DEPARTMENT OF THE TREASURY
OFFICE OF FOREIGN ASSETS CONTROL
SETTLEMENT AGREEMENT
This settlement agreement (the “Agreement”) with respect to is made by and between the U.S. Department of the Treasury’s (the “Department”) Office of Foreign Assets Control (OFAC) and Extreme Networks Inc. (“Extreme”) including its subsidiaries, assignees, successors, and affiliates worldwide (collectively, “Respondent”).
I. PARTIES
OFAC administers and enforces economic sanctions against targeted foreign countries, regimes, terrorists, international narcotics traffickers, human rights abusers, and proliferators of weapons of mass destruction, among others. OFAC acts under Presidential national emergency authorities, as well as authority granted by specific legislation, to impose controls on transactions and freeze assets under U.S. jurisdiction.
Extreme is a North Carolina headquartered artificial intelligence and cloud networking solutions provider that employs over 2,800 employees across offices in 29 countries. Extreme’s former Russian...
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...