EXTREME NETWORKS TO PAY $975,722 IN FIRST DOJ “NEAR MISS” NON-PROSECUTION AGREEMENT OVER SALES TO RUSSIAN WEAPONS MANUFACTURER

WASHINGTON — The U.S. Department of Justice has entered into a non-prosecution agreement with Extreme Networks, Inc., resolving a national security investigation into unlawful sales of networking equipment and services to a Russian weapons manufacturer owned by a sanctioned entity.

Extreme Networks agreed to pay $975,721.84 in criminal penalties, consisting of a $487,860.92 criminal fine and $487,860.92 in forfeiture representing proceeds from the sanctions and export-control offenses. The company will also resolve a parallel administrative action with the Treasury Department’s Office of Foreign Assets Control. The executed agreement states that Extreme Networks agreed to pay an additional $1,529,685 administrative penalty to OFAC.

The resolution marks the Justice Department’s first non-prosecution agreement involving a “near miss” voluntary self-disclosure under its 2026 Corporate Enforcement and Voluntary Self-Disclosure Policy. Under the policy, a near-miss case can involve a company that fully cooperated and appropriately remediated misconduct but did not qualify for a complete declination because its self-report did not satisfy the requirements for a voluntary self-disclosure or because aggravating factors warranted a criminal resolution.

Extreme Networks did not qualify for a declination because its disclosure was not considered timely under the policy. The company learned of allegations involving its Russia-based employees through a whistleblower report in April 2022 and began an internal investigation. Several months later, while that investigation was continuing, an investigative journalist contacted the company with additional information concerning possible misconduct. Extreme Networks then disclosed the potential violations to the Justice Department shortly before the information was expected to become public. The agreement states that the disclosure therefore did not satisfy the policy requirement that disclosure occur before an imminent threat that DOJ would learn of the misconduct.

The underlying investigation centered on sales to Moscow Machinery Building Plant Avangard, known as MMZA, a Russian weapons manufacturer owned by JSC Concern Almaz-Antey, which had been placed on the Treasury Department’s Specially Designated Nationals and Blocked Persons List in July 2014.

Between approximately March 2018 and March 2022, Extreme Networks, through its then-Russia-based subsidiary Extreme Networks Rus LLC, processed and fulfilled 11 purchase orders involving networking equipment and services for MMZA without the required OFAC license or authorization. MMZA was a primary producer of the S-300 and S-400 anti-aircraft missile systems used by the Russian military.

According to the agreement, a small group of employees within Extreme Networks’ Russian subsidiary concealed the activity from the company’s U.S.-based compliance personnel. The company’s employees and agents filed electronic export information that falsely identified either a distributor or another entity as the ultimate consignee for shipments connected to MMZA. The agreement states that the conduct interfered with the U.S. government’s enforcement of sanctions and export controls intended to protect national security and economic interests.

The company ultimately earned approximately $487,860.92 in revenue from the transactions. The executed agreement states that Extreme Networks admits, accepts, and acknowledges responsibility for the conduct described in the attached Statement of Facts and acknowledges that those facts constitute violations of federal law, including conspiracy, willful export-control and sanctions violations, filing false export information, and smuggling.

The Justice Department credited Extreme Networks with full cooperation during the investigation. The company responded to multiple subpoenas on a rolling basis, produced nearly 400,000 documents, provided translations, expanded its document-production efforts, made current and former employees available for interviews, conducted an internal investigation, presented its findings to federal authorities, and agreed to toll applicable statutes of limitation while the investigation continued.

Extreme Networks also undertook substantial remediation. The company terminated its Russian subsidiary and Russia-based personnel, ended its agreement with the distributor involved in the unlawful sales, increased trade-compliance training, hired an outside compliance consultant, expanded end-user diligence and screening procedures, hired additional compliance personnel, adopted a new denied-party screening system, and implemented additional merger-and-acquisition due diligence procedures.

Based on those remedial measures and the company’s compliance program, DOJ determined that an independent compliance monitor was not required. Extreme Networks remains obligated to maintain its compliance program, continue cooperating with federal authorities, and report on implementation of its compliance measures during the term of the agreement.

Under DOJ’s 2026 Corporate Enforcement and Voluntary Self-Disclosure Policy, companies seeking a full declination generally must voluntarily self-disclose misconduct, fully cooperate with the government, timely and appropriately remediate the wrongdoing, and avoid aggravating circumstances that would make a criminal resolution appropriate. The policy separately provides a “near miss” path for companies that fully cooperate and remediate but fall short of the requirements for a complete declination.

The investigation was conducted by the FBI Charlotte Field Office, the Department of Commerce’s Bureau of Industry and Security, and Homeland Security Investigations.

Former National Security Division Trial Attorney Maria Fedor of the Counterintelligence and Export Control Section and Assistant U.S. Attorney Adam Hulbig for the Eastern District of North Carolina prosecuted the matter.

The non-prosecution agreement does not erase the admitted conduct or extend immunity beyond the conduct specifically covered by the agreement. It also does not protect individuals from prosecution, and Extreme Networks remains subject to prosecution if it breaches the terms of the agreement.

U.S. Department of Justice, National Security Division, Non-Prosecution Agreement — Extreme Networks, Inc., executed October 2026. (Free Download)

U.S. Department of Justice, Corporate Enforcement and Voluntary Self-Disclosure Policy, 2026. (Free Download)

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