interview-memo-yves-leclerc.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 — NOT FOR DISTRIBUTION

MEMORANDUM

TO: Victoria Chambers, Partner; Jasmine Thornton, Lead Associate; Conrad Reeves, Senior Counsel — Calderwood & Harkness LLP

FROM: Amara Osei, Associate — Calderwood & Harkness LLP (London Office, 30 St Mary Axe, 12th Floor, London EC3A 8BF, United Kingdom)

DATE: June 22, 2022

RE: Interview of Yves Leclerc, Director of Logistics & Shipping, Dunmore Trading International Ltd. — Witness Interview Memorandum

MATTER: Dunmore Energy Holdings Ltd. — DOJ Sanctions & Export Controls Inquiry (Calderwood & Harkness Matter No. 1016-00009)

1. Interview Summary and Overview

This memorandum summarizes the interview of Yves Leclerc, a French national currently serving as Director of Logistics & Shipping at Dunmore Trading International Ltd. ("DTI"), a subsidiary of Dunmore Energy Holdings Ltd. ("Dunmore" or the "Company"). Mr. Leclerc is based in Dubai, United Arab Emirates. The interview was conducted in connection with the internal investigation initiated by Dunmore in response to the inquiry and grand jury subpoena issued by the U.S. Department of Justice ("DOJ").

Date of Interview: June 22, 2022

Location: Calderwood & Harkness LLP, London Office, 30 St Mary Axe, 12th Floor, London EC3A 8BF, United Kingdom

Time: Approximately 9:30 a.m. to 1:15 p.m. (BST), with a short break taken at approximately 11:20 a.m. The total substantive interview time was approximately three hours and fifteen minutes.

Interviewers: Amara Osei (Associate, Calderwood & Harkness LLP, London Office) conducted the interview in person. Liam Donahue (Working Associate, Calderwood & Harkness LLP, New York Office) assisted by secure videoconference throughout the session. Ms. Osei took the lead on all substantive questioning; Mr. Donahue posed follow-up questions on approximately three occasions concerning shipping documentation and Caspian Logistik GmbH's role as an intermediary.

Counsel for Witness: None present. Mr. Leclerc is a current employee of DTI and did not retain personal counsel at the time of this interview. The question of whether Mr. Leclerc should retain personal counsel is addressed in the follow-up items section below and should be evaluated by Victoria Chambers in light of the developing factual record.

Court Reporter / Recording: No court reporter was present, and the interview was not recorded by audio or video. Amara Osei took contemporaneous handwritten and typed notes during the interview. Liam Donahue took supplemental notes from the videoconference.

Interview Number: This is the eighteenth (18th) witness interview conducted in Round 1 of the internal investigation. Round 1 encompasses interviews scheduled between May 18, 2022, and June 30, 2022, with a total of twenty-two (22) interviews planned in this first round.

This memorandum was prepared by Amara Osei on June 22, 2022, based on her contemporaneous notes. It reflects counsel's summary and characterization of Mr. Leclerc's statements and is not a verbatim transcript. All characterizations, assessments, and notations labeled "Counsel's note" reflect the mental impressions, conclusions, and legal analysis of counsel and are protected as attorney work product.

2. Upjohn / Corporate Miranda Warning

At the outset of the interview, prior to any substantive questioning, Amara Osei administered the Upjohn corporate Miranda warning to Mr. Leclerc. The warning was delivered orally and in accordance with the Witness Interview Protocol & Upjohn Warning Script dated April 18, 2022, which was prepared by Victoria Chambers and approved by the investigation team for use in all witness interviews. A copy of the Protocol and Script is attached as Appendix A.

Ms. Osei informed Mr. Leclerc of the following key points, pausing after each to confirm his understanding:

(a) Calderwood & Harkness LLP represents Dunmore Energy Holdings Ltd. and its subsidiaries, including Dunmore Trading International Ltd. Calderwood & Harkness does not represent Mr. Leclerc individually in any capacity. The firm's obligations of loyalty and confidentiality run to the Company, not to Mr. Leclerc personally.

(b) The purpose of the interview is to gather facts for the internal investigation that the Company has initiated in connection with the DOJ inquiry and grand jury subpoena GJ No. 22-418, which was issued on April 19, 2022, by the U.S. District Court for the District of Columbia, Grand Jury 22-2. The investigation concerns potential violations of U.S. sanctions, export controls, and related statutes.

(c) The interview and the information shared during it are protected by the Company's attorney-client privilege. The privilege belongs to Dunmore Energy Holdings Ltd. and its subsidiaries — not to Mr. Leclerc personally.

(d) Dunmore may, at its sole discretion, choose to waive the attorney-client privilege and disclose the contents of this interview to third parties, including the DOJ, the Office of Foreign Assets Control ("OFAC"), the Bureau of Industry and Security ("BIS"), or other governmental authorities.

(e) Mr. Leclerc has the right to retain personal legal counsel at his own expense. If he chooses to do so, the Company will not prevent him from consulting with personal counsel before or during the interview.

(f) Mr. Leclerc should not discuss the substance of this interview with other Dunmore or DTI employees, business associates, or any third parties. Doing so could jeopardize the privilege and the integrity of the investigation.

Mr. Leclerc acknowledged his understanding of each of the foregoing points. He confirmed that he did not wish to retain personal counsel at this time and stated that he was willing to cooperate fully with the investigation. He agreed to proceed with the interview on the terms described.

Ms. Osei noted that Mr. Leclerc appeared to listen attentively to the Upjohn warning and asked one clarifying question: whether the Company's decision to waive the privilege would be made by the Board of Directors or by management. Ms. Osei explained that the decision would be made by the Company through its authorized representatives, including the Board and outside counsel, and that Mr. Leclerc would have no ability to prevent such disclosure. Mr. Leclerc nodded in understanding and did not raise further questions about the warning.

3. Background and Role of Yves Leclerc

3.1 Personal Background

Mr. Leclerc is a French national. He was born and raised in Marseille, France. He holds a degree in logistics and supply chain management from a French university (he identified the institution but the specific name was not recorded by the interviewer in contemporaneous notes; this detail can be confirmed in a follow-up). He also holds an MBA or equivalent advanced business degree, which he obtained prior to entering the oil and gas industry.

Mr. Leclerc stated that he has approximately fifteen to eighteen years of professional experience in oil and gas logistics, shipping, and supply chain management. His career prior to joining DTI included positions at several international trading houses and logistics companies, primarily in Europe and the Middle East. He described his expertise as centered on the physical movement of crude oil, refined petroleum products, and oilfield equipment, including vessel chartering, freight forwarding, port operations, and customs documentation.

Mr. Leclerc relocated to Dubai, United Arab Emirates, in approximately 2016 when he accepted the position at DTI. He currently resides in Dubai with his family.

3.2 Position and Responsibilities at DTI

Mr. Leclerc's current title is Director of Logistics & Shipping at Dunmore Trading International Ltd. DTI's principal office is located at Level 14, Gate Building 3, Dubai International Financial Centre, P.O. Box 506774, Dubai, UAE. DTI operates under DIFC License No. CL-4827.

Mr. Leclerc reports directly to Derek Hargrave, President of DTI. (Counsel's note: Mr. Hargrave was subsequently placed on administrative leave effective July 1, 2022, nine days after this interview. At the time of this interview, on June 22, 2022, Mr. Hargrave remained in his role as President of DTI, although he was under increased scrutiny by the investigation team and senior management at Dunmore Energy Holdings Ltd.)

Mr. Leclerc described his responsibilities as follows:

• He is responsible for all logistics, shipping, freight forwarding, and transportation arrangements for DTI's physical trades, encompassing crude oil, refined petroleum products, and oilfield equipment.

• He manages DTI's relationships with external freight forwarders, shipping companies, vessel charterers, port authorities, and logistics intermediaries operating across the Middle East, Europe, and Africa.

• He oversees the preparation, review, and processing of key shipping and trade documentation, including bills of lading, shipping instructions, export documentation, end-user certificates, and customs declarations.

• He manages a team of approximately eight to ten logistics and operations staff based in DTI's Dubai office, all of whom report directly or indirectly to him.

Mr. Leclerc stated that, in the execution of his duties, he works closely with several other DTI personnel. In particular, he identified:

• Natasha Sorokin (Senior Trader, DTI) — Ms. Sorokin was the primary trader with whom Mr. Leclerc coordinated on the execution of physical trades. Mr. Leclerc noted that Ms. Sorokin has been on administrative leave since May 16, 2022. Prior to her leave, Ms. Sorokin would issue trade instructions — including counterparty details, volumes, delivery windows, and routing preferences — which Mr. Leclerc would then execute from a logistics perspective.

• Omar Al-Rashidi (Head of Middle East Operations, DTI) — Mr. Leclerc described Mr. Al-Rashidi as responsible for DTI's broader regional operations, including client relationship management and business development. Mr. Leclerc coordinated with Mr. Al-Rashidi on operational matters relating to physical deliveries within the Middle East.

• Rajesh Malhotra (Controller, DTI) — Mr. Leclerc stated that he coordinated with Mr. Malhotra on trade finance documentation, payment verification for shipped goods, letters of credit, and bank guarantee arrangements. Mr. Leclerc described this coordination as routine and primarily administrative in nature from his perspective; the substantive financial decision-making was handled by Mr. Malhotra and the finance team.

4. Leclerc's Knowledge of and Involvement with Caspian Logistik GmbH

4.1 Introduction to Caspian Logistik GmbH

Mr. Leclerc was asked to describe his knowledge of and dealings with Caspian Logistik GmbH, a company registered at Mönckebergstraße 22, 20095 Hamburg, Germany, and managed by Klaus Weidemann, a German national. This entity is a central focus of the investigation.

Mr. Leclerc stated that Caspian Logistik GmbH was introduced to DTI as a freight forwarding and logistics intermediary. Its role, as he understood it, was to facilitate the shipment of oilfield equipment to end users in Europe, with the potential for transshipment to destinations further east, including Central Asia. Mr. Leclerc described Caspian Logistik as a mid-sized logistics operator that specialized in handling industrial and oilfield equipment through the port of Hamburg.

Mr. Leclerc recalled that the relationship with Caspian Logistik began in approximately mid-2020, which he estimated as around August 2020. This timing aligns with the date of the first suspect equipment shipment identified by the investigation team. Mr. Leclerc stated that, prior to August 2020, he had not heard of Caspian Logistik and had no prior professional relationship with Mr. Weidemann.

When asked how the relationship was initiated, Mr. Leclerc stated that the introduction came through Derek Hargrave. According to Mr. Leclerc, Hargrave told him that Caspian Logistik had been recommended by a counterparty and that DTI should engage Caspian Logistik for certain upcoming oilfield equipment shipments. Mr. Leclerc stated that he was not initially told the identity of the counterparty that had recommended Caspian Logistik. However, over time, and based on context gathered from conversations with Hargrave and Ms. Sorokin, Mr. Leclerc came to understand that the recommendation was connected to Petronova Trading FZE, managed by Sergei Volkov. Mr. Leclerc stated that he could not pinpoint the exact moment he formed this understanding but believes it developed gradually during late 2020 and early 2021.

Mr. Leclerc stated that he had direct dealings with Klaus Weidemann via email and phone throughout the duration of the relationship. He described Weidemann as responsive, professional, and knowledgeable about freight forwarding logistics. Mr. Leclerc communicated with Weidemann primarily in English, though Mr. Leclerc noted that on occasion they exchanged brief communications in French when scheduling calls or confirming receipt of documents. Mr. Leclerc estimated that he exchanged emails with Weidemann on a frequency of approximately two to four times per month during active shipping periods.

4.2 Nature of Shipments

Mr. Leclerc stated that, between approximately August 2020 and January 2022, DTI arranged for the export of oilfield drilling equipment and components through Caspian Logistik GmbH. The total value of these shipments was approximately $12.4 million over the period, spread across multiple individual consignments.

The equipment included drilling components and related items used in oil and gas exploration and production. Mr. Leclerc described the items in general terms as downhole drilling tools, wellhead components, specialized valves, and related spare parts. He was not, however, aware of the specific export control classifications of these items.

Counsel's note: Based on the investigation team's review of the commercial invoices and packing lists associated with these shipments, the equipment includes items classified under the Export Administration Regulations ("EAR") at ECCN 2B350 (chemical/biological equipment — certain valves and components with dual-use applications) and ECCN 2B999 (items subject to controls for anti-terrorism, regional stability, or sanctions reasons). These classifications are significant because they trigger export license requirements for shipments to certain destinations, including Russia, under EAR §746.5 and related provisions.

The shipments were typically routed from various origin points, including suppliers located in the United States (principally Texas and Oklahoma) and in Europe (principally the United Kingdom and the Netherlands), to Hamburg, Germany, where Caspian Logistik would receive the goods, consolidate them as needed, and forward them to the stated end users. Mr. Leclerc described the logistical chain as a "hub-and-spoke" arrangement, with Hamburg serving as the central consolidation point under Caspian Logistik's management.

Mr. Leclerc acknowledged that he was responsible for coordinating the logistics chain for these shipments. He stated that he selected Caspian Logistik as the forwarding agent for these particular transactions on instructions from Derek Hargrave. Mr. Leclerc emphasized that the use of Caspian Logistik was not his independent decision but was directed by Hargrave, who specified Caspian Logistik as the required intermediary for the oilfield equipment shipments in question.

4.3 End-User Certificates and Export Documentation

Mr. Leclerc described the standard documentation process for the equipment shipments routed through Caspian Logistik. For each shipment, Caspian Logistik would provide end-user certificates identifying the ultimate consignee — that is, the entity that was stated to be the final recipient and end user of the equipment. These certificates were part of the standard documentation package that Mr. Leclerc maintained for each shipment, alongside bills of lading, commercial invoices, packing lists, and shipping instructions.

Mr. Leclerc stated that the end-user certificates he received from Caspian Logistik typically identified end users located in Germany, Turkey, or Kazakhstan. He was clear on this point: none of the end-user certificates he reviewed stated Russia as the ultimate destination for the equipment. Russia did not appear as either the country of the consignee or the country of ultimate destination on any document he recalled processing.

When asked directly whether he had reason to believe that any of the shipments were ultimately destined for Russia or for entities controlled by Russian interests, Mr. Leclerc stated that the documentation he received did not indicate Russia as a destination. He stated that he took the end-user certificates at face value and had no independent basis to question the stated destinations.

However, Mr. Leclerc acknowledged that he did not independently verify the end-user certificates beyond reviewing their face content. He did not, for example, contact the stated end users to confirm their existence, their relationship with DTI, or their receipt of the equipment. He did not conduct any due diligence on the entities named in the certificates. He relied entirely on Caspian Logistik's representations regarding the identity and legitimacy of the end users.

During the interview, Mr. Leclerc was shown several end-user certificates that had been retrieved from DTI's records during the document collection phase of the investigation. Counsel's note: These documents form part of the approximately 2,347,812 documents collected by Nexagen Analytics Inc. (Project No. NX-DEH-2204) from DTI's systems. Relevant documents have been or will be Bates-stamped in the DEH-DOJ production range for potential production to the DOJ.

Mr. Leclerc confirmed that he recognized the certificates and that he had processed them as part of his standard logistics workflow. He was able to identify his initials and electronic date stamps on several of the documents. However, he stated that he could not confirm from personal knowledge whether the stated end users — companies identified on the certificates as being located in Ankara, Istanbul, and Almaty — were legitimate operating businesses or were fronts established for the purpose of diverting the equipment to other destinations.

Counsel's note: The investigation team, in coordination with Ridgeline Advisory Group LLC (Engagement No. RAG-2022-0319, led by Dr. Margaret Liu), has determined that certain of the end-user certificates associated with the Caspian Logistik shipments may contain false statements regarding the ultimate destination of the equipment. Preliminary evidence suggests that equipment listed as destined for entities in Turkey and Kazakhstan may have been diverted to Russia, potentially to entities affiliated with or controlled by Volkhov Industrial Group JSC. If confirmed, this would constitute potential violations of EAR §746.5 (prohibiting certain exports and reexports to Russia and Belarus), applicable OFAC sanctions regulations, and potentially 18 U.S.C. §1001 (false statements). The analysis of the end-user certificates is ongoing and will be addressed in a separate memorandum.

4.4 Red Flags Leclerc Observed or Should Have Observed

Mr. Leclerc was questioned at length regarding potential red flags associated with the Caspian Logistik shipments. Ms. Osei identified several categories of red flags and asked Mr. Leclerc to address each:

Unusual Routing. Mr. Leclerc acknowledged that the routing of certain shipments was somewhat unusual. Specifically, some consignments were routed from origin points in the United States or Western Europe to Hamburg, Germany, where Caspian Logistik consolidated them, and then onward to Turkey or Kazakhstan — with the possibility of further transshipment from those locations. Mr. Leclerc stated that multi-leg routing is not inherently abnormal in the oilfield equipment trade, but he acknowledged that the specific patterns — particularly the use of Hamburg as a consolidation hub for goods ultimately destined for Central Asian markets — were not standard practice within his prior professional experience. When he observed the routing, Mr. Leclerc stated that he asked Hargrave and Sorokin about it. He said they explained the routing as necessary due to "logistical efficiencies" and client preferences regarding delivery scheduling. Mr. Leclerc accepted these explanations at the time and did not pursue further inquiries.

Lack of Direct End-User Contact. Mr. Leclerc acknowledged that he had no direct contact with any of the stated end users identified in the end-user certificates from Turkey or Kazakhstan. All communications regarding shipment scheduling, delivery confirmation, and documentation were channeled exclusively through Caspian Logistik and its managing director, Klaus Weidemann. Mr. Leclerc stated that in his prior experience at other trading companies, the logistics team would typically have at least some direct communication with the ultimate recipient of goods — particularly for high-value equipment shipments — to confirm delivery arrangements, site access, and acceptance procedures. The absence of such contact in the Caspian Logistik transactions was, in retrospect, notable, though Mr. Leclerc stated he did not view it as a significant concern at the time.

Payment Routing. Mr. Leclerc stated that he was not directly involved in the payment side of the transactions, as payments were handled by Rajesh Malhotra and the DTI finance team. However, Mr. Leclerc noted that he was occasionally aware — through conversations with Mr. Malhotra or through incidental review of trade documentation — that payments for certain shipments sometimes came from entities different from the stated buyers on the end-user certificates. Mr. Leclerc described this as unusual but stated that he did not find it alarming, given what he characterized as common practice in commodity trading for payments to be structured through intermediary accounts or affiliated entities.

Hargrave's Instructions. Mr. Leclerc stated that Derek Hargrave instructed him on multiple occasions to use Caspian Logistik GmbH for the oilfield equipment shipments and actively discouraged Mr. Leclerc from seeking alternative logistics providers for these specific transactions. Mr. Leclerc described Hargrave's instructions as firm and not open to discussion. The specifics of these instructions are addressed further in Section 7.2 below.

When asked why he did not raise these concerns with the compliance function, Mr. Leclerc stated that he did not escalate the red flags to Gerald Fisk (former Chief Compliance Officer, based at Dunmore's headquarters in Houston, Texas) or to any other compliance personnel. Mr. Leclerc offered two reasons for this failure. First, he stated that he assumed Hargrave, as President of DTI, had obtained the necessary approvals and clearances for the transactions, including any required compliance sign-offs. Mr. Leclerc did not believe it was his role to second-guess the President's decisions regarding counterparty selection. Second, Mr. Leclerc stated that, in his experience, the Dubai trading desk operated with significant autonomy from Houston headquarters, and there was no established culture or practice of the logistics function independently escalating concerns to the compliance function.

5. Leclerc's Knowledge of Petronova Trading FZE and Volkhov Industrial Group

5.1 Petronova Trading FZE

Mr. Leclerc was asked about his knowledge of Petronova Trading FZE, a company registered at Office 1407, Al Shafar Tower, Dubai Internet City, Dubai, UAE. Mr. Leclerc stated that he was aware of Petronova as a counterparty in DTI's crude oil trading operations. He identified Sergei Volkov, a Russian national and UAE resident, as the Managing Director of Petronova.

Mr. Leclerc stated that he had seen Mr. Volkov at DTI's offices in the DIFC on several occasions, typically in connection with meetings with Derek Hargrave and Natasha Sorokin. Mr. Leclerc described these encounters as incidental; he was not included in the meetings themselves but observed Volkov arriving at or departing from DTI's offices. He estimated that he saw Volkov at the DTI offices on approximately four or five occasions over the period from 2020 to early 2022.

Mr. Leclerc stated that his role regarding Petronova was limited. He occasionally arranged logistics for crude oil swap physical deliveries that were linked to Petronova-related trades, but these were standard logistics tasks (vessel nominations, loading and discharge port coordination) that did not require him to engage substantively with Petronova's business or principals. The primary relationship management for the Petronova account was handled by Natasha Sorokin and Derek Hargrave, and Mr. Leclerc did not participate in commercial negotiations or deal structuring.

Critically, Mr. Leclerc stated that, at the time the Petronova-related shipments occurred, he was not aware of any connection between Petronova Trading FZE and Volkhov Industrial Group JSC. He learned of the alleged connection only after the DOJ inquiry became known within the Company and after the internal investigation commenced.

5.2 Volkhov Industrial Group JSC

Mr. Leclerc was asked about his knowledge of Volkhov Industrial Group JSC, a company headquartered at 12 Kutuzovsky Prospekt, Moscow 121248, Russia, with Arkady Volkhov serving as Chairman. Mr. Leclerc stated unequivocally that he had no direct dealings with Volkhov Industrial Group at any point during his tenure at DTI. He did not communicate with any representatives of Volkhov, did not process any shipments addressed to Volkhov, and did not encounter Volkhov's name in any shipping or logistics documentation he reviewed.

Mr. Leclerc stated that he was not aware that Volkhov Industrial Group had been designated under OFAC Directive 2 (sectoral sanctions) on November 15, 2019, pursuant to Executive Order 13662 relating to the Russian energy sector. He was also not aware that Volkhov was subsequently added to the OFAC Specially Designated Nationals and blocked Persons List ("SDN List") on April 6, 2022, pursuant to Executive Order 14024 in connection with the U.S. government's expanded Russia-related sanctions in the wake of Russia's invasion of Ukraine.

When asked whether he had ever received any compliance communications, bulletins, or training materials from Dunmore that specifically addressed the Volkhov designation or Russian energy sector sanctions more broadly, Mr. Leclerc stated that he had not received any such materials. He was not aware of the Volkhov name in a sanctions context prior to the commencement of the internal investigation.

Counsel's note: Mr. Leclerc's lack of awareness of the Volkhov designation is consistent with the investigation's broader finding that Dunmore's pre-existing sanctions compliance program suffered from significant deficiencies, including a failure to disseminate updated sanctions information to relevant operational personnel and a failure to implement sanctions screening at the transactional level within DTI's Dubai operations. These deficiencies are analyzed in detail in the assessment memorandum on the pre-existing compliance program, dated November 15, 2022, prepared by Conrad Reeves and Jasmine Thornton.

6. Leclerc's Awareness of Sanctions and Export Control Requirements

6.1 Training and Compliance Knowledge

Mr. Leclerc was asked in detail about the compliance training he had received during his employment at DTI and his general understanding of sanctions and export control obligations.

Mr. Leclerc recalled receiving one general compliance training session when he first joined DTI in 2016. He described this training as a broad overview covering anti-bribery and anti-corruption policies (referencing the UK Bribery Act and the U.S. Foreign Corrupt Practices Act), basic trade compliance principles, and general corporate governance expectations. The training lasted approximately half a day and was conducted in Dubai by a member of the Houston-based compliance team. Mr. Leclerc did not recall the specific presenter but believed it may have been Gerald Fisk or a member of Mr. Fisk's team.

Beyond this initial onboarding session, Mr. Leclerc stated that he did not recall receiving any specific training on the following subjects:

• OFAC sanctions programs, including the SDN List, the Sectoral Sanctions Identifications List, the 50 percent rule, or country-based sanctions programs (Russia, Iran, Syria, North Korea, etc.);

• The Export Administration Regulations ("EAR"), including the Commerce Control List, Export Control Classification Numbers ("ECCNs"), license exception eligibility, or the EAR's applicability to items of U.S. origin transiting through third countries;

• Dual-use export control classifications, specifically ECCN 2B350 and ECCN 2B999 as applicable to oilfield equipment;

• The concept of "re-export" and "deemed export" under the EAR;

• EU restrictive measures and sanctions regulations applicable to DTI's operations in or through EU member states, including Germany.

Mr. Leclerc stated that he was not familiar with the concept of "U.S. person" obligations under the International Emergency Economic Powers Act ("IEEPA") or the extraterritorial reach of U.S. sanctions to non-U.S. persons who cause or facilitate transactions involving U.S.-origin goods, U.S. financial institutions, or U.S.-dollar-denominated payments. He stated that, prior to the commencement of the internal investigation, he had a general awareness that "sanctions" existed as a regulatory concept but did not have a working understanding of how they applied to DTI's operations or to his role specifically.

Mr. Leclerc stated that compliance matters within DTI were understood to be the responsibility of Gerald Fisk's team, which was based at Dunmore's headquarters in Houston, Texas. The Dubai office did not have a dedicated compliance officer or a sanctions screening capability embedded within the logistics function. Mr. Leclerc stated that there was no process or system by which the logistics team independently screened counterparties, freight forwarders, or logistics intermediaries against the OFAC SDN List, the EU Consolidated List, or any other restricted-party lists prior to engaging them. He acknowledged that he personally did not screen Caspian Logistik GmbH, Klaus Weidemann, or any of the stated end users against any sanctions or restricted-party list at any point during the relevant period.

6.2 Export Classification

Mr. Leclerc was asked whether he was aware that the oilfield equipment shipped through Caspian Logistik was classified under specific ECCNs — namely, 2B350 and 2B999 — and whether he understood that such classifications could trigger export license requirements for certain destinations, including Russia.

Mr. Leclerc stated that he was not aware of the specific ECCN classifications of the equipment. He stated that he understood the equipment to be standard oilfield drilling tools and components, but he had no knowledge of the regulatory classification framework under the EAR or of the specific license requirements that attached to items classified under ECCN 2B350 or 2B999. He did not review or request Automated Export System ("AES") filings, export licenses, or license exception certifications for any of the shipments in question.

Mr. Leclerc stated that he relied on the suppliers of the equipment and on Caspian Logistik to handle all export licensing, customs documentation, and regulatory compliance associated with the movement of the goods. He viewed his role as coordinating the physical logistics — booking freight, arranging transport, and managing documentation flow — rather than as ensuring regulatory compliance with export control laws.

Counsel's note: This represents a significant gap in DTI's export control compliance framework. Under the EAR, the obligation to ensure that exports, reexports, and in-country transfers of controlled items are properly authorized does not rest solely with the freight forwarder or the supplier. As the party arranging and directing the transactions — and as a party with a U.S.-nexus through its parent company, Dunmore Energy Holdings Ltd. (incorporated in Delaware), and through the use of U.S.-origin equipment — DTI bore independent obligations to classify the items, determine applicable license requirements, and obtain or verify the existence of required authorizations. Mr. Leclerc's reliance on third parties for these functions, without any internal verification mechanism, is a critical compliance failure that will be addressed in the pre-existing compliance program assessment.

7. Leclerc's Relationship with Derek Hargrave and Natasha Sorokin

7.1 Reporting Structure and Dynamics

Mr. Leclerc reported directly to Derek Hargrave, President of DTI, throughout the relevant period. He described Hargrave as a hands-on manager who closely controlled the trading desk's operations and exercised personal authority over key counterparty relationships, deal structuring, and commercial strategy. Mr. Leclerc stated that Hargrave was deeply involved in the day-to-day operations of DTI and maintained direct personal relationships with the principals of DTI's most significant counterparties, including Sergei Volkov of Petronova Trading FZE.

Mr. Leclerc described Natasha Sorokin as the primary trader responsible for managing the Petronova relationship and the crude oil swap transactions that formed a significant portion of DTI's trading book. In the operational flow, Sorokin would receive or negotiate trade terms, execute the commercial side of transactions, and then issue trade instructions — including counterparty details, product specifications, volumes, delivery windows, and routing preferences — to Mr. Leclerc, who would execute the logistics. Mr. Leclerc characterized his relationship with Sorokin as professional and functional; they worked together closely on the logistics execution of physical trades but Mr. Leclerc was not involved in the commercial or strategic aspects of Sorokin's trading activity.

Mr. Leclerc characterized the culture of the DTI Dubai office as one in which Hargrave made most strategic and significant operational decisions, with limited oversight from Houston headquarters. He stated that Hargrave had cultivated a degree of operational independence for the Dubai desk and that Houston-based management, including Gerald Fisk's compliance team, did not have real-time visibility into the Dubai desk's day-to-day transactions and counterparty engagements. Mr. Leclerc noted that this autonomy extended to counterparty selection, routing arrangements, and the use of intermediaries — areas in which Hargrave's decisions were treated as final within the Dubai office.

Mr. Leclerc also noted that Hargrave did not encourage questions from subordinates about the business rationale for specific counterparty selections or routing arrangements. Mr. Leclerc described Hargrave as someone who expected his instructions to be followed efficiently and without extensive inquiry. Mr. Leclerc stated that, while he did not feel actively intimidated by Hargrave, there was a clear understanding within the team that Hargrave's decisions on these matters were not to be questioned.

7.2 Specific Instructions from Hargrave Regarding Caspian Logistik

Mr. Leclerc provided additional detail regarding the instructions he received from Hargrave concerning the use of Caspian Logistik GmbH for the oilfield equipment shipments. Mr. Leclerc stated that Hargrave specifically instructed him, on at least four or five occasions over the period from August 2020 to late 2021, to use Caspian Logistik as the freight forwarding agent for the oilfield equipment shipments. On each occasion, Hargrave's instructions were clear and directive: Caspian Logistik was to be used, and Mr. Leclerc was not to engage DTI's other established logistics partners — several of which had longer track records with DTI and, in some cases, offered more competitive rates — for these particular transactions.

Mr. Leclerc described one specific occasion, which he estimated occurred in approximately early 2021 (possibly January or February 2021), on which he suggested to Hargrave that DTI should consider using a different freight forwarder that had quoted lower rates for a comparable shipment to Turkey. According to Mr. Leclerc, Hargrave responded by telling him that Caspian Logistik was "required by the client" and instructed Mr. Leclerc to proceed with Caspian Logistik without further discussion. Hargrave did not elaborate on who "the client" was in that context, and Mr. Leclerc did not press the question at the time. However, in light of the information that has emerged during the investigation, Mr. Leclerc now suspects that the reference to "the client" may have been to Volkhov-connected entities or to Petronova Trading FZE acting on behalf of such entities.

Mr. Leclerc stated that he complied with Hargrave's instructions and continued to use Caspian Logistik for the relevant shipments throughout the period without further questioning the arrangement.

8. Leclerc's Knowledge of Dunmore Renewables GmbH Connection

Mr. Leclerc was asked about one particular transaction involving Dunmore Renewables GmbH (registered at Überseeallee 12, 20457 Hamburg, Germany; Managing Director: Tobias Engel) and Caspian Logistik GmbH.

Mr. Leclerc stated that he was aware of a single shipment of equipment that was originally booked through Dunmore Renewables GmbH — a separate Dunmore subsidiary focused on renewable energy operations in Europe — but for which the logistics arrangements were handled through DTI's shipping infrastructure. Mr. Leclerc stated that this occurred at Hargrave's specific request. Mr. Leclerc described this arrangement as unusual because Dunmore Renewables typically maintained its own separate supply chain and logistics function for renewable energy components (e.g., wind turbine parts, solar panel equipment), and there was no obvious operational reason for a Dunmore Renewables shipment to be routed through DTI's logistics team in Dubai.

Mr. Leclerc stated that he did not have details on the commercial terms of this particular transaction — including the buyer, the price, or the contractual arrangements between Dunmore Renewables and any counterparty. He recalled that Tobias Engel, the Managing Director of Dunmore Renewables GmbH, reached out to him directly (Mr. Leclerc believed this was by email, possibly supplemented by a phone call) to clarify the shipping route for this transaction. Mr. Leclerc stated that he did not have sufficient information to answer Engel's questions and directed Engel to contact Derek Hargrave for further clarification. Mr. Leclerc did not follow up on Engel's inquiry and does not know whether Engel subsequently spoke with Hargrave.

Counsel's note: This transaction involving Dunmore Renewables GmbH is being analyzed separately. It is potentially significant because it may represent an attempt to route controlled equipment through a subsidiary entity whose business profile (renewable energy) would not typically attract export control scrutiny for oilfield equipment. The transaction and Mr. Engel's knowledge and involvement are addressed in a separate memorandum dated October 10, 2022, prepared by Liam Donahue.

9. Leclerc's Knowledge of Payment Flows and Crescent Commercial Bank

Mr. Leclerc was asked about his knowledge of the payment flows associated with the Caspian Logistik shipments and DTI's banking arrangements more broadly.

Mr. Leclerc stated that he was not directly involved in payment authorization or processing for the transactions in question. Payments, including trade finance arrangements such as letters of credit and bank guarantees, were handled by Rajesh Malhotra (Controller, DTI) and the DTI finance team. Mr. Leclerc's role was limited to the physical logistics side of transactions, and he did not have signatory authority over DTI's bank accounts or trade finance instruments.

Mr. Leclerc was aware that DTI's primary trade finance banking relationship was with Crescent Commercial Bank PJSC (Al Maktoum Tower, DIFC, P.O. Box 335102, Dubai, UAE). He identified Khalid Mansour as DTI's relationship manager at Crescent Commercial Bank. Mr. Leclerc stated that he interacted with Crescent Commercial Bank only indirectly, in that he occasionally saw letters of credit and bank guarantees referenced in or attached to shipping documentation that he processed. However, he did not review the underlying payment structures, the sources or destinations of funds, or the identities of the paying or receiving entities in the financial transaction chain.

Mr. Leclerc stated that he could not comment on the approximately $34.2 million in structured payments across 127 transactions that have been identified by Ridgeline Advisory Group LLC's forensic accounting analysis as potentially connected to the Caspian Logistik shipments and the broader Petronova/Volkhov transaction network. He was not familiar with the details of these payment flows and could not provide insight into their structure, routing, or purpose beyond his general awareness that DTI's trade finance was managed through Crescent Commercial Bank.

Counsel's note: Mr. Leclerc's limited involvement with payments is consistent with his logistics-focused role within DTI and with the organizational structure described by other interviewees. The investigation team does not expect Mr. Leclerc to have detailed knowledge of payment structuring. Mr. Malhotra's knowledge of the payment structures, including the use of intermediary accounts, correspondent banking channels, and potential sanctions evasion techniques, is addressed in a separate memorandum dated October 20, 2022, prepared by Nicholas Ferreira.

10. Zenith Petroleum DMCC

Mr. Leclerc was asked about his knowledge of Zenith Petroleum DMCC, a company registered at Unit 2201, Jumeirah Bay Tower X2, Cluster X, Jumeirah Lakes Towers, Dubai, UAE, with Farhan Qureshi serving as Managing Director.

Mr. Leclerc stated that Zenith Petroleum was known to him as a counterparty in DTI's crude oil swap transactions. However, he described his logistics involvement with Zenith Petroleum as limited to two physical delivery arrangements, both of which he characterized as routine crude oil loadings at Middle Eastern ports. He did not provide further detail on the specific dates, volumes, or commercial terms of these deliveries.

Mr. Leclerc stated that he had met Farhan Qureshi briefly at an industry event in Dubai — he believed it was an energy trading conference or networking reception — but did not have a substantive working relationship with Qureshi. Their interaction was limited to introductions and brief pleasantries. Mr. Leclerc did not communicate with Qureshi in connection with the oilfield equipment shipments or the Caspian Logistik relationship.

Mr. Leclerc stated that he was not aware of any connection between Zenith Petroleum DMCC and Volkhov Industrial Group JSC. He did not know whether Zenith Petroleum was involved in or connected to any of the transactions under investigation.

11. Document Preservation

Mr. Leclerc confirmed that he received the litigation hold notice dated April 20, 2022, issued by Calderwood & Harkness LLP to all relevant Dunmore and DTI personnel in connection with the DOJ inquiry and the internal investigation. A copy of the litigation hold notice issued to Mr. Leclerc is attached as Appendix B.

Mr. Leclerc stated that, upon receipt of the hold notice, he took steps to preserve all emails, files, documents, and communications stored on his DTI-issued devices and in DTI's electronic systems. He confirmed that he has not deleted, destroyed, altered, or removed any documents, files, or communications since receiving the hold notice.

Mr. Leclerc confirmed that he uses a DTI-issued laptop computer and a DTI-issued mobile phone for work purposes. He stated that he does not use personal devices — including personal mobile phones, personal email accounts, personal laptops, or personal cloud storage services — for work communications or for the storage of work-related documents.

When asked specifically about the use of encrypted messaging applications, Mr. Leclerc stated that he does not use Meridian Services Inc., Signal, Kestrel Data Systems, or any other encrypted messaging application for business communications. He stated that his work communications are conducted exclusively through DTI's corporate email system and, occasionally, through DTI's corporate telephone system. Mr. Leclerc stated he was aware that some colleagues used Meridian Services Inc. for informal business communications but that he did not personally do so.

Counsel's note: Mr. Leclerc's statement that he does not use encrypted messaging for business purposes stands in contrast to the situation with Natasha Sorokin, whose use of Meridian Services Inc. and potentially Signal for business communications — including communications with Sergei Volkov — has been identified as a significant issue for the investigation. Ms. Sorokin's encrypted messaging use is being analyzed separately, including through the engagement of forensic technology specialists.

12. Credibility Assessment and Counsel's Observations

Based on the approximately three-and-a-quarter-hour interview, the undersigned offers the following assessment of Mr. Leclerc's credibility and the significance of his testimony to the broader investigation:

Demeanor and Cooperativeness. Mr. Leclerc appeared cooperative and candid throughout the interview. He responded to questions directly and without undue hesitation. He did not appear evasive or combative, even when questioned about potentially sensitive topics such as his failure to escalate red flags and his reliance on Hargrave's instructions without independent verification. He volunteered information on several occasions without prompting, including his recollection of the specific instance in which Hargrave told him Caspian Logistik was "required by the client." His overall demeanor was that of a professional who is concerned about the situation but genuinely willing to assist the investigation.

Awareness of Sanctions and Volkhov Designation. Mr. Leclerc appeared genuinely unaware of the sanctioned status of Volkhov Industrial Group JSC or of the connections between Petronova Trading FZE and Volkhov. His lack of knowledge appeared authentic rather than feigned. His description of the compliance environment at DTI's Dubai office — characterized by minimal training, no dedicated compliance personnel, and no sanctions screening capability — is consistent with the broader compliance deficiencies that the investigation team has identified across DTI and the Dunmore group.

Consistency with Emerging Factual Picture. Mr. Leclerc's account is broadly consistent with the picture that has emerged from prior interviews and document review, in which Derek Hargrave exercised tight control over counterparty selection, routing decisions, and the use of intermediaries — with limited visibility, oversight, or pushback from either the logistics function or the compliance function. Mr. Leclerc's description of Hargrave's management style and the Dubai office's operational autonomy corroborates accounts provided by other interviewees, including Omar Al-Rashidi (interviewed May 25, 2022) and Rajesh Malhotra (interviewed June 8, 2022).

Assessment of Culpability. At this time, the undersigned's assessment is that Mr. Leclerc does not appear to have acted with intent to evade U.S. sanctions, export controls, or other applicable laws. There is no evidence currently available suggesting that Mr. Leclerc knew or believed that the oilfield equipment shipped through Caspian Logistik was destined for Russia or for sanctioned Russian entities. However, his failure to escalate identifiable red flags — including the unusual multi-leg routing, Hargrave's insistence on using Caspian Logistik to the exclusion of alternative providers, the lack of any direct end-user contact, and the payment irregularities of which he was peripherally aware — reflects, at a minimum, negligence and is symptomatic of a broader compliance culture failure within DTI. Whether this negligence rises to the level of "willful blindness" or "conscious avoidance" under applicable legal standards is a question that should be assessed by the senior investigation team in the context of the full factual record.

Recommendation Regarding DOJ Proffer Process. Mr. Leclerc may be a useful cooperative witness in connection with a potential DOJ proffer process. His direct knowledge of the logistics chain, the Caspian Logistik relationship, and Hargrave's specific instructions could be valuable in establishing the factual basis for the government's case against more culpable actors. However, the undersigned recommends that Mr. Leclerc be re-interviewed after the forensic accounting workstream (Ridgeline Advisory Group) and the document review workstream (Nexagen Analytics) yield more detailed shipping documentation, bills of lading, and correspondence between Leclerc and Weidemann. A re-interview will permit a more granular examination of specific transactions and will allow counsel to test Mr. Leclerc's account against the documentary record.

Counsel's note: Mr. Leclerc's statements should be cross-referenced with the following work product: (a) the Caspian Logistik export shipment analysis memorandum (dated July 20, 2022, prepared by Liam Donahue); (b) the Derek Hargrave role assessment memorandum (dated September 1, 2022, prepared by Jasmine Thornton); and (c) the pre-existing compliance program assessment memorandum (dated November 15, 2022, prepared by Conrad Reeves and Jasmine Thornton).

13. Follow-Up Items

The following action items have been identified in connection with this interview and should be assigned and tracked by the investigation team:

1. Email Correspondence with Klaus Weidemann. Obtain and review all emails between Yves Leclerc and Klaus Weidemann (Caspian Logistik GmbH) from August 2020 through January 2022. Coordinate with the Nexagen Analytics document review team to prioritize the identification, collection, and review of these communications within the broader document corpus.

2. End-User Certificates. Obtain and review all end-user certificates processed by Leclerc for shipments routed through Caspian Logistik GmbH during the relevant period. Cross-reference these certificates with the Nexagen Analytics document collection (Project No. NX-DEH-2204) and the Ridgeline Advisory Group forensic analysis to determine which certificates contain potentially false statements regarding the ultimate destination of the equipment.

3. Shipping Instruction Files and Bills of Lading. Obtain Mr. Leclerc's shipping instruction files, bills of lading, freight invoices, and related logistics documentation for the approximately $12.4 million in oilfield equipment exports shipped through Caspian Logistik. These documents should be analyzed for routing anomalies, discrepancies between stated and actual destinations, and evidence of diversion.

4. Follow-Up Interview. Schedule a follow-up interview with Mr. Leclerc after the completion of the Caspian Logistik export shipment analysis (expected July 2022) and the Ridgeline Advisory Group forensic accounting report (Engagement No. RAG-2022-0319). The follow-up interview should focus on specific transactions identified as potentially problematic by the document review and forensic analysis.

5. DOJ Proffer Assessment. Assess whether Mr. Leclerc should be included in the DOJ proffer process as a cooperative witness, potentially alongside Omar Al-Rashidi. This assessment should be made by Victoria Chambers and Jasmine Thornton in consultation with Conrad Reeves, taking into account Mr. Leclerc's level of culpability, his potential value as a witness, and the strategic considerations relating to the Company's cooperation with the DOJ.

6. EAR §746.5 Analysis. Coordinate with Conrad Reeves on the application of EAR §746.5 to Mr. Leclerc's specific shipments and the ECCN 2B350 and 2B999 classifications. Determine whether any of the shipments for which Leclerc coordinated logistics required export licenses that were not obtained.

7. Personal Counsel for Leclerc. Determine whether Mr. Leclerc should be advised to retain personal counsel. This determination should be made by Victoria Chambers based on the evolving risk assessment, including whether Mr. Leclerc faces potential individual exposure under U.S. or UAE law. If the decision is made to recommend personal counsel, the logistics of communication and joint defense arrangements should be coordinated promptly.

14. Attachments / Appendices (Referenced)

The following documents are referenced in this memorandum and are maintained in the investigation team's files:

Appendix A: Witness Interview Protocol & Upjohn Warning Script (dated April 18, 2022, prepared by Victoria Chambers).

Appendix B: Litigation Hold Notice issued to Yves Leclerc (dated April 20, 2022, issued by Calderwood & Harkness LLP).

Appendix C: Sample end-user certificates reviewed during the interview. Bates numbers to be confirmed upon completion of production indexing by the Nexagen Analytics document review team. Copies of the certificates shown to Mr. Leclerc during the interview are maintained in the interview file.

Appendix D: Organizational chart of Dunmore Trading International Ltd. showing Mr. Leclerc's reporting line to Derek Hargrave, President of DTI. The chart reflects the organizational structure as of the date of the interview (June 22, 2022), prior to Mr. Hargrave's administrative leave.

Prepared by: Amara Osei, Associate, Calderwood & Harkness LLP (London Office)

Reviewed by: [To be reviewed by Victoria Chambers, Partner, and Jasmine Thornton, Lead Associate]

Distribution: Limited to Calderwood & Harkness LLP investigation team — Victoria Chambers, Jasmine Thornton, Conrad Reeves, Liam Donahue, Howard Quinn. No further distribution without authorization from Victoria Chambers.

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

PRIVILEGED AND CONFIDENTIAL ATTORNEY-CLIENT PRIVILEGE / ATTORNEY WORK PRODUCT PREPARED IN ANTICIPATION OF LITIGATION — NOT FOR DISTRIBUTION
MEMORANDUM
TO: Victoria Chambers, Partner; Jasmine Thornton, Lead Associate; Conrad Reeves, Senior Counsel — Calderwood & Harkness LLP
FROM: Amara Osei, Associate — Calderwood & Harkness LLP (London Office, 30 St Mary Axe, 12th Floor, London EC3A 8BF, United Kingdom)
DATE: June 22, 2022
RE: Interview of Yves Leclerc, Director of Logistics & Shipping, Dunmore Trading International Ltd. — Witness Interview Memorandum
MATTER: Dunmore Energy Holdings Ltd. — DOJ Sanctions & Export Controls Inquiry (Calderwood & Harkness Matter No. 1016-00009)
1. Interview Summary and Overview
This memorandum summarizes the interview of Yves Leclerc, a French national currently serving as Director of Logistics & Shipping at Dunmore Trading International Ltd. ("DTI"), a subsidiary of Dunmore Energy Holdings Ltd. ("Dunmore" or the "Company"). Mr. Leclerc is based in Dubai, United Arab Emirates. The interview was conducted in connection with the internal investigation initiated by Dunmore in response to the inquiry and grand jury subpoena issued by the U.S. Department of Justice ("DOJ").
Date of Interview: June 22, 2022
Location: Calderwood & Harkness LLP, London Office, 30 St Mary Axe, 12th Floor, London EC3A 8BF, United Kingdom
Time: Approximately 9:30 a.m. to 1:15 p.m. (BST), with a short break taken at approximately 11:20 a.m. The total substantive interview time was approximately three hours and fifteen minutes.
Interviewers: Amara Osei (Associate, Calderwood & Harkness LLP, London Office) conducted the interview in person. Liam Donahue (Working Associate, Calderwood & Harkness LLP, New York Office) assisted by secure videoconference throughout the session. Ms. Osei took the lead on all substantive questioning; Mr. Donahue posed follow-up questions on approximately three occasions concerning shipping documentation and Caspian Logistik GmbH's role as an intermediary.
Counsel for Witness: None present. Mr. Leclerc is a current employee of DTI and did not retain personal counsel at the time of this interview. The question of whether Mr. Leclerc should retain personal counsel is addressed in the follow-up items section below and should be evaluated by Victoria Chambers in light of the developing factual record.
Court Reporter / Recording: No court reporter was present, and the interview was not recorded by audio or video. Amara Osei took contemporaneous handwritten and typed notes during the interview. Liam Donahue took supplemental notes from the videoconference.
Interview Number: This is the eighteenth (18th) witness interview conducted in Round 1 of the internal investigation. Round 1 encompasses interviews scheduled between May 18, 2022, and June 30, 2022, with a total of twenty-two (22) interviews planned in this first round.
This memorandum was prepared by Amara Osei on June 22, 2022, based on her contemporaneous notes. It reflects counsel's summary and characterization of Mr. Leclerc's statements and is not a verbatim transcript. All characterizations, assessments, and notations labeled "Counsel's note" reflect the mental impressions, conclusions, and legal analysis of counsel and are protected as attorney work product.
2. Upjohn / Corporate Miranda Warning
At the outset of the interview, prior to any substantive questioning, Amara Osei administered the Upjohn corporate Miranda warning to Mr. Leclerc. The warning was delivered orally and in accordance with the Witness Interview Protocol & Upjohn Warning Script dated April 18, 2022, which was prepared by Victoria Chambers and approved by the investigation team for use in all witness interviews. A copy of the Protocol and Script is attached as Appendix A.
Ms. Osei informed Mr. Leclerc of the following key points, pausing after each to confirm his understanding:
(a) Calderwood & Harkness LLP represents Dunmore Energy Holdings Ltd. and its subsidiaries, including Dunmore Trading International Ltd. Calderwood & Harkness does not represent Mr. Leclerc individually in any capacity. The firm's obligations of loyalty and confidentiality run to the Company, not to Mr. Leclerc personally.
(b) The purpose of the interview is to gather facts for the internal investigation that the Company has initiated in connection with the DOJ inquiry and grand jury subpoena GJ No. 22-418, which was issued on April 19, 2022, by the U.S. District Court for the District of Columbia, Grand Jury 22-2. The investigation concerns potential violations of U.S. sanctions, export controls, and related statutes.
(c) The interview and the information shared during it are protected by the Company's attorney-client privilege. The privilege belongs to Dunmore Energy Holdings Ltd. and its subsidiaries — not to Mr. Leclerc personally.
(d) Dunmore may, at its sole discretion, choose to waive the attorney-client privilege and disclose the contents of this interview to third parties, including the DOJ, the Office of Foreign Assets Control ("OFAC"), the Bureau of Industry and Security ("BIS"), or other governmental authorities.
(e) Mr. Leclerc has the right to retain personal legal counsel at his own expense. If he chooses to do so, the Company will not prevent him from consulting with personal counsel before or during the interview.
(f) Mr. Leclerc should not discuss the substance of this interview with other Dunmore or DTI employees, business associates, or any third parties. Doing so could jeopardize the privilege and the integrity of the investigation.
Mr. Leclerc acknowledged his understanding of each of the foregoing points. He confirmed that he did not wish to retain personal counsel at this time and stated that he was willing to cooperate fully with the investigation. He agreed to proceed with the interview on the terms described.
Ms. Osei noted that Mr. Leclerc appeared to listen attentively to the Upjohn warning and asked one clarifying question: whether the Company's decision to waive the privilege would be made by the Board of Directors or by management. Ms. Osei explained that the decision would be made by the Company through its authorized representatives, including the Board and outside counsel, and that Mr. Leclerc would have no ability to prevent such disclosure. Mr. Leclerc nodded in understanding and did not raise further questions about the warning.
3. Background and Role of Yves Leclerc
3.1 Personal Background
Mr. Leclerc is a French national. He was born and raised in Marseille, France. He holds a degree in logistics and supply chain management from a French university (he identified the institution but the specific name was not recorded by the interviewer in contemporaneous notes; this detail can be confirmed in a follow-up). He also holds an MBA or equivalent advanced business degree, which he obtained prior to entering the oil and gas industry.
Mr. Leclerc stated that he has approximately fifteen to eighteen years of professional experience in oil and gas logistics, shipping, and supply chain management. His career prior to joining DTI included positions at several international trading houses and logistics companies, primarily in Europe and the Middle East. He described his expertise as centered on the physical movement of crude oil, refined petroleum products, and oilfield equipment, including vessel chartering, freight forwarding, port operations, and customs documentation.
Mr. Leclerc relocated to Dubai, United Arab Emirates, in approximately 2016 when he accepted the position at DTI. He currently resides in Dubai with his family.
3.2 Position and Responsibilities at DTI
Mr. Leclerc's current title is Director of Logistics & Shipping at Dunmore Trading International Ltd. DTI's principal office is located at Level 14, Gate Building 3, Dubai International Financial Centre, P.O. Box 506774, Dubai, UAE. DTI operates under DIFC License No. CL-4827.
Mr. Leclerc reports directly to Derek Hargrave, President of DTI. (Counsel's note: Mr. Hargrave was subsequently placed on administrative leave effective July 1, 2022, nine days after this interview. At the time of this interview, on June 22, 2022, Mr. Hargrave remained in his role as President of DTI, although he was under increased scrutiny by the investigation team and senior management at Dunmore Energy Holdings Ltd.)
Mr. Leclerc described his responsibilities as follows:
• He is responsible for all logistics, shipping, freight forwarding, and transportation arrangements for DTI's physical trades, encompassing crude oil, refined petroleum products, and oilfield equipment.
• He manages DTI's relationships with external freight forwarders, shipping companies, vessel charterers, port authorities, and logistics intermediaries operating across the Middle East, Europe, and Africa.
• He oversees the preparation, review, and processing of key shipping and trade documentation, including bills of lading, shipping instructions, export documentation, end-user certificates, and customs declarations.
• He manages a team of approximately eight to ten logistics and operations staff based in DTI's Dubai office, all of whom report directly or indirectly to him.
Mr. Leclerc stated that, in the execution of his duties, he works closely with several other DTI personnel. In particular, he identified:
• Natasha Sorokin (Senior Trader, DTI) — Ms. Sorokin was the primary trader with whom Mr. Leclerc coordinated on the execution of physical trades. Mr. Leclerc noted that Ms. Sorokin has been on administrative leave since May 16, 2022. Prior to her leave, Ms. Sorokin would issue trade instructions — including counterparty details, volumes, delivery windows, and routing preferences — which Mr. Leclerc would then execute from a logistics perspective.
• Omar Al-Rashidi (Head of Middle East Operations, DTI) — Mr. Leclerc described Mr. Al-Rashidi as responsible for DTI's broader regional operations, including client relationship management and business development. Mr. Leclerc coordinated with Mr. Al-Rashidi on operational matters relating to physical deliveries within the Middle East.
• Rajesh Malhotra (Controller, DTI) — Mr. Leclerc stated that he coordinated with Mr. Malhotra on trade finance documentation, payment verification for shipped goods, letters of credit, and bank guarantee arrangements. Mr. Leclerc described this coordination as routine and primarily administrative in nature from his perspective; the substantive financial decision-making was handled by Mr. Malhotra and the finance team.
4. Leclerc's Knowledge of and Involvement with Caspian Logistik GmbH
4.1 Introduction to Caspian Logistik GmbH
Mr. Leclerc was asked to describe his knowledge of and dealings with Caspian Logistik GmbH, a company registered at Mönckebergstraße 22, 20095 Hamburg, Germany, and managed by Klaus Weidemann, a German national. This entity is a central focus of the investigation.
Mr. Leclerc stated that Caspian Logistik GmbH was introduced to DTI as a freight forwarding and logistics intermediary. Its role, as he understood it, was to facilitate the shipment of oilfield equipment to end users in Europe, with the potential for transshipment to destinations further east, including Central Asia. Mr. Leclerc described Caspian Logistik as a mid-sized logistics operator that specialized in handling industrial and oilfield equipment through the port of Hamburg.
Mr. Leclerc recalled that the relationship with Caspian Logistik began in approximately mid-2020, which he estimated as around August 2020. This timing aligns with the date of the first suspect equipment shipment identified by the investigation team. Mr. Leclerc stated that, prior to August 2020, he had not heard of Caspian Logistik and had no prior professional relationship with Mr. Weidemann.
When asked how the relationship was initiated, Mr. Leclerc stated that the introduction came through Derek Hargrave. According to Mr. Leclerc, Hargrave told him that Caspian Logistik had been recommended by a counterparty and that DTI should engage Caspian Logistik for certain upcoming oilfield equipment shipments. Mr. Leclerc stated that he was not initially told the identity of the counterparty that had recommended Caspian Logistik. However, over time, and based on context gathered from conversations with Hargrave and Ms. Sorokin, Mr. Leclerc came to understand that the recommendation was connected to Petronova Trading FZE, managed by Sergei Volkov. Mr. Leclerc stated that he could not pinpoint the exact moment he formed this understanding but believes it developed gradually during late 2020 and early 2021.
Mr. Leclerc stated that he had direct dealings with Klaus Weidemann via email and phone throughout the duration of the relationship. He described Weidemann as responsive, professional, and knowledgeable about freight forwarding logistics. Mr. Leclerc communicated with Weidemann primarily in English, though Mr. Leclerc noted that on occasion they exchanged brief communications in French when scheduling calls or confirming receipt of documents. Mr. Leclerc estimated that he exchanged emails with Weidemann on a frequency of approximately two to four times per month during active shipping periods.
4.2 Nature of Shipments
Mr. Leclerc stated that, between approximately August 2020 and January 2022, DTI arranged for the export of oilfield drilling equipment and components through Caspian Logistik GmbH. The total value of these shipments was approximately $12.4 million over the period, spread across multiple individual consignments.
The equipment included drilling components and related items used in oil and gas exploration and production. Mr. Leclerc described the items in general terms as downhole drilling tools, wellhead components, specialized valves, and related spare parts. He was not, however, aware of the specific export control classifications of these items.
Counsel's note: Based on the investigation team's review of the commercial invoices and packing lists associated with these shipments, the equipment includes items classified under the Export Administration Regulations ("EAR") at ECCN 2B350 (chemical/biological equipment — certain valves and components with dual-use applications) and ECCN 2B999 (items subject to controls for anti-terrorism, regional stability, or sanctions reasons). These classifications are significant because they trigger export license requirements for shipments to certain destinations, including Russia, under EAR §746.5 and related provisions.
The shipments were typically routed from various origin points, including suppliers located in the United States (principally Texas and Oklahoma) and in Europe (principally the United Kingdom and the Netherlands), to Hamburg, Germany, where Caspian Logistik would receive the goods, consolidate them as needed, and forward them to the stated end users. Mr. Leclerc described the logistical chain as a "hub-and-spoke" arrangement, with Hamburg serving as the central consolidation point under Caspian Logistik's management.
Mr. Leclerc acknowledged that he was responsible for coordinating the logistics chain for these shipments. He stated that he selected Caspian Logistik as the forwarding agent for these particular transactions on instructions from Derek Hargrave. Mr. Leclerc emphasized that the use of Caspian Logistik was not his independent decision but was directed by Hargrave, who specified Caspian Logistik as the required intermediary for the oilfield equipment shipments in question.
4.3 End-User Certificates and Export Documentation
Mr. Leclerc described the standard documentation process for the equipment shipments routed through Caspian Logistik. For each shipment, Caspian Logistik would provide end-user certificates identifying the ultimate consignee — that is, the entity that was stated to be the final recipient and end user of the equipment. These certificates were part of the standard documentation package that Mr. Leclerc maintained for each shipment, alongside bills of lading, commercial invoices, packing lists, and shipping instructions.
Mr. Leclerc stated that the end-user certificates he received from Caspian Logistik typically identified end users located in Germany, Turkey, or Kazakhstan. He was clear on this point: none of the end-user certificates he reviewed stated Russia as the ultimate destination for the equipment. Russia did not appear as either the country of the consignee or the country of ultimate destination on any document he recalled processing.
When asked directly whether he had reason to believe that any of the shipments were ultimately destined for Russia or for entities controlled by Russian interests, Mr. Leclerc stated that the documentation he received did not indicate Russia as a destination. He stated that he took the end-user certificates at face value and had no independent basis to question the stated destinations.
However, Mr. Leclerc acknowledged that he did not independently verify the end-user certificates beyond reviewing their face content. He did not, for example, contact the stated end users to confirm their existence, their relationship with DTI, or their receipt of the equipment. He did not conduct any due diligence on the entities named in the certificates. He relied entirely on Caspian Logistik's representations regarding the identity and legitimacy of the end users.
During the interview, Mr. Leclerc was shown several end-user certificates that had been retrieved from DTI's records during the document collection phase of the investigation. Counsel's note: These documents form part of the approximately 2,347,812 documents collected by Nexagen Analytics Inc. (Project No. NX-DEH-2204) from DTI's systems. Relevant documents have been or will be Bates-stamped in the DEH-DOJ production range for potential production to the DOJ.
Mr. Leclerc confirmed that he recognized the certificates and that he had processed them as part of his standard logistics workflow. He was able to identify his initials and electronic date stamps on several of the documents. However, he stated that he could not confirm from personal knowledge whether the stated end users — companies identified on the certificates as being located in Ankara, Istanbul, and Almaty — were legitimate operating businesses or were fronts established for the purpose of diverting the equipment to other destinations.
Counsel's note: The investigation team, in coordination with Ridgeline Advisory Group LLC (Engagement No. RAG-2022-0319, led by Dr. Margaret Liu), has determined that certain of the end-user certificates associated with the Caspian Logistik shipments may contain false statements regarding the ultimate destination of the equipment. Preliminary evidence suggests that equipment listed as destined for entities in Turkey and Kazakhstan may have been diverted to Russia, potentially to entities affiliated with or controlled by Volkhov Industrial Group JSC. If confirmed, this would constitute potential violations of EAR §746.5 (prohibiting certain exports and reexports to Russia and Belarus), applicable OFAC sanctions regulations, and potentially 18 U.S.C. §1001 (false statements). The analysis of the end-user certificates is ongoing and will be addressed in a separate memorandum.
4.4 Red Flags Leclerc Observed or Should Have Observed
Mr. Leclerc was questioned at length regarding potential red flags associated with the Caspian Logistik shipments. Ms. Osei identified several categories of red flags and asked Mr. Leclerc to address each:
Unusual Routing. Mr. Leclerc acknowledged that the routing of certain shipments was somewhat unusual. Specifically, some consignments were routed from origin points in the United States or Western Europe to Hamburg, Germany, where Caspian Logistik consolidated them, and then onward to Turkey or Kazakhstan — with the possibility of further transshipment from those locations. Mr. Leclerc stated that multi-leg routing is not inherently abnormal in the oilfield equipment trade, but he acknowledged that the specific patterns — particularly the use of Hamburg as a consolidation hub for goods ultimately destined for Central Asian markets — were not standard practice within his prior professional experience. When he observed the routing, Mr. Leclerc stated that he asked Hargrave and Sorokin about it. He said they explained the routing as necessary due to "logistical efficiencies" and client preferences regarding delivery scheduling. Mr. Leclerc accepted these explanations at the time and did not pursue further inquiries.
Lack of Direct End-User Contact. Mr. Leclerc acknowledged that he had no direct contact with any of the stated end users identified in the end-user certificates from Turkey or Kazakhstan. All communications regarding shipment scheduling, delivery confirmation, and documentation were channeled exclusively through Caspian Logistik and its managing director, Klaus Weidemann. Mr. Leclerc stated that in his prior experience at other trading companies, the logistics team would typically have at least some direct communication with the ultimate recipient of goods — particularly for high-value equipment shipments — to confirm delivery arrangements, site access, and acceptance procedures. The absence of such contact in the Caspian Logistik transactions was, in retrospect, notable, though Mr. Leclerc stated he did not view it as a significant concern at the time.
Payment Routing. Mr. Leclerc stated that he was not directly involved in the payment side of the transactions, as payments were handled by Rajesh Malhotra and the DTI finance team. However, Mr. Leclerc noted that he was occasionally aware — through conversations with Mr. Malhotra or through incidental review of trade documentation — that payments for certain shipments sometimes came from entities different from the stated buyers on the end-user certificates. Mr. Leclerc described this as unusual but stated that he did not find it alarming, given what he characterized as common practice in commodity trading for payments to be structured through intermediary accounts or affiliated entities.
Hargrave's Instructions. Mr. Leclerc stated that Derek Hargrave instructed him on multiple occasions to use Caspian Logistik GmbH for the oilfield equipment shipments and actively discouraged Mr. Leclerc from seeking alternative logistics providers for these specific transactions. Mr. Leclerc described Hargrave's instructions as firm and not open to discussion. The specifics of these instructions are addressed further in Section 7.2 below.
When asked why he did not raise these concerns with the compliance function, Mr. Leclerc stated that he did not escalate the red flags to Gerald Fisk (former Chief Compliance Officer, based at Dunmore's headquarters in Houston, Texas) or to any other compliance personnel. Mr. Leclerc offered two reasons for this failure. First, he stated that he assumed Hargrave, as President of DTI, had obtained the necessary approvals and clearances for the transactions, including any required compliance sign-offs. Mr. Leclerc did not believe it was his role to second-guess the President's decisions regarding counterparty selection. Second, Mr. Leclerc stated that, in his experience, the Dubai trading desk operated with significant autonomy from Houston headquarters, and there was no established culture or practice of the logistics function independently escalating concerns to the compliance function.
5. Leclerc's Knowledge of Petronova Trading FZE and Volkhov Industrial Group
5.1 Petronova Trading FZE
Mr. Leclerc was asked about his knowledge of Petronova Trading FZE, a company registered at Office 1407, Al Shafar Tower, Dubai Internet City, Dubai, UAE. Mr. Leclerc stated that he was aware of Petronova as a counterparty in DTI's crude oil trading operations. He identified Sergei Volkov, a Russian national and UAE resident, as the Managing Director of Petronova.
Mr. Leclerc stated that he had seen Mr. Volkov at DTI's offices in the DIFC on several occasions, typically in connection with meetings with Derek Hargrave and Natasha Sorokin. Mr. Leclerc described these encounters as incidental; he was not included in the meetings themselves but observed Volkov arriving at or departing from DTI's offices. He estimated that he saw Volkov at the DTI offices on approximately four or five occasions over the period from 2020 to early 2022.
Mr. Leclerc stated that his role regarding Petronova was limited. He occasionally arranged logistics for crude oil swap physical deliveries that were linked to Petronova-related trades, but these were standard logistics tasks (vessel nominations, loading and discharge port coordination) that did not require him to engage substantively with Petronova's business or principals. The primary relationship management for the Petronova account was handled by Natasha Sorokin and Derek Hargrave, and Mr. Leclerc did not participate in commercial negotiations or deal structuring.
Critically, Mr. Leclerc stated that, at the time the Petronova-related shipments occurred, he was not aware of any connection between Petronova Trading FZE and Volkhov Industrial Group JSC. He learned of the alleged connection only after the DOJ inquiry became known within the Company and after the internal investigation commenced.
5.2 Volkhov Industrial Group JSC
Mr. Leclerc was asked about his knowledge of Volkhov Industrial Group JSC, a company headquartered at 12 Kutuzovsky Prospekt, Moscow 121248, Russia, with Arkady Volkhov serving as Chairman. Mr. Leclerc stated unequivocally that he had no direct dealings with Volkhov Industrial Group at any point during his tenure at DTI. He did not communicate with any representatives of Volkhov, did not process any shipments addressed to Volkhov, and did not encounter Volkhov's name in any shipping or logistics documentation he reviewed.
Mr. Leclerc stated that he was not aware that Volkhov Industrial Group had been designated under OFAC Directive 2 (sectoral sanctions) on November 15, 2019, pursuant to Executive Order 13662 relating to the Russian energy sector. He was also not aware that Volkhov was subsequently added to the OFAC Specially Designated Nationals and blocked Persons List ("SDN List") on April 6, 2022, pursuant to Executive Order 14024 in connection with the U.S. government's expanded Russia-related sanctions in the wake of Russia's invasion of Ukraine.
When asked whether he had ever received any compliance communications, bulletins, or training materials from Dunmore that specifically addressed the Volkhov designation or Russian energy sector sanctions more broadly, Mr. Leclerc stated that he had not received any such materials. He was not aware of the Volkhov name in a sanctions context prior to the commencement of the internal investigation.
Counsel's note: Mr. Leclerc's lack of awareness of the Volkhov designation is consistent with the investigation's broader finding that Dunmore's pre-existing sanctions compliance program suffered from significant deficiencies, including a failure to disseminate updated sanctions information to relevant operational personnel and a failure to implement sanctions screening at the transactional level within DTI's Dubai operations. These deficiencies are analyzed in detail in the assessment memorandum on the pre-existing compliance program, dated November 15, 2022, prepared by Conrad Reeves and Jasmine Thornton.
6. Leclerc's Awareness of Sanctions and Export Control Requirements
6.1 Training and Compliance Knowledge
Mr. Leclerc was asked in detail about the compliance training he had received during his employment at DTI and his general understanding of sanctions and export control obligations.
Mr. Leclerc recalled receiving one general compliance training session when he first joined DTI in 2016. He described this training as a broad overview covering anti-bribery and anti-corruption policies (referencing the UK Bribery Act and the U.S. Foreign Corrupt Practices Act), basic trade compliance principles, and general corporate governance expectations. The training lasted approximately half a day and was conducted in Dubai by a member of the Houston-based compliance team. Mr. Leclerc did not recall the specific presenter but believed it may have been Gerald Fisk or a member of Mr. Fisk's team.
Beyond this initial onboarding session, Mr. Leclerc stated that he did not recall receiving any specific training on the following subjects:
• OFAC sanctions programs, including the SDN List, the Sectoral Sanctions Identifications List, the 50 percent rule, or country-based sanctions programs (Russia, Iran, Syria, North Korea, etc.);
• The Export Administration Regulations ("EAR"), including the Commerce Control List, Export Control Classification Numbers ("ECCNs"), license exception eligibility, or the EAR's applicability to items of U.S. origin transiting through third countries;
• Dual-use export control classifications, specifically ECCN 2B350 and ECCN 2B999 as applicable to oilfield equipment;
• The concept of "re-export" and "deemed export" under the EAR;
• EU restrictive measures and sanctions regulations applicable to DTI's operations in or through EU member states, including Germany.
Mr. Leclerc stated that he was not familiar with the concept of "U.S. person" obligations under the International Emergency Economic Powers Act ("IEEPA") or the extraterritorial reach of U.S. sanctions to non-U.S. persons who cause or facilitate transactions involving U.S.-origin goods, U.S. financial institutions, or U.S.-dollar-denominated payments. He stated that, prior to the commencement of the internal investigation, he had a general awareness that "sanctions" existed as a regulatory concept but did not have a working understanding of how they applied to DTI's operations or to his role specifically.
Mr. Leclerc stated that compliance matters within DTI were understood to be the responsibility of Gerald Fisk's team, which was based at Dunmore's headquarters in Houston, Texas. The Dubai office did not have a dedicated compliance officer or a sanctions screening capability embedded within the logistics function. Mr. Leclerc stated that there was no process or system by which the logistics team independently screened counterparties, freight forwarders, or logistics intermediaries against the OFAC SDN List, the EU Consolidated List, or any other restricted-party lists prior to engaging them. He acknowledged that he personally did not screen Caspian Logistik GmbH, Klaus Weidemann, or any of the stated end users against any sanctions or restricted-party list at any point during the relevant period.
6.2 Export Classification
Mr. Leclerc was asked whether he was aware that the oilfield equipment shipped through Caspian Logistik was classified under specific ECCNs — namely, 2B350 and 2B999 — and whether he understood that such classifications could trigger export license requirements for certain destinations, including Russia.
Mr. Leclerc stated that he was not aware of the specific ECCN classifications of the equipment. He stated that he understood the equipment to be standard oilfield drilling tools and components, but he had no knowledge of the regulatory classification framework under the EAR or of the specific license requirements that attached to items classified under ECCN 2B350 or 2B999. He did not review or request Automated Export System ("AES") filings, export licenses, or license exception certifications for any of the shipments in question.
Mr. Leclerc stated that he relied on the suppliers of the equipment and on Caspian Logistik to handle all export licensing, customs documentation, and regulatory compliance associated with the movement of the goods. He viewed his role as coordinating the physical logistics — booking freight, arranging transport, and managing documentation flow — rather than as ensuring regulatory compliance with export control laws.
Counsel's note: This represents a significant gap in DTI's export control compliance framework. Under the EAR, the obligation to ensure that exports, reexports, and in-country transfers of controlled items are properly authorized does not rest solely with the freight forwarder or the supplier. As the party arranging and directing the transactions — and as a party with a U.S.-nexus through its parent company, Dunmore Energy Holdings Ltd. (incorporated in Delaware), and through the use of U.S.-origin equipment — DTI bore independent obligations to classify the items, determine applicable license requirements, and obtain or verify the existence of required authorizations. Mr. Leclerc's reliance on third parties for these functions, without any internal verification mechanism, is a critical compliance failure that will be addressed in the pre-existing compliance program assessment.
7. Leclerc's Relationship with Derek Hargrave and Natasha Sorokin
7.1 Reporting Structure and Dynamics
Mr. Leclerc reported directly to Derek Hargrave, President of DTI, throughout the relevant period. He described Hargrave as a hands-on manager who closely controlled the trading desk's operations and exercised personal authority over key counterparty relationships, deal structuring, and commercial strategy. Mr. Leclerc stated that Hargrave was deeply involved in the day-to-day operations of DTI and maintained direct personal relationships with the principals of DTI's most significant counterparties, including Sergei Volkov of Petronova Trading FZE.
Mr. Leclerc described Natasha Sorokin as the primary trader responsible for managing the Petronova relationship and the crude oil swap transactions that formed a significant portion of DTI's trading book. In the operational flow, Sorokin would receive or negotiate trade terms, execute the commercial side of transactions, and then issue trade instructions — including counterparty details, product specifications, volumes, delivery windows, and routing preferences — to Mr. Leclerc, who would execute the logistics. Mr. Leclerc characterized his relationship with Sorokin as professional and functional; they worked together closely on the logistics execution of physical trades but Mr. Leclerc was not involved in the commercial or strategic aspects of Sorokin's trading activity.
Mr. Leclerc characterized the culture of the DTI Dubai office as one in which Hargrave made most strategic and significant operational decisions, with limited oversight from Houston headquarters. He stated that Hargrave had cultivated a degree of operational independence for the Dubai desk and that Houston-based management, including Gerald Fisk's compliance team, did not have real-time visibility into the Dubai desk's day-to-day transactions and counterparty engagements. Mr. Leclerc noted that this autonomy extended to counterparty selection, routing arrangements, and the use of intermediaries — areas in which Hargrave's decisions were treated as final within the Dubai office.
Mr. Leclerc also noted that Hargrave did not encourage questions from subordinates about the business rationale for specific counterparty selections or routing arrangements. Mr. Leclerc described Hargrave as someone who expected his instructions to be followed efficiently and without extensive inquiry. Mr. Leclerc stated that, while he did not feel actively intimidated by Hargrave, there was a clear understanding within the team that Hargrave's decisions on these matters were not to be questioned.
7.2 Specific Instructions from Hargrave Regarding Caspian Logistik
Mr. Leclerc provided additional detail regarding the instructions he received from Hargrave concerning the use of Caspian Logistik GmbH for the oilfield equipment shipments. Mr. Leclerc stated that Hargrave specifically instructed him, on at least four or five occasions over the period from August 2020 to late 2021, to use Caspian Logistik as the freight forwarding agent for the oilfield equipment shipments. On each occasion, Hargrave's instructions were clear and directive: Caspian Logistik was to be used, and Mr. Leclerc was not to engage DTI's other established logistics partners — several of which had longer track records with DTI and, in some cases, offered more competitive rates — for these particular transactions.
Mr. Leclerc described one specific occasion, which he estimated occurred in approximately early 2021 (possibly January or February 2021), on which he suggested to Hargrave that DTI should consider using a different freight forwarder that had quoted lower rates for a comparable shipment to Turkey. According to Mr. Leclerc, Hargrave responded by telling him that Caspian Logistik was "required by the client" and instructed Mr. Leclerc to proceed with Caspian Logistik without further discussion. Hargrave did not elaborate on who "the client" was in that context, and Mr. Leclerc did not press the question at the time. However, in light of the information that has emerged during the investigation, Mr. Leclerc now suspects that the reference to "the client" may have been to Volkhov-connected entities or to Petronova Trading FZE acting on behalf of such entities.
Mr. Leclerc stated that he complied with Hargrave's instructions and continued to use Caspian Logistik for the relevant shipments throughout the period without further questioning the arrangement.
8. Leclerc's Knowledge of Dunmore Renewables GmbH Connection
Mr. Leclerc was asked about one particular transaction involving Dunmore Renewables GmbH (registered at Überseeallee 12, 20457 Hamburg, Germany; Managing Director: Tobias Engel) and Caspian Logistik GmbH.
Mr. Leclerc stated that he was aware of a single shipment of equipment that was originally booked through Dunmore Renewables GmbH — a separate Dunmore subsidiary focused on renewable energy operations in Europe — but for which the logistics arrangements were handled through DTI's shipping infrastructure. Mr. Leclerc stated that this occurred at Hargrave's specific request. Mr. Leclerc described this arrangement as unusual because Dunmore Renewables typically maintained its own separate supply chain and logistics function for renewable energy components (e.g., wind turbine parts, solar panel equipment), and there was no obvious operational reason for a Dunmore Renewables shipment to be routed through DTI's logistics team in Dubai.
Mr. Leclerc stated that he did not have details on the commercial terms of this particular transaction — including the buyer, the price, or the contractual arrangements between Dunmore Renewables and any counterparty. He recalled that Tobias Engel, the Managing Director of Dunmore Renewables GmbH, reached out to him directly (Mr. Leclerc believed this was by email, possibly supplemented by a phone call) to clarify the shipping route for this transaction. Mr. Leclerc stated that he did not have sufficient information to answer Engel's questions and directed Engel to contact Derek Hargrave for further clarification. Mr. Leclerc did not follow up on Engel's inquiry and does not know whether Engel subsequently spoke with Hargrave.
Counsel's note: This transaction involving Dunmore Renewables GmbH is being analyzed separately. It is potentially significant because it may represent an attempt to route controlled equipment through a subsidiary entity whose business profile (renewable energy) would not typically attract export control scrutiny for oilfield equipment. The transaction and Mr. Engel's knowledge and involvement are addressed in a separate memorandum dated October 10, 2022, prepared by Liam Donahue.
9. Leclerc's Knowledge of Payment Flows and Crescent Commercial Bank
Mr. Leclerc was asked about his knowledge of the payment flows associated with the Caspian Logistik shipments and DTI's banking arrangements more broadly.
Mr. Leclerc stated that he was not directly involved in payment authorization or processing for the transactions in question. Payments, including trade finance arrangements such as letters of credit and bank guarantees, were handled by Rajesh Malhotra (Controller, DTI) and the DTI finance team. Mr. Leclerc's role was limited to the physical logistics side of transactions, and he did not have signatory authority over DTI's bank accounts or trade finance instruments.
Mr. Leclerc was aware that DTI's primary trade finance banking relationship was with Crescent Commercial Bank PJSC (Al Maktoum Tower, DIFC, P.O. Box 335102, Dubai, UAE). He identified Khalid Mansour as DTI's relationship manager at Crescent Commercial Bank. Mr. Leclerc stated that he interacted with Crescent Commercial Bank only indirectly, in that he occasionally saw letters of credit and bank guarantees referenced in or attached to shipping documentation that he processed. However, he did not review the underlying payment structures, the sources or destinations of funds, or the identities of the paying or receiving entities in the financial transaction chain.
Mr. Leclerc stated that he could not comment on the approximately $34.2 million in structured payments across 127 transactions that have been identified by Ridgeline Advisory Group LLC's forensic accounting analysis as potentially connected to the Caspian Logistik shipments and the broader Petronova/Volkhov transaction network. He was not familiar with the details of these payment flows and could not provide insight into their structure, routing, or purpose beyond his general awareness that DTI's trade finance was managed through Crescent Commercial Bank.
Counsel's note: Mr. Leclerc's limited involvement with payments is consistent with his logistics-focused role within DTI and with the organizational structure described by other interviewees. The investigation team does not expect Mr. Leclerc to have detailed knowledge of payment structuring. Mr. Malhotra's knowledge of the payment structures, including the use of intermediary accounts, correspondent banking channels, and potential sanctions evasion techniques, is addressed in a separate memorandum dated October 20, 2022, prepared by Nicholas Ferreira.
10. Zenith Petroleum DMCC
Mr. Leclerc was asked about his knowledge of Zenith Petroleum DMCC, a company registered at Unit 2201, Jumeirah Bay Tower X2, Cluster X, Jumeirah Lakes Towers, Dubai, UAE, with Farhan Qureshi serving as Managing Director.
Mr. Leclerc stated that Zenith Petroleum was known to him as a counterparty in DTI's crude oil swap transactions. However, he described his logistics involvement with Zenith Petroleum as limited to two physical delivery arrangements, both of which he characterized as routine crude oil loadings at Middle Eastern ports. He did not provide further detail on the specific dates, volumes, or commercial terms of these deliveries.
Mr. Leclerc stated that he had met Farhan Qureshi briefly at an industry event in Dubai — he believed it was an energy trading conference or networking reception — but did not have a substantive working relationship with Qureshi. Their interaction was limited to introductions and brief pleasantries. Mr. Leclerc did not communicate with Qureshi in connection with the oilfield equipment shipments or the Caspian Logistik relationship.
Mr. Leclerc stated that he was not aware of any connection between Zenith Petroleum DMCC and Volkhov Industrial Group JSC. He did not know whether Zenith Petroleum was involved in or connected to any of the transactions under investigation.
11. Document Preservation
Mr. Leclerc confirmed that he received the litigation hold notice dated April 20, 2022, issued by Calderwood & Harkness LLP to all relevant Dunmore and DTI personnel in connection with the DOJ inquiry and the internal investigation. A copy of the litigation hold notice issued to Mr. Leclerc is attached as Appendix B.
Mr. Leclerc stated that, upon receipt of the hold notice, he took steps to preserve all emails, files, documents, and communications stored on his DTI-issued devices and in DTI's electronic systems. He confirmed that he has not deleted, destroyed, altered, or removed any documents, files, or communications since receiving the hold notice.
Mr. Leclerc confirmed that he uses a DTI-issued laptop computer and a DTI-issued mobile phone for work purposes. He stated that he does not use personal devices — including personal mobile phones, personal email accounts, personal laptops, or personal cloud storage services — for work communications or for the storage of work-related documents.
When asked specifically about the use of encrypted messaging applications, Mr. Leclerc stated that he does not use Meridian Services Inc., Signal, Kestrel Data Systems, or any other encrypted messaging application for business communications. He stated that his work communications are conducted exclusively through DTI's corporate email system and, occasionally, through DTI's corporate telephone system. Mr. Leclerc stated he was aware that some colleagues used Meridian Services Inc. for informal business communications but that he did not personally do so.
Counsel's note: Mr. Leclerc's statement that he does not use encrypted messaging for business purposes stands in contrast to the situation with Natasha Sorokin, whose use of Meridian Services Inc. and potentially Signal for business communications — including communications with Sergei Volkov — has been identified as a significant issue for the investigation. Ms. Sorokin's encrypted messaging use is being analyzed separately, including through the engagement of forensic technology specialists.
12. Credibility Assessment and Counsel's Observations
Based on the approximately three-and-a-quarter-hour interview, the undersigned offers the following assessment of Mr. Leclerc's credibility and the significance of his testimony to the broader investigation:
Demeanor and Cooperativeness. Mr. Leclerc appeared cooperative and candid throughout the interview. He responded to questions directly and without undue hesitation. He did not appear evasive or combative, even when questioned about potentially sensitive topics such as his failure to escalate red flags and his reliance on Hargrave's instructions without independent verification. He volunteered information on several occasions without prompting, including his recollection of the specific instance in which Hargrave told him Caspian Logistik was "required by the client." His overall demeanor was that of a professional who is concerned about the situation but genuinely willing to assist the investigation.
Awareness of Sanctions and Volkhov Designation. Mr. Leclerc appeared genuinely unaware of the sanctioned status of Volkhov Industrial Group JSC or of the connections between Petronova Trading FZE and Volkhov. His lack of knowledge appeared authentic rather than feigned. His description of the compliance environment at DTI's Dubai office — characterized by minimal training, no dedicated compliance personnel, and no sanctions screening capability — is consistent with the broader compliance deficiencies that the investigation team has identified across DTI and the Dunmore group.
Consistency with Emerging Factual Picture. Mr. Leclerc's account is broadly consistent with the picture that has emerged from prior interviews and document review, in which Derek Hargrave exercised tight control over counterparty selection, routing decisions, and the use of intermediaries — with limited visibility, oversight, or pushback from either the logistics function or the compliance function. Mr. Leclerc's description of Hargrave's management style and the Dubai office's operational autonomy corroborates accounts provided by other interviewees, including Omar Al-Rashidi (interviewed May 25, 2022) and Rajesh Malhotra (interviewed June 8, 2022).
Assessment of Culpability. At this time, the undersigned's assessment is that Mr. Leclerc does not appear to have acted with intent to evade U.S. sanctions, export controls, or other applicable laws. There is no evidence currently available suggesting that Mr. Leclerc knew or believed that the oilfield equipment shipped through Caspian Logistik was destined for Russia or for sanctioned Russian entities. However, his failure to escalate identifiable red flags — including the unusual multi-leg routing, Hargrave's insistence on using Caspian Logistik to the exclusion of alternative providers, the lack of any direct end-user contact, and the payment irregularities of which he was peripherally aware — reflects, at a minimum, negligence and is symptomatic of a broader compliance culture failure within DTI. Whether this negligence rises to the level of "willful blindness" or "conscious avoidance" under applicable legal standards is a question that should be assessed by the senior investigation team in the context of the full factual record.
Recommendation Regarding DOJ Proffer Process. Mr. Leclerc may be a useful cooperative witness in connection with a potential DOJ proffer process. His direct knowledge of the logistics chain, the Caspian Logistik relationship, and Hargrave's specific instructions could be valuable in establishing the factual basis for the government's case against more culpable actors. However, the undersigned recommends that Mr. Leclerc be re-interviewed after the forensic accounting workstream (Ridgeline Advisory Group) and the document review workstream (Nexagen Analytics) yield more detailed shipping documentation, bills of lading, and correspondence between Leclerc and Weidemann. A re-interview will permit a more granular examination of specific transactions and will allow counsel to test Mr. Leclerc's account against the documentary record.
Counsel's note: Mr. Leclerc's statements should be cross-referenced with the following work product: (a) the Caspian Logistik export shipment analysis memorandum (dated July 20, 2022, prepared by Liam Donahue); (b) the Derek Hargrave role assessment memorandum (dated September 1, 2022, prepared by Jasmine Thornton); and (c) the pre-existing compliance program assessment memorandum (dated November 15, 2022, prepared by Conrad Reeves and Jasmine Thornton).
13. Follow-Up Items
The following action items have been identified in connection with this interview and should be assigned and tracked by the investigation team:
1. Email Correspondence with Klaus Weidemann. Obtain and review all emails between Yves Leclerc and Klaus Weidemann (Caspian Logistik GmbH) from August 2020 through January 2022. Coordinate with the Nexagen Analytics document review team to prioritize the identification, collection, and review of these communications within the broader document corpus.
2. End-User Certificates. Obtain and review all end-user certificates processed by Leclerc for shipments routed through Caspian Logistik GmbH during the relevant period. Cross-reference these certificates with the Nexagen Analytics document collection (Project No. NX-DEH-2204) and the Ridgeline Advisory Group forensic analysis to determine which certificates contain potentially false statements regarding the ultimate destination of the equipment.
3. Shipping Instruction Files and Bills of Lading. Obtain Mr. Leclerc's shipping instruction files, bills of lading, freight invoices, and related logistics documentation for the approximately $12.4 million in oilfield equipment exports shipped through Caspian Logistik. These documents should be analyzed for routing anomalies, discrepancies between stated and actual destinations, and evidence of diversion.
4. Follow-Up Interview. Schedule a follow-up interview with Mr. Leclerc after the completion of the Caspian Logistik export shipment analysis (expected July 2022) and the Ridgeline Advisory Group forensic accounting report (Engagement No. RAG-2022-0319). The follow-up interview should focus on specific transactions identified as potentially problematic by the document review and forensic analysis.
5. DOJ Proffer Assessment. Assess whether Mr. Leclerc should be included in the DOJ proffer process as a cooperative witness, potentially alongside Omar Al-Rashidi. This assessment should be made by Victoria Chambers and Jasmine Thornton in consultation with Conrad Reeves, taking into account Mr. Leclerc's level of culpability, his potential value as a witness, and the strategic considerations relating to the Company's cooperation with the DOJ.
6. EAR §746.5 Analysis. Coordinate with Conrad Reeves on the application of EAR §746.5 to Mr. Leclerc's specific shipments and the ECCN 2B350 and 2B999 classifications. Determine whether any of the shipments for which Leclerc coordinated logistics required export licenses that were not obtained.
7. Personal Counsel for Leclerc. Determine whether Mr. Leclerc should be advised to retain personal counsel. This determination should be made by Victoria Chambers based on the evolving risk assessment, including whether Mr. Leclerc faces potential individual exposure under U.S. or UAE law. If the decision is made to recommend personal counsel, the logistics of communication and joint defense arrangements should be coordinated promptly.
14. Attachments / Appendices (Referenced)
The following documents are referenced in this memorandum and are maintained in the investigation team's files:
Appendix A: Witness Interview Protocol & Upjohn Warning Script (dated April 18, 2022, prepared by Victoria Chambers).
Appendix B: Litigation Hold Notice issued to Yves Leclerc (dated April 20, 2022, issued by Calderwood & Harkness LLP).
Appendix C: Sample end-user certificates reviewed during the interview. Bates numbers to be confirmed upon completion of production indexing by the Nexagen Analytics document review team. Copies of the certificates shown to Mr. Leclerc during the interview are maintained in the interview file.
Appendix D: Organizational chart of Dunmore Trading International Ltd. showing Mr. Leclerc's reporting line to Derek Hargrave, President of DTI. The chart reflects the organizational structure as of the date of the interview (June 22, 2022), prior to Mr. Hargrave's administrative leave.
Prepared by: Amara Osei, Associate, Calderwood & Harkness LLP (London Office)
Reviewed by: [To be reviewed by Victoria Chambers, Partner, and Jasmine Thornton, Lead Associate]
Distribution: Limited to Calderwood & Harkness LLP investigation team — Victoria Chambers, Jasmine Thornton, Conrad Reeves, Liam Donahue, Howard Quinn. No further distribution without authorization from Victoria Chambers.
PRIVILEGED AND CONFIDENTIAL — ATTORNEY-CLIENT PRIVILEGE / ATTORNEY WORK PRODUCT PREPARED IN ANTICIPATION OF LITIGATION — NOT FOR DISTRIBUTION

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