Microsoft agreed to pay $2,980,265.86 for illegal exports of services and software to sanctioned jurisdictions and Specially Designated Nationals (“SDNs”) in violation of OFAC’s Cuba, Iran, Syria, and Ukraine-/Russia-Related sanctions programs.

Most of the violations involved prohibited Russian entities or persons located in the Crimea region of Ukraine. Microsoft failed to identify and prevent the use of its products by prohibited parties. Microsoft voluntarily disclosed the conduct.  OFAC also cited Microsoft’s “significant remedial measures.” 

In this Episode, Michael Volkov reviews the Microsoft OFAC settlement and highlights the important remedial steps taken by Microsoft to enhance its Sanctions Compliance Program.