In this episode, Michael Volkov examines OFAC’s October 27, 2026 settlement with Extreme Networks, which agreed to pay $1,529,685 for nine apparent violations involving exports to MMZA, a Russian defense manufacturer blocked under the 50 percent rule through its ownership by Almaz-Antey. The company had a policy to review every Russia-related dealing, yet OFAC says it ignored red flags that included MMZA email addresses and addresses in purchase orders, a distributor that supplied MMZA’s website before switching to a different named end user, and customer portal registrations made under the wrong company name. Michael walks through the penalty calculation, the parallel Justice Department non-prosecution agreement and its “near-miss” characterization of the company’s disclosure, and eight practical lessons: treat acquired customer lists as acquired risk, make the 50 percent rule operational, resolve paperwork mismatches with independent evidence, never treat a distributor’s statement as a control, follow up on screening hits, connect compliance to what the business knows, watch portals and support channels, and oversee foreign affiliates closely.