi stated that he had limited involvement with Caspian Logistik GmbH ("Caspian Logistik"), a logistics company registered at Mönckebergstraße 22, 20095 Hamburg, Germany, and managed by Klaus Weidemann. He described Caspian Logistik as a logistics and freight forwarding company that he understood to have been used for the shipment of oilfield equipment and related components.
Mr. Al-Rashidi stated that the coordination of logistics and shipping arrangements, including the engagement of Caspian Logistik, was primarily managed by Yves Leclerc, Director of Logistics & Shipping at DTI. He stated that Leclerc reported to Hargrave on these matters and that the specific details of shipping arrangements, freight forwarding contracts, and related documentation were handled by Leclerc's team.
Mr. Al-Rashidi recalled that some equipment shipments were arranged through Caspian Logistik at Hargrave's direction, but he stated that he was not involved in the specifics of these arrangements, including end-user certifications, export licensing applications, or shipping documentation. He characterized his awareness of the Caspian Logistik relationship as general and peripheral.
When asked about the approximately $12.4 million in oilfield equipment exports that have been identified as potentially problematic in the investigation, Mr. Al-Rashidi deferred all detailed knowledge on this topic to Leclerc and Hargrave. He stated that he did not have sufficient information to address the specifics of these transactions.
V. Description of Trading Desk Operations and Transaction Approval Process
A. General Trading Desk Structure
Mr. Al-Rashidi provided a description of DTI's Dubai trading desk operations that is relevant to understanding the context in which the transactions at issue were executed. He described the DTI Dubai trading desk as a relatively small operation, comprising approximately 15 to 20 staff members in total, including traders, support staff, and operations personnel. The desk operated under DTI's DIFC license (License No. CL-4827).
The trading desk's primary activities included crude oil and refined products trading, consisting of spot purchases and sales, forward contracts, and swap transactions. In addition, the desk facilitated some procurement of oilfield equipment and services for DTI's counterparties and affiliates. Mr. Al-Rashidi described the desk as an active but not unusually large trading operation by Dubai standards.
Derek Hargrave, as President of DTI, had ultimate authority over all transactions executed by the trading desk. Mr. Al-Rashidi was clear that Hargrave was the final decision-maker on all material trading decisions and that no significant transaction was executed without Hargrave's knowledge and approval.
Natasha Sorokin was the most active trader on the desk. Mr. Al-Rashidi described her as a highly skilled trader who generated a significant portion of the desk's revenue. According to Mr. Al-Rashidi, Sorokin had significant autonomy in identifying counterparties and structuring transactions, subject to Hargrave's approval. He stated that Sorokin operated with a degree of independence that, while not unusual in the commodities trading industry, was notable within the context of DTI's relatively small operation.
B. Transaction Approval Workflow
Mr. Al-Rashidi described the standard transaction approval workflow for the DTI trading desk as follows:
1. Deal Identification: Traders, primarily Sorokin, would identify a transaction opportunity through counterparty outreach, market monitoring, or inbound inquiries. The trader would conduct initial discussions with the counterparty to establish the basic commercial terms.
2. Deal Ticket Preparation: Upon reaching preliminary agreement on commercial terms, the trader would prepare a deal ticket summarizing the key terms of the transaction, including the counterparty identity, the commodity involved, the notional value, pricing terms, delivery or settlement terms, and any other material provisions.
3. Counterparty Screening: Prior to execution, the counterparty was supposed to be screened against OFAC sanctions lists and other applicable restricted party lists using Dunmore's sanctions screening software. This screening was administered from Houston by the compliance team under Gerald Fisk. A screening request would be submitted, and the compliance team would return a clearance or flag any potential matches.
4. Approval by Hargrave: For transactions above a certain threshold, which Mr. Al-Rashidi believed to be $10 million in notional value, Hargrave was required to approve the deal in writing, typically via email. For transactions below this threshold, Mr. Al-Rashidi was less certain of the formal approval requirements but stated that Hargrave was generally informed of all transactions.
5. Execution: Upon receipt of Hargrave's approval (and, nominally, compliance clearance), the trader would execute the transaction with the counterparty.
Mr. Al-Rashidi noted, however, that the described workflow was the nominal or intended process. In practice, he observed several departures from this process that he considered significant in the context of the current investigation.
Specifically, Mr. Al-Rashidi stated that compliance screening of counterparties was "not always timely." He explained that the screening process was managed by the Houston compliance team, which operated in a time zone eight to nine hours behind Dubai. This time zone differential created practical delays in obtaining screening results, particularly for transactions that arose during the Dubai business day when the Houston office was closed or operating at reduced capacity.
As a result, Mr. Al-Rashidi stated, Sorokin and Hargrave sometimes executed transactions before receiving compliance clearance from Houston. This was particularly common when market conditions were time-sensitive — for example, when a crude oil parcel was available at a favorable price and required rapid commitment. In these situations, Mr. Al-Rashidi stated, traders would execute the deal and submit the screening request simultaneously or after execution, with the expectation that any compliance issues would be identified and addressed retroactively.
Mr. Al-Rashidi expressed concern, in hindsight, about this practice. He stated that the compliance function in Houston had limited visibility into the Dubai desk's day-to-day activities and that the screening protocols, as implemented, were "more reactive than proactive." He acknowledged that this created a vulnerability in Dunmore's sanctions compliance framework that could have allowed problematic transactions to be executed without adequate pre-transaction screening.
C. Crude Oil Swap Transactions with Petronova and Zenith Petroleum
Mr. Al-Rashidi confirmed his general awareness of crude oil swap transactions conducted between DTI and Petronova Trading FZE and Zenith Petroleum DMCC during the approximate period of June 2020 through February 2022. He described these as commodity swap transactions in which DTI and the counterparty would exchange cash flows based on the price differential of specified crude oil benchmarks, with settlement typically occurring through physical delivery or financial settlement depending on the specific terms of each transaction.
When asked to estimate the number of transactions with Petronova, Mr. Al-Rashidi stated that there were "roughly a dozen, maybe more." This estimate is broadly consistent with the 14 flagged crude oil swap transactions with Petronova totaling approximately $218.7 million in aggregate notional value that have been identified as part of the investigation's forensic review.
Mr. Al-Rashidi confirmed that Sorokin was the primary negotiator and point of contact for the Petronova and Zenith Petroleum transactions. Hargrave approved each transaction, consistent with the standard approval workflow described above. Mr. Al-Rashidi stated that his own role in these specific transactions was largely peripheral. While he was involved in broader regional relationship management and general oversight of counterparty activity in the Middle East, he did not negotiate the commercial terms of the individual swap transactions with Petronova or Zenith Petroleum.
Mr. Al-Rashidi recalled that some of the transactions involved crude oil sourced from or destined for entities in Russia or the Commonwealth of Independent States ("CIS"), which he described as consistent with the general trading patterns of the Dubai-based commodities market. However, he stated that he was not aware of the specific counterparty chains beyond Petronova and Zenith Petroleum — that is, he did not know the identity of the ultimate counterparties or beneficiaries on the other side of Petronova's or Zenith Petroleum's trades.
When asked specifically about the nine transactions later identified in the forensic analysis as "tainted" — meaning those with an aggregate notional value of approximately $156.3 million that have been identified as involving Volkhov-connected entities on the other side of the intermediary chain — Mr. Al-Rashidi stated that he could not distinguish which specific transactions involved Volkhov-connected entities without the benefit of reviewing the forensic analysis. He stated that the transactions appeared, from his vantage point, to be routine commodity swap transactions with Dubai-based counterparties and that nothing in the commercial terms or documentation that he reviewed flagged a connection to Volkhov Industrial Group.
VI. Knowledge of Payment Structuring
A. Awareness of Crescent Commercial Bank Payment Flows
Mr. Al-Rashidi confirmed that Crescent Commercial Bank PJSC ("Crescent Bank") was DTI's primary trade finance bank in the Dubai region. He identified the bank's head office as located in Al Maktoum Tower, DIFC, and confirmed that DTI's relationship manager at Crescent Bank was Khalid Mansour. Mr. Al-Rashidi described Crescent Bank as a well-established regional bank with which DTI maintained letters of credit, trade finance facilities, and transactional banking accounts.
Mr. Al-Rashidi stated that payment processing and wire transfers for the trading desk were primarily handled by Rajesh Malhotra, DTI's Controller. He stated that Malhotra was responsible for the operational mechanics of processing payment instructions, initiating wire transfers, and reconciling trade settlements. Mr. Al-Rashidi stated that he was not directly involved in the preparation or execution of payment instructions or wire transfers on a transaction-by-transaction basis.
The interviewing team presented Mr. Al-Rashidi with a general description of the structured payment flows identified in the forensic analysis: approximately $34.2 million routed through intermediary accounts at Crescent Commercial Bank across 127 individual transactions during the period from March 2020 through March 2022. Mr. Al-Rashidi was not shown specific documents at this stage but was asked whether he was aware of this payment activity.
Mr. Al-Rashidi stated that he was aware, in general terms, that payments to Petronova Trading FZE and Zenith Petroleum DMCC were processed through DTI's accounts at Crescent Bank. This was consistent with his understanding of DTI's standard payment processing procedures. However, he stated that he was not aware that payments were being structured through intermediary accounts, as described in the forensic analysis. He stated that he understood the payments to be direct transfers to the counterparties' accounts and that he had no knowledge of layered or intermediary payment routing.
Mr. Al-Rashidi expressed visible surprise at the volume of transactions — 127 individual wire transfers — and stated that this number "seemed unusual" given the relatively limited number of underlying commercial transactions with Petronova and Zenith Petroleum. He stated that if the underlying commercial transactions numbered approximately 14 to 20, a volume of 127 wire transfers suggested a degree of fragmentation or structuring that would warrant closer examination.
Mr. Al-Rashidi confirmed that he did not have authority to approve wire transfers. He stated that approval authority for wire transfers rested with Hargrave for amounts above a certain threshold (which Mr. Al-Rashidi did not specify precisely) and with Malhotra for routine payments within established parameters.
B. Observations Regarding Unusual Payment Patterns
Mr. Al-Rashidi volunteered a specific observation that he acknowledged could be relevant to the investigation's analysis of payment structuring. He stated that on at least one occasion, which he estimated to have occurred sometime in late 2021, he observed Malhotra at his workstation processing what appeared to be multiple smaller wire transfers to the same beneficiary account on the same day. Mr. Al-Rashidi described this activity as "splitting payments" — that is, breaking a larger payment amount into several smaller individual transfers.
Mr. Al-Rashidi stated that he asked Malhotra about this practice informally. He characterized the conversation as brief and casual, not a formal inquiry. According to Mr. Al-Rashidi, Malhotra explained the practice as "standard practice to comply with bank processing limits." Mr. Al-Rashidi stated that Malhotra's explanation seemed plausible to him at the time and that he did not probe further or seek independent verification of whether Crescent Bank imposed processing limits that would necessitate the splitting of payments.
Mr. Al-Rashidi acknowledged that he did not escalate this observation to the compliance function in Houston (Gerald Fisk) or to Hargrave. He stated that, in hindsight, the practice of splitting payments into multiple smaller transfers is a recognized indicator of potential structuring activity and that he should have raised it as a potential red flag warranting investigation by the compliance team. He stated that his failure to escalate was not motivated by any intent to conceal the activity but rather by his assumption that Malhotra's explanation was adequate and that payment processing matters fell outside the scope of his direct responsibilities.
VII. Knowledge of Derek Hargrave's and Natasha Sorokin's Activities
A. Derek Hargrave
Mr. Al-Rashidi provided substantive observations regarding Derek Hargrave's management style, involvement with key counterparties, and conduct during the relevant period. These observations are relevant to the investigation's assessment of Hargrave's role in the transactions at issue.
Mr. Al-Rashidi described Hargrave as a "hands-on" manager who was deeply involved in the trading desk's day-to-day activities. He stated that Hargrave took a personal interest in the commercial details of significant transactions and that he personally cultivated relationships with key counterparties. This management style, according to Mr. Al-Rashidi, was characteristic of Hargrave throughout his tenure as President of DTI and was generally viewed within the organization as a reflection of his experience and industry knowledge.
Mr. Al-Rashidi stated that Hargrave traveled frequently, both within the UAE and internationally, to meet with counterparties and business partners. He stated that some of these trips were, to his belief, related to the Petronova and/or Zenith Petroleum relationships, although he could not identify specific trip dates or destinations without reference to Hargrave's travel records. He recalled that Hargrave occasionally mentioned meetings or dinners with counterparties that he associated with the Petronova relationship.
Mr. Al-Rashidi made a significant observation regarding Hargrave's attitude toward the Petronova relationship. He stated that Hargrave was "very protective" of the Petronova relationship and that he discouraged other DTI staff from conducting independent due diligence on Petronova beyond what was required by the standard compliance checklist. Mr. Al-Rashidi described this as unusual. He stated that, while Hargrave was generally hands-on with respect to important counterparties, the degree of protectiveness he exhibited toward Petronova was more pronounced than with other counterparty relationships. Mr. Al-Rashidi interpreted this at the time as Hargrave's desire to manage the relationship personally and to avoid disrupting a profitable trading channel, rather than as evidence of any improper motive.
Mr. Al-Rashidi further recalled a specific instance in which the compliance team in Houston, under Gerald Fisk's direction, raised questions about a Petronova-related transaction. Mr. Al-Rashidi estimated that this occurred in approximately mid-2021, although he could not provide a precise date without reference to email records. He stated that Fisk or a member of Fisk's team communicated concerns to the DTI office regarding certain aspects of a Petronova transaction, the details of which Mr. Al-Rashidi could not recall specifically. Hargrave "handled it directly," according to Mr. Al-Rashidi, and subsequently informed Al-Rashidi and other DTI staff that the matter was "resolved." Mr. Al-Rashidi stated that Hargrave did not share the specifics of his communications with Fisk or the Houston compliance team, and that Mr. Al-Rashidi did not inquire further. He accepted Hargrave's representation that the compliance issue had been satisfactorily addressed.
Mr. Al-Rashidi did not have visibility into the substance of Hargrave's communications with Fisk or the Houston compliance team regarding this incident, and he was unable to assess whether Hargrave's characterization of the matter as "resolved" was accurate.
B. Natasha Sorokin
Mr. Al-Rashidi also provided observations regarding Natasha Sorokin that are relevant to the investigation's understanding of her role and activities.
Mr. Al-Rashidi described Sorokin as a "highly skilled" but "independent" trader who operated with significant latitude from Hargrave. He stated that Sorokin was widely regarded within DTI as one of the desk's top performers and that her trading activity generated significant revenue for the company. He noted, however, that her independence — her ability to identify counterparties, structure transactions, and manage relationships with relatively limited oversight beyond Hargrave's approval — was greater than that of other traders on the desk.
Mr. Al-Rashidi stated that Sorokin is a Russian-American dual national. He observed that she appeared to have pre-existing personal or professional connections with Sergei Volkov, the Managing Director of Petronova Trading FZE. He recalled that when the Petronova relationship was first established, Sorokin referenced "old contacts" in explaining how she had identified Petronova as a potential counterparty. Mr. Al-Rashidi did not inquire further into the nature of these pre-existing connections at the time.
Mr. Al-Rashidi raised an additional observation regarding Sorokin's communications practices. He stated that Sorokin communicated with counterparties using both her official DTI email (the Company's standard email platform) and, he believed, personal encrypted messaging applications. He stated that on multiple occasions during office hours, he observed Sorokin using what appeared to be an encrypted messaging application on her personal mobile phone. He was unable to identify the specific application but described it as appearing to be an end-to-end encrypted messaging platform. He stated that he did not know the content of these communications and could not confirm whether the communications were business-related, personal, or both.
Mr. Al-Rashidi stated that he did not raise the issue of Sorokin's use of personal encrypted messaging for business purposes with Hargrave, Fisk, or any other individual within the organization. He acknowledged that the use of personal encrypted messaging for business communications, if such communications related to DTI's trading activity, would be inconsistent with the Company's records retention policies and could impede the ability of the compliance function to monitor counterparty communications.
Mr. Al-Rashidi confirmed that he was aware Sorokin was placed on administrative leave effective May 16, 2022, and that he had been informed this action was related to the ongoing investigation. He stated that he has had no communications with Sorokin since her placement on leave and that he understood he should not contact her or discuss the investigation with her.
VIII. Knowledge of Compliance Function and Gerald Fisk
A. Pre-Existing Compliance Program
Mr. Al-Rashidi provided his assessment of Dunmore's pre-existing sanctions compliance program as it operated during the period relevant to this investigation. His observations are relevant to the investigation's evaluation of the adequacy of the Company's compliance infrastructure and any potential defenses based on the existence or quality of the compliance program.
Mr. Al-Rashidi described Dunmore's sanctions compliance program as "basic" and "Houston-centric." He stated that the program was designed and administered from the Company's headquarters in Houston, Texas, under the direction of Gerald Fisk, who held the title of Chief Compliance Officer. The program's primary mechanism for sanctions compliance was a screening software system that checked counterparty names against the OFAC SDN List and other relevant sanctions lists.
Mr. Al-Rashidi noted several structural features of the compliance program that he considered relevant:
• Centralized Administration: OFAC screening and sanctions compliance were conducted by the compliance team in Houston. The Dubai office, despite being the location of DTI's trading desk and the site of the Company's most active counterparty relationships, did not have a dedicated compliance officer or compliance function. All compliance matters originating in Dubai were routed to Houston for processing and review.
• Time Zone Challenges: The time zone difference between Dubai (GST, UTC+4) and Houston (CST/CDT, UTC-6/-5) created a gap of approximately eight to nine hours. This differential resulted in practical delays in the turnaround of counterparty screening requests submitted by the Dubai desk. Screening requests submitted during the Dubai business day often could not be processed until the following Houston business day, by which time market conditions may have changed or the transaction may have already been executed.
• Software-Based Screening: The compliance program relied primarily on automated name-matching software to screen counterparties against sanctions lists. Mr. Al-Rashidi did not have detailed knowledge of the software's capabilities, configuration, or limitations, but he observed that the screening appeared to be a name-based matching exercise without more comprehensive due diligence (such as beneficial ownership analysis or network mapping).
Mr. Al-Rashidi stated that the combination of centralized Houston-based administration, time zone delays, and limited on-the-ground compliance presence in Dubai contributed to the practice, described above, of traders executing transactions before receiving compliance clearance.
B. Gerald Fisk
Mr. Al-Rashidi described his interactions with Gerald Fisk, DTI's Chief Compliance Officer, as occurring primarily via email and occasional video calls. These interactions typically related to counterparty screening requests submitted by the Dubai office or to periodic compliance updates disseminated by Fisk's team.
Mr. Al-Rashidi described Fisk as "responsive but stretched thin." He stated that Fisk appeared to be managing compliance responsibilities across all Dunmore entities globally — not only DTI but also Dunmore Energy Holdings Ltd. and its other subsidiaries — with a limited staff. Mr. Al-Rashidi's impression was that Fisk was personally dedicated to his compliance responsibilities but that the resources allocated to the compliance function were insufficient for the scope and complexity of Dunmore's global operations.
Mr. Al-Rashidi stated that he was aware Gerald Fisk departed Dunmore on June 10, 2022. He was told by management that Fisk's departure was voluntary, although he stated he was not aware of the specific circumstances surrounding the departure. He confirmed that he had been notified that Catherine Blackthorn, of the law firm Blackthorn & Associates LLP in Houston, had been retained as Fisk's personal counsel in connection with matters related to this investigation. Mr. Al-Rashidi stated he had no contact with Fisk or Fisk's counsel since Fisk's departure.
C. Red Flags and Escalation
In a portion of the interview that the investigation team considers particularly significant, Mr. Al-Rashidi was asked to identify, with the benefit of hindsight, any red flags that he observed during the relevant period that he now believes should have been escalated to the compliance function, to legal counsel, or to senior management.
Mr. Al-Rashidi acknowledged that, in retrospect, several red flags were present that should have prompted more aggressive inquiry and escalation. He identified the following:
1. Introduction of Petronova through Personal Connections: Petronova Trading FZE was introduced to DTI's trading desk by Natasha Sorokin through what appeared to be her personal or pre-existing professional connections, rather than through DTI's standard counterparty onboarding process. Mr. Al-Rashidi acknowledged that the use of personal connections to introduce a counterparty, while not inherently improper, should have prompted enhanced due diligence to verify the counterparty's bona fides and to assess any potential conflicts of interest.
2. Surname Similarity Between "Volkov" and "Volkhov." The similarity between the surname of Petronova's Managing Director (Sergei Volkov) and the name of the sanctioned Russian conglomerate (Volkhov Industrial Group / Arkady Volkhov) should have been recognized as a potential indicator of a relationship between the two entities. Mr. Al-Rashidi acknowledged that this similarity did not register with him at the time and that, in hindsight, it should have triggered additional screening and investigation.
3. Volume and Pattern of Payments Through Crescent Commercial Bank. The volume of individual wire transfers (127 transactions for $34.2 million) relative to the number of underlying commercial transactions was disproportionate and suggestive of payment structuring. Mr. Al-Rashidi acknowledged that his observation of Malhotra "splitting payments" was consistent with this concern and should have been escalated.
4. Hargrave's Protectiveness Over the Petronova Relationship. Hargrave's discouragement of independent due diligence on Petronova and his insistence on personally managing compliance inquiries related to Petronova were unusual and should have been recognized as potential indicators that Hargrave was seeking to limit scrutiny of the relationship.
5. Sorokin's Use of Personal Encrypted Messaging. The use of personal encrypted messaging applications for what may have been business communications with counterparties was inconsistent with the Company's records retention policies and could have been motivated by a desire to avoid corporate oversight of those communications.
Mr. Al-Rashidi stated that he did not escalate any of these concerns during the relevant period. He offered the following explanation for his failure to do so: at the time, he believed that Hargrave, as President of DTI, and the Houston compliance team under Fisk were handling matters appropriately and that the compliance process, while imperfect, was functioning within acceptable parameters. He also stated that he "did not want to overstep" his role, given that Hargrave was his direct supervisor and that compliance matters were formally the responsibility of Fisk's team in Houston. He acknowledged that this reasoning was inadequate and that he should have been more assertive in raising concerns, regardless of his position in the organizational hierarchy.
IX. Knowledge of Oilfield Equipment Exports
Mr. Al-Rashidi stated that the oilfield equipment export activities under investigation were primarily managed by Yves Leclerc, Director of Logistics & Shipping at DTI, under the direction of Derek Hargrave. Mr. Al-Rashidi's involvement in these activities was minimal.
He stated that he was generally aware that DTI facilitated shipments of oilfield drilling equipment and related components to various destinations as part of its broader business activities. However, he was not involved in the specifics of these activities, including export licensing, export classification, end-user certification, or the preparation of export documentation.
When asked about specific Export Administration Regulations ("EAR") classifications, including Export Control Classification Numbers ("ECCNs") 2B350 and 2B999, Mr. Al-Rashidi stated that he was not familiar with these specific classifications and that export control compliance was not part of his responsibilities or area of expertise. He stated that matters related to EAR compliance and export licensing were handled by Leclerc's team and, to his understanding, were subject to oversight by the compliance function in Houston.
Mr. Al-Rashidi deferred all questions regarding the approximately $12.4 million in oilfield equipment exports that have been identified as potentially problematic, including shipments arranged through Caspian Logistik GmbH, to Leclerc and Hargrave as the individuals with direct knowledge and responsibility for these transactions.
X. Knowledge of Tobias Engel and Dunmore Renewables GmbH Transaction
When asked about any knowledge of transactions involving Dunmore Renewables GmbH, a Dunmore subsidiary based in Hamburg, Germany, and managed by Tobias Engel, Mr. Al-Rashidi stated that he had no knowledge of any such transactions.
Specifically, he stated that he was not aware of any transaction between Dunmore Renewables GmbH and Caspian Logistik GmbH. He confirmed that he had never met, spoken with, or communicated with Tobias Engel in any capacity. He further stated that the renewables business operated by Dunmore Renewables GmbH was entirely separate from DTI's trading operations and that he had no visibility into or involvement with the activities of that subsidiary.
XI. Post-April 2022 Events and Cooperation
A. Discovery of Potential Volkhov Exposure
Mr. Al-Rashidi provided the following account of the events following the discovery of DTI's potential exposure to Volkhov Industrial Group.
He confirmed that on or about April 11, 2022, Gerald Fisk sent an internal email to Dunmore personnel, including recipients at the DTI Dubai office, alerting them that a routine OFAC screening refresh had identified potential historical exposure to Volkhov Industrial Group through Petronova Trading FZE. This alert was precipitated by the addition of Volkhov Industrial Group JSC to the OFAC SDN List on April 6, 2022, pursuant to Executive Order 14024, which expanded the scope of Russian sanctions in response to Russia's further invasion of Ukraine.
Mr. Al-Rashidi stated that he reviewed Fisk's internal alert and that it caused him significant concern regarding DTI's historical transactions with Petronova. He stated that the alert was the first time he became aware of a potential connection between Petronova and Volkhov Industrial Group.
He stated that Marcus Wellbourne, General Counsel of Dunmore Energy Holdings Ltd. (Houston), contacted the DTI office shortly after the circulation of Fisk's alert and instructed all staff to preserve all records, documents, and communications that could be relevant to the matter. Mr. Al-Rashidi stated that he understood the seriousness of the instruction and immediately took steps to ensure that his files and records were preserved.
Mr. Al-Rashidi confirmed that he received a formal litigation hold notice from Calderwood & Harkness LLP, dated April 20, 2022, which directed him to preserve all documents and communications potentially relevant to the investigation. He stated that he has complied with all preservation obligations set forth in the litigation hold notice, including the preservation of emails, electronic files, calendar entries, and any handwritten notes within his possession or control.
B. Willingness to Cooperate
Mr. Al-Rashidi affirmatively stated his willingness to cooperate fully with the internal investigation being conducted by Calderwood & Harkness on behalf of Dunmore Energy Holdings Ltd. and its subsidiaries. He stated that he understands the importance of the investigation and is committed to providing complete and truthful information to the investigation team.
He further stated that he is prepared to be interviewed by the U.S. Department of Justice if such an interview is requested by Dunmore and Calderwood & Harkness. He indicated that he understands that such an interview may be appropriate as part of the Company's cooperation with the government and that he is willing to participate, subject to any advice he receives from counsel.
Mr. Al-Rashidi confirmed the following additional points:
• He has not destroyed, altered, concealed, or disposed of any documents, communications, files, or other records related to the matters under investigation, whether in physical or electronic form.
• He has not communicated with Derek Hargrave, Natasha Sorokin, or any counsel representing those individuals since they were placed on administrative leave. He understands that any such communication would be inappropriate and potentially harmful to the investigation.
• He is willing to make himself available for further interviews by the Calderwood & Harkness investigation team, at times and locations that are mutually convenient, and to provide any additional documents or information within his possession or control that may be relevant to the investigation.
XII. Documents Identified / Requested for Follow-Up
During the course of the interview, the investigation team identified several categories of documents and materials that Mr. Al-Rashidi agreed to provide access to for purposes of the investigation:
1. DTI Email Archive: Mr. Al-Rashidi agreed to provide access to his complete DTI email archive for the period from January 2019 to the present. This collection will be performed by Nexagen Analytics Inc. (Project No. NX-DEH-2204), the e-discovery vendor engaged by Calderwood & Harkness for this matter. Mr. Al-Rashidi stated that he will cooperate with Nexagen's technical team to facilitate the collection process.
2. Personal Notes and Files Relating to Petronova: Mr. Al-Rashidi agreed to identify and produce any personal notes, memoranda, or files in his possession relating to meetings with Sergei Volkov, other Petronova representatives, or the Petronova counterparty relationship generally.
3. Calendar Entries: Mr. Al-Rashidi agreed to provide access to his electronic calendar entries for the period 2020 through 2022, with particular attention to entries reflecting meetings with counterparties, including Petronova, Zenith Petroleum, Crescent Commercial Bank, and any other relevant third parties.
4. Personal Device Communications: Mr. Al-Rashidi agreed to provide access to any text or messaging communications on his personal devices that relate to DTI business. He stated that he primarily used his DTI-issued devices (laptop, mobile phone) for business communications and that he did not use personal encrypted messaging applications for DTI matters. This stands in contrast to the reported practices of Natasha Sorokin, as described above. Nonetheless, Mr. Al-Rashidi consented to a review of his personal devices to confirm the absence of relevant business communications.
XIII. Credibility and Cooperation Assessment
Overall Assessment: Mr. Al-Rashidi was forthcoming, composed, and detailed in his responses throughout the approximately four hours and forty-five minutes of the interview. He answered questions directly and, where he did not have specific knowledge, clearly delineated the boundaries of his awareness without attempting to speculate or fill gaps with conjecture. He did not appear evasive, defensive, or inclined to minimize his awareness of relevant events. His demeanor was consistent and professional throughout, and he did not exhibit signs of deception or discomfort when addressing sensitive topics.
Credibility Indicators: Mr. Al-Rashidi's account is internally consistent and does not contain contradictions or material inconsistencies. His recollections regarding timelines, personnel, and counterparty interactions are generally aligned with the documentary record that the investigation team has reviewed to date, including email communications, deal tickets, and organizational charts. Notably, his admissions regarding red flags that should have been escalated — including his own failure to escalate concerns about payment structuring, Hargrave's protectiveness over the Petronova relationship, and Sorokin's use of encrypted messaging — enhance his credibility. Witnesses who acknowledge their own shortcomings and mistakes are generally viewed as more reliable by government investigators than those who present themselves as wholly blameless.
Potential Vulnerabilities: Notwithstanding the positive credibility assessment, the investigation team notes that Mr. Al-Rashidi's failure to escalate observed red flags could present vulnerabilities in a government interview or enforcement context. Specifically, his failure to report the payment structuring activity he observed (Malhotra "splitting payments"), his failure to flag the surname similarity between Volkov and Volkhov, and his failure to question Hargrave's protectiveness over the Petronova relationship could be characterized by government investigators as negligent or, under an aggressive theory, as evidence of willful blindness — particularly given his seniority and his position as Head of Middle East Operations. However, the balance of evidence reviewed to date suggests that Mr. Al-Rashidi's inaction was passive in nature — attributable to deference to his supervisor and to the designated compliance function — rather than the product of deliberate intent to facilitate or conceal sanctions violations.
Recommendation: Based on the foregoing assessment, Mr. Al-Rashidi is a strong candidate for presentation to the DOJ as a cooperating witness. His willingness to cooperate, his candid acknowledgment of missed red flags, and his positioning as a current employee (not a subject or target of the inquiry) make him a valuable resource for demonstrating Dunmore's cooperation with the government under the DOJ Corporate Enforcement Policy (formerly the Principles of Federal Prosecution of Business Organizations). Victoria Chambers shou

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