The award winning, Compliance into the Weeds is the only weekly podcast which takes a deep dive into a compliance related topic, literally going into the weeds to more fully explore a subject. Looking for some hard-hitting insights on compliance? Look no further than Compliance into the Weeds! In this episode of Compliance into the Weeds, Tom Fox and Matt Kelly discuss the DOJ and OFAC actions involving Extreme Networks.
The company’s Russia office sold advanced networking equipment to Avangard, a Russian state-owned defense firm on U.S. sanctions lists via majority ownership by Almaz-Antey. After a whistleblower report in April 2022, Extreme investigated and briefed its board by June but did not disclose until investigative reporters contacted the company in October with additional facts, prompting a renewed inquiry and self-disclosure by year-end. DOJ deemed the disclosure driven by “imminent threat,” denying voluntary self-disclosure credit and issuing a non-prosecution agreement rather than a declination, with $2.5 million in combined penalties. The episode examines uncertainty about what changed, how DOJ benefits from quality disclosures, and OFAC’s emphasis on timely, effective screening and heightened diligence in high-risk jurisdictions like Russia.
Key Highlights
- The enforcement actions
- Imminent Threat Debate
- OFAC Red Flags
- Screening Lessons
- Self Disclosure Policy
Resources
Matt in Radical Compliance
Tom
A multi-award winning podcast, Compliance into the Weeds was most recently honored as one of a Top 25 Regulatory Compliance Podcast and a Top 10 Business Law Podcast, and a Top 12 Risk Management Podcast. Compliance into the Weeds has been conferred a Davey, Communicator and w3 Award, all for podcast excellence.