Case Document 1-23 Filed 03/07/16 Page 1 of 14 Exhibit 22 Case Document 1-23 Filed 03/07/16 Page 2 of 14 Wayne Kemp From: Lussier, Narmand DLA CIV SENERAL Normandiussier?i?lamil> gent: Wednegday, March 23, 2011 9:31 AM To: Wayne Keup Sub?ect: Attenticn Check the Attachment (FOUO) ?ttachments: Fallow Up Flag: Follow up ?ag Status: Flagged Wayne, As usual, no attribution please. Ali, FYI Attached is an anonymous email the KO received today concerning KGL continuing to deai with iranian companies. Buennig is an Army KO at Rack island Aisa the individual Cc?c? the GAO. No {me at Distribution J7 is aware of who this individual is. Game wwOriginai From: Scott Wilson Sent: Tuesday, March 22, 2011 11:07 AM Ta: Kowalski, Medard DLA Ci?u? buennig@us.army.mil Cc: contactcapgaagov; congrei@gao.gov Subgect: Attention (thank the Attachment 1 WAK, PLLCOO4 Case Document 1-23 Filed 03/07/16 Page 3 of 14 March 122, 2201 1 Via Emaii and Registerci} Mail Medan} R. Kowal?zksi, 112 Comracting Of?cm?, macaw Defense Distribution Center .2601 Mission Du? HQ 40:; NCW C?umberiant?i, PA 170706060 mai}: J'nedarwzl. k0 wai?ki?dm. if David 13 ucmu' g; Army Sugtaimnem Cnmmamd Ruck IsEand Cm?rauiing Canter, 350 Rock IS'iand, IL 61299-3000 Emaii: i3 umm? u??us?rm v. mi i Dear Sims; 1 2.11.11 Writing to thaw your a?eminn to a serious and vioimim?i (if US law conuninth by Kuwait Link Transpan Campany (mam), this: mmpartsy which ihe Dcf?cnsc Logistics Agency of'thc US Uepartment of ?Defemsa awarded a (lontractm~~ (CQCO) smmge and disn?mtion {:apability Within Kuwait comma (Solicitation i? on In?rmary 233 201 I. I have cmmpelling evidence: that continues to business with Iranian entities, in viniatiun ofihe Comprehensive 1mm Sanctions, Accountability, and Act of 2010' As you may be well aware, prohibits emi'tias contracting with the US. Government {Exam doing buximss with Iran. 0r {Iranian entities. CISADA mamiates {but be: [hay US or i?nzreigrhowmed, must certify that that); comply with ail Sanclians againgt Iran. has had ajoint venture rclatiomhip with Vaifa}r Shipping, through its subsidiary Combined Shipping, and with Oasis Freight. Services (aka. Pacific Shipping Campany}. {30121 are: .iisted as suhaidiariss of? the ?Isiamic Repubiic (if Iran Shippi?g Limes O'f?zze DfForeigm Assct (301111013 and sanctiomzd as a specially designated national for providing imgis?cai services t0 Iran?a Minimry of and Armed Farms Logi?tics. The designation imposed by the US. prohibit?] all zransamions bc?wccn {he designees and any person, and freczds] any assets the desigmes may have Lm?er US. jurirsdicliun. Oasis and Vaifnjr were also Iisied by the European Unieu {m Juiy 26, 2.610 as entities linked Iran's. WAK, PLLCODS Case Document 1-23 Filed 03/07/16 Page 4 of 14 prolt?to?rat?iowsom?tivo nuclear activitits or Iran?s ofnuolom weapon delivery systems: through thoir aosooiat?on with IRTSL. In 2010, a member of Boot-cl, Dr. Ali mote to United Against Nuclear Iran, that and its af?liates will not engage in any transactions for goods or services; with any business or supplier that is known by KGL to be an Eraoian entity or located in Iran.? Similar were reported having boon givm to members of Congress as well as to certain of?ces within the US Department o't??ot?enso. Despite thoso wouranaos, KGL ti; still doing 'lmsiooss with lraoian entities, speci?cally subsidiaries of HHSL. 01'1.Marclt 8, 201 I, a series of emails between KGL, Oasis and Valfajr (attached hereto) reveals that KGL is ciirectly involved in chartering vossol for ?v?olfo?ir, with the exprogs approval of Km?. Chairman, $314:ch thahti. to no email messogo to Faro, too managing attractor of Oasis, {atom Capt. tut. Keshavam the: Managing Liliroutor of Valfzgir Shipping (iompony, (titted March 20113 Kcshavarz indicotco Volt?ajr wants to charter at vessel from {.L?asis, stating; ?Surely we need the vessel and the charter rate will b: who! Season pays for Awa?." Faro then emails Alan Rosenberg, the Cl?lii'if Executive Of?oor of ECG-L Port-S International (KGL PIL askng ?Can we live with this proposal?? Emails go back and forth about "pricing voogci botw am Patrol and Rosenberg follow, with Mr. Rosenberg. stating in one message: ?Certainly, we will. charter out to the highest. paying and most reliable charterersi? and aloo stating, ?13.33 you know, I will always; charter the vessels out subject to Board Approval,? whorl Faro raises; {hit soyiztg ?Ifwe ?on?t want to give them the vessel that is a different story anti we moo to involve Mr Daghti as well,? Mr. Rosenberg ultimately gets approval {tom Mr. Saccd Dasltti for the proposed chartorycleal and than him (113$th is copying on the counter offer, Saved Dashti is a report on its gonoml assembly to; Choim?mn and Kuwait and Gulf Link Transport Company ?l?hcso emails clearly indicate KGL Board made. flagrant milmfoprmentations to tho (Zongress and the US Department of Doibtt?o and the US law in its attemgt to obtom govommoot contracts. to Eight of this ovi?onoez KGL Should be forthwith dtsciuah?cd from any existing, US contract: awards and barred from any future US contract awards. I urge you to investigate this matter immediately as 1 have engogod a law ?rm to pursue all necessary legal 21nd 'rccourso Sincomly, "a .0 Scott; Wilson WAK. PLLCOO6 Case Document 1-23 Filed 03/07/16 CC: (3.51:0 (Litgai Department) Government Of?ce 441 St, NW {Room 7169) Washington, DC 20548 Attention: Ethic Counsal: (Ti-$113011 Emaii: maiaci?iimm?uv ?avammem Accmmiabiliiy Of?ce St, NW {Room 7125) Attantion: Congr?ssionai Relations: Ralph Dawn Email: Attachmm?s pag?s} WAK, PLLCOOT Page 5 of 14 Case Document 1-23 Filed 03/07/16 Page 6 of 14 From: giiarz Rosenberg {allan.rosenberg@kgl.coml amt: Su?day, March 23, 201.1 7:43 AM Ta: Saeed 03511:; Subject: Elia: Merjan Thanks Saeed, I have bcc?ed Moghaddami and valfajr Or: my wunter offer 2:0 SeaCon; 50 has: knows what I am doing. Kind regards Allan me: Saeed Dasha Sam: 20 March, 211311 12:31 m: Allan Rosenberg gubject: RE: Merjan Fine with me. SAEED DASHTI Pram: Aiian Resenberg Sent: Sunday, March 20, 2011 7:32 AM Ta: Saeed Dashti Subject: RE: Mcrjan Dear Saeed, Appraciate your guidance in how to proceed! i suggest we agk Seaman to increase their offer and aim far chartering; Out to either Seaman 0r E3ima?i?aach at USSD 4,600/day or abova. Simatech will not revert until Timsday, accorcling to the valfajr, but that deem?: mean we camel: progress; the matter with SeaCon and keep the final fixture until Tuesday ler Dubai time. We will then still have. time?: ta: 2'3330535655 the vessei on March 26?" in Jebei All. Kind regards Alien?; Frem: Saeer? Dashti Sent: 10 March, 201,: 13:58 To: Allan Rosenberg Subj??t: RE: Merjan take me necessary actions. From: Allan Egogm_ Sent: Thursday, Marcia 10, 2011 8:19 AM Ta: Moghad?ami Fard Cc: Sae?d Gash?umd?vaifajrjr Subjaat: RE: Medan WAK. PLLCOOB Case Document 1-23 Filed 03/07/16 Page 7 of 14 Pram: Meghaddami Fans! Sent: Tuesday, March 08, 2011 10:14 AM To: Subject: FW: Marjan {Dear Gawain Piaase Jet U3 have yaw ?nal decisicm; 5 don't like to femard you all aners messages but 3 am under pressure to reply Best Regards Moghadeiami Managing ciiz'ccl?cs'r Tel: +9724 3325 000 ext 300 Faxr+~9714 3532. 37312 c~m?i12 WAK, PLLCOGQ Case Document 1-23 ?rom: {csc@cscq8.com] Sank; Saturday, January 29, 201: 3:50 PM To: Saeed Dasnti Cc: alna?ar svmex?hotmaimom Subject: FW: Agency Agreement Expenses?: on ELEBJEOH Dear Mr. Saeed Dasneti For your kind information. 1:3. 'I{ogards,, Bade? AiNajjar Filed 03/07/16 Page 8 of 14 From; keshavarz Sonic: Saturday, January 29; 2011 2:12 PM To: ?Bader Najjar' Cc: csc; 'MD-?Paci?cship' 5ob?ac? RE: Agency Agreement Exper?an on 21.403361: Dear Mr, Bader A. Najjar, From your way of answering, i ?fee: that you are in a way interested in stonoing this company and that is the reason you are everyday coming up with new and strange requirements. in any case, recentiy there have aiso been some events in CSC which we have not confirmed it and they must be alt thoroughly reviewed anti deaer if the company ?3 to be run in a mutuai and beneficiai ways to both partieg as; it used to run. before. Kindly confirm our understanding is correct for our further planning. Rgds, Capt. H.Kesnavanz Managing Director Valfajn Shipping Company ~3838838 1 8836?996 Fax 1498-21 $833914? email: From: Easier A1 Najjar {maiitnzalna?ar 38%: Saturday, January 29, 2011 2:13 PM To: keshavers aifajr CC: FOFO Subjoct: RE: Agency Agre?ment {Experian on 21.03.2011 MKKESHRVER I AM SORRYJ CAN NOT COME TO ON SUCH A NOTICEAS FAR MRMUKADAMI I DID NOT CONFIRM THAT MGR THE OTHER SHARE OR ANY OTHER PERSGN YQU CHOSE MUST BE IN KUWAIT, AS A BGARQ MEMBER AVRILABLE AT ALL TIMES FOR EASSY AND AS I INFORMED DURING MY LAST TRIP REGARDING THE MID THE PRESENCE OF CEO NOT REALLY NFLEUED. WAK. Case Document 1-23 Filed 03/07/16 Page 9 of 14 cmmii: From: Allan Rosenberg Sank: Tuesday, March 08, 2011 3:08 PM Ta: F?oghaddami Fara: Subject: Re: Marjan Dear Moghadciumi, No, we need a date as simple. as that We have to put the: vesgel in {his} mazkei as sum: as passibie. Certainly, we will charter out. to "the highest paying and most rciiablc cha?crcm The propnsai below is not uccepmbie and nen-commemiai; we can 11m accept chartcrars dictating us how we: should charter our vesseis. Kindiy ask charmer to {welt with radcli'vcry date. Best regard Allan On 8 Mar 261. at ?81129, "Moghaddami Fart nasf'??oasisdxbae?? wromx Dear Nian Can we ?ve w?th ibis proposai? Best Regarda Maghaddmni Managing dimmer Tel: +9714 352:3 00f} ext 300 Fur-99714 352 mm curtail: Worm: md Sent: Tuesday! March 08, 2011 1:01 PM Ta: Meghadciami Farsi Eubjact: RE: Mairjarz Dear Mr. Moghaddamifar?, It scams them is; :3 bmak Era as I have answered to this ques?on many times. Sometimes; yam? massages are also bouncing, back which needs veri?catians of your syslam. 81.1rc31y we: need "the vessel anci the charter rim: wili be what Semen 13332:: for Awa?. Capt. H?Keshavarz Managing Director Valfajr Shipping Company 883Q7QQB a-maii: {fl-Dowa Case Document 1-23 Filed 03/07/16 Page 10 of 14 {Dear Moghaddaml, {Still no news from Bright Ship? is; somewhat: worrying that: One months; of unpaid cl'lizsrter him No reaction to owners claim for mieappropriatet} equipment expires; on March 25?? and we have not received redelivery date yet lx?or any reaction to our USE) 5,000fday offer which we giant via our broker two weeks ago Likewise redeilvery requests from our broker are ignored You wili agree that thug: is mi: in line with normal international shipp?ng practice and suggeet we prepare to regain control of the vesgel w?tl'z the assistaoce from vaif?ajr! Best regards Allan From: Allan Rosenberg Sent: March, 2013, 14:34. To: Moghaddami Ford (to: weed Dashti Subject: Re: Merjan Dem? Moghaddami, As you know, i will alwayr: charter the vessels out subject to .lzimard Approval. Meanwhile, We can not. allow Bright: Ship in {fiat-ate ?(he terms. We have given Bright Ship ?rst offer of USD to which we have not had any reaction ?ll data We will have no problem ?nding deployment for the ?vessel. if we ask for ?rm offers now; but. for that 1 need a redeizivery date which kindly revert with. Bright Ship can wok on one hand ignore: our offer and 31th some time dictate us to charter {he vessel to them under their terms. Best regarde Allan On 8 Mar 201 1,0 at 19:21,, ?Mogimddami g" wrote: Dear Ailan really wish we had so much time to do this why not we go to market for Awefi and whatever we get we will charge them as; well. if we {ion?t wan? to give {hem the vessel that is a different story and we need to involve Mr {Dashti as; well. Best Regards Mogimcldami Managing director Tel: 3525 000 ext 300 Fowl-97 $53 352 7812 WAK, PLLCO12 Case Document 1-23 Filed 03/07/16 Page 11 of 14 A CONSULTANT IS CONDUCTING A FULL STUDY RE STRUCTURING THE COMPANY BASED GN THE ACTUAL NEEDS AND REQUIREMENTS FOR ALL STAFF ENCLUDING THE MD THEN NC) DICTION WILL SEE TAKEN FOR ANY POST Frem: To: CC: Subject: RE: Agency Agreement Experitm (at: 21.03.2011 Sate: Thu, 27 Jan 2011 17?:28:14 $0330 Dear Mr, ?atter A. Naijar, i will be in Dubai on cuming Sunday and Monday. Mn Mogha?damifard will alse be there. if you can came ta Dubai, it wilt be a good opportunity to meet him too. Meanwhile, as Mr. Karimi has informed yet: before, Mr. Mohammad Maghaddamifard is anether board member in CSC together with myself and Mr. Karimi will remain as the MD of the company. Please note above and make your necessary arrangements fer registration purposes. Mr. Karimi will follow anti will get you all necessary particulars and documents. Rgds, Capt? H.Keshavarz Managing Director Valfajr? Shipping Company talwesqtmasgeeam, 8830709253 e-maii: ?lQ?iJ?s/gilfzajm: Frem: Seder Al Najjar {snailtmainaitar Syttiex?khotmail?eml Sent: Wednesday, jammy 26, 2011 431 PM Tu: mm: karimi' Subjett: FW: Agency Agreement Experiam an 21.03.2011 Subject: Agency Mir-seamen: Expering at: 21.03.2011 Date: Wadi 26 35m 2011 15:42:12. ?1-0300 From: mcgumgcg?tcom To: Dear Capt Kaehavarz Sub: Agency Aareement Experiatien 21,03,201}. Hepe that: all is well with yea and your family. Pl CD13 Case Document 1-23 Filed 03/07/16 Page 12 of 14 Reference to the ebeve subject, pleaee mete that we would like to have a meeting te discuss the terms, mnd?tlens end the fees/ tariff in the above said agreement before the expiration date of the said centract "this is in prevent with article Please let me know when it is conveeient t0 meet to discuss and ?nalize all matter needless to say we ere will-leg to meet in or any other place yeu suggest. Awaiting yeur reply with my Best Regerde. . fey, Ne?ee ?ememed ?Mpping Ce, Case Document 1-23 Filed 03/07/16 Page 13 of 14 KGL History Page 1 02?} 3 gramme 53% A Leader in Integrated S?upgz?y (Chair: Marxagemen? 950mg; ?ber}: rg?L News; Comoraie mas-rm :v Aime? ma. 9 ?actmmuna 6L mum? K232. History 011? Enema}! Succese Teri-23y, KGL is {er-3 merraier provider of inmgrated Suppiy Chain Management sewimg in the Middte 82mm fuifiiling E?eawager?nem, Emippmg and Freight, Forwarding needs 0F muratfeat?, regional and interna?enai ciierzts. i~iowever, our j: {Sorretruction Ce. (W.L.L) was emi?ablisshed by Mr. Esma? Daehn, in Co?etiruciton and Stevedoring operatziom: wi En the. 397(5?3, me Ceirrpany began m; mm and Stevcdoring operations whe- rrmaimazwr in Sf?ruwmxh 530M: 3n Kris-mite In 938172, the. Steve?ormg emf {magni?cation uperat?ms were as. Kw Sweat ?I?hreegh the hard wart; at" Mr. Emmi! [32133th and his; Deputy, Mn A!~Wazzan, Km. con?rm: of Saudi Arabia in 19825, when: it started its gtevedmmg in Mimi!) Yaniau?n and ?Is-mam? Po commie-d {a germ a reputation fer emeiimce in transparz?ng marge, indudmg that at? mega we: projects. in the 3989?s, the Commany steaz??iy expander! its; services and beqam gzwv'?ding ween: co?iection ff KGL to became one of the Zargeet and mom ef?cient aervica previews; within {me Benton Degmte the 6: Kuwait WM anvm?im} by Iraq in Che early 19536323; bummer, iike many others; Suffered in the mitist at the negro Mile-wing; the Liberation of Kuwait, {he cmnpany rebuiit ?te Simmering, ?f?ransporratmn, Wane Management, and Was Bimini ems} the ?enere? Manager or? KGL at that time, Mr. Saved marshti, csetinued in; expamion with their perseverance EH .3693. the cm?agmray?? trangaor?t bee: gamer, which wens iaunr?md mier to the Gui?" War in We! an Egypt, expanded its and $yria. KGL rater imaarrm a member the is.er Unfur- {05" Land Transport. In 2995,, KGL became the": {wise Offmr??itm" PICSL amended Ranger by dimr-gi?rarzg 353 line 0? gerwm? by launching me Car Rania? dw?imon in 199?, targeting in; gen: 2569, KGL the ?rst privazimtzion project in Saudi Arabia, xvi-rare it wan a year agreement: operate as, par-2: a (Gui? SStevedering Crimean-y). That game year, KGL tank a major step arm was iister {he ?rs-3i: rum. 11?: 20M, regimmi and (3103255 Gamer-stir?; imtreemd far mm; integrates: Trangszormtirm, Logiietics and $1pr {aromded an omincrtunity for KGL to achieve :sustainable and greater prni?u'abit?w by Eeveraging its core comma and Sammy Chain ?ewiccs. The Kuwait if: Gulf Link Holding; Company Hoidmg) wag: By 259?, the germs-are magmas-,5 unite in order to enhance the services and ef?ciency 03? each matter, well as so treat-e mommies 9 3122120 1 i WAK, PLLCO15 Case Document 1-23 Filed 03/07/16 Page 14 of 14 $5"wa n? - mum. Management Page I of I ?vme teamsKiri P1 Nari $39731th 53? Panama New: :m Slimly {mm Mamxcamm .33. PS 1? Hams;- Mmut K61, lilenmgemmi Executive Etm'trastlve F?til?ml Albaghli Chairman 8: Managing {jimcmr Fadlwl Albaghli Serves the Chairman ml? KGL Parts; international (KG: PI), a post he has: new since leading and {he epea?et?onz?s and affairs; of the-Beard and facilitates; rare-per goven?mnee. He Pom; activity alsscip?meg; at KGL 9i, :?angmg me oeex?atlens and managerrzent echleve ihe Saimmgy. gay-ale and ablative-ml mam: mange: (we: extensive experlel?we in 5evex'a3 art-m in Parts fv?aaimg?n'K??W arid in which he held Severe: poaltlons as airmtm ml" Sl?suaib?il Pen: Conrainer Terminal 8: Sir Termirml. Familial ix: syez?akimd geezer Ol??rzer in Farm and joined KGL gmup in 2000. We? being the Ware Chairmfm amt} ?llet ?eeiness Ql?l?lcer er KGL ?d?el warmed 239mm; of Silence {legreae in Genera? Buyis'zem Marine Comm; Zen degree ?12 Mame Affairs {mm me of Miami, Sal-lam of Maer ab. Science in 1981 {ewe in 291%, r?ek-Ljaeciiwt?ly. Farr?th also a Dieleme in P?mt Qg'mratimas, Flaming, {??velepmm the Part Felixtow {minute if?: Engtamsi, mat} a Diplmm Er: Part Management from the institute of Sin-lg mf the us; Naval Arm,de in Maryland. as well ms the International Ontuanograyhy Foundmien in Executive Advi?m?y Beard rnc?mlmr KGL Mien Rumsaenlxerg Chief Executive Of?cer #131. ?eld?s International Allan scarves; am the Liner ?xacu?m Of?cer mi? KGL Pans: lrxbiw?nm?mrlal (KGL W). a {303$ ETC 3" C330 07' KGL pi: Allan awe-glow the company?s iatmmgir: plan and the meme-n; iml?amve provides leadership :0 noslrlon KGiw PI all the {eminent ol? the Ports i?vizmngement industry. Prior he; current role, Allan the Chief Executive (Mme: a? KC-SL Shipping, 3 pm: lam has held sir yew r2? l-vxpmome Maersk. Fer this past :23 years, we has; been {jammy Menage!" var: Cafgm?hiz! mam: cm a regmmi level In 133015, he we?: rumored to serve {or a Emmi time with 33/221201} WAK. PLLC016