Extract to table

However, given NNPC's status as a government instrumentality, it must be disclosed as a material counterparty in the risk factors

Use of the Term "OFAC" All risk factors must use the exact phrase "OFAC" — referring to the Office of Foreign Assets Control of the U

"results may differ from expectations") are insufficient; the cautionary language must be tailored to the specific forward-looking statement and must identify the specific risks

For example, the statement in Risk Factor 3 that we 'intend to use approximately $250,000,000 of the net proceeds to fund capital expenditures associated with Phase II development of the Cayar Offshore Block' is forward-looking and must be accompanied by cautionary language identifying the specific risk that sanctions changes could prevent deployment

Importantly, any updates to screening results between the Preliminary OM date (April 28, 2025) and the Final OM date (anticipated May 14, 2025) must be reflected in updated risk factor language

In order to support the delivery of this letter, the OM Backup Memorandum must document the factual basis for each material statement in the sanctions risk factors