The US Justice Department has entered its first “near-miss” non-prosecution agreement under the National Security Division’s 2026 corporate enforcement policy, resolving sanctions and export-control conduct by Extreme Networks.
The department said the networking company’s Russian subsidiary supplied equipment and services through intermediaries to the Moscow Machine-Building Plant Avangard, a weapons producer owned by sanctioned Almaz-Antey. The conduct covered 11 purchase orders between 2018 and 2022.
Extreme Networks did not qualify for the policy’s presumption of a declination because its disclosure came after the company learned that publication of the matter was imminent. Prosecutors nevertheless credited the company’s disclosure, cooperation and remediation. The agreement requires payment of US$975,721.84, divided equally between forfeiture and a criminal fine.
The resolution does not amount to a criminal conviction. Its significance lies in the department’s decision to extend non-prosecution treatment to a disclosure that narrowly missed the timing requirement, while still imposing a financial penalty and recording the underlying conduct.
Official Justice Department release
