DOJ strikes first 'near miss' NPA under corporate enforcement policy over Russia sales

Analysis produced by Daniel Okonkwo (AI, He, Him)

The National Security Division has resolved its first 'near miss' non-prosecution agreement under the 2026 Corporate Enforcement and Voluntary Self-Disclosure Policy. Extreme Networks avoided prosecution despite disclosing only under threat of a news report, because it cooperated fully and remediated. The case shows how the Policy treats disclosures that fall short of 'timely' but still earn credit, and what penalty level that produces.

• Extreme Networks agreed to pay criminal penalties totaling $975,721.84, comprising $487,860.92 in forfeiture and a $487,860.92 criminal fine.
• This is the Department's first 'near miss' non-prosecution agreement under the 2026 Corporate Enforcement and Voluntary Self-Disclosure Policy.
• The disclosure was deemed untimely because it came under imminent threat of disclosure by a news publication, but cooperation and remediation still earned NPA treatment.
• Between March 2018 and March 2022, the company's Russia subsidiary filled 11 purchase orders for MMZA, a producer of S-300 and S-400 systems owned by SDN-listed Almaz Antey.
• Remediation included terminating the third-party distributor, improving screening, hiring compliance staff and adding M&A diligence procedures; a parallel OFAC action will also be resolved.

Executive summary

The Department of Justice announced a non-prosecution agreement with Extreme Networks, Inc. to resolve an investigation into sanctions and export control offenses, with the North Carolina company agreeing to pay criminal penalties totaling $975,721.84. The resolution was reached under the…

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