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Extract to table / memo-sanctions-framework-ofac.docx
memo-sanctions-framework-ofac.docx
Parties
HARKNESS LLP
Dunmore Energy Holdings Ltd
Dunmore Trading International Ltd
Caspian Logistik GmbH
Americas LLC
Dunmore Renewables GmbH
Greystone Capital Management LLC
Thornbury Asset Management Ltd
Dates
April 27, 2022
April 19, 2022
April 15, 2021
November 15, 2019
April 6, 2022
June 15, 2022
July 5, 2022
May 10, 2022
March 20, 2014
April 5, 2022
Amounts
$218.7
$156.3
$12.4
$34.2
$4.87
$10
€2.3
$1,000,000
$356,579
Obligations
-person entity or employee must be immediately blocked (i
All ongoing contracts, accounts receivable, accounts payable, or any other continuing business relationships or transactional arrangements with Volkhov-connected entities — including Petronova Trading FZE, Zenith Petroleum DMCC, and any other entity determined to be 50%+ owned by Volkhov — must be immediately suspended
Any such general license must be carefully reviewed to determine its scope and applicability to Dunmore's specific transactions
A careful review of each applicable general license must be conducted to determine whether any of the DTI crude oil swap transactions or oilfield equipment exports fall within their scope
a violation of any license, order, regulation, or prohibition issued under IEEPA — shall, upon conviction, be fined not more than $1,000,000, or, if a natural person, may be imprisoned for not more than 20 years, or both
Cooperation must be genuine, not selective or incomplete