Enforcement Release - Extreme Networks

Date issued: Oct. 28 2026

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TURBOFAC Commentary (254 words)

Notes common to Enforcement Release - Extreme Networks, Settlement Agreement - Extreme Networks and Extreme Networks - Non-Prosecution Agreement

1) Compare Enforcement Release - Microsoft Corporation (similar case where a “rogue” Russian subsidiary of a U.S. parent company engaged in willful sanctions violations, while the U.S. person parent facilitated or otherwise played a role in the transactions and therefore engaged in its own violations). Note that, in this case, OFAC does not suggest that the U.S. person parent handling the compliance function constituted a violation. Instead, it was that “Extreme [the U.S. person] exported networking equipment and related services from the United States,” indicating that the Russian subsidiary was acting more as a distributor than a subsidiary that has commercial operations independent of the U.S. person.

2) The violations committed by the...