$1 Million Criminal Penalty for Sanctions and Export Violations

The Department of Justice announced recently that a U.S. company will pay nearly $1 million in criminal penalties as part of a non-prosecution agreement resolving a DOJ investigation of sanctions and export control offenses. Separately, the Treasury Department’s Office of Foreign Assets Control announced a $1.53 million settlement with the company related to these violations.

A DOJ press release states that over the course of four years this company, through a Russia-based subsidiary, processed and fulfilled 11 purchase orders for networking equipment and services to a Russian weapons manufacturer owned by an entity added to the Specially Designated Nationals and Blocked Persons List in July 2014. To facilitate these sales employees concealed the identity of the buyer from the company’s global trade compliance group, causing the company to file false electronic export information via the Automated Export System. 

The DOJ notes that this NPA was reached under its 2026 Corporate Enforcement and Voluntary Self-Disclosure Policy, “which incentivizes companies to voluntarily disclose discovered misconduct, cooperate with Department investigations, and timely and appropriately remediate the wrongdoing.” The DOJ adds that this is the first NPA in a “near-miss” case under that policy, meaning a case that involved full cooperation and appropriate remediation (e.g., improving screening procedures, hiring additional compliance personnel, and implementing diligence procedures in connection with mergers and acquisitions) but did not qualify for a declination of prosecution because the company’s disclosure occurred under imminent threat of disclosure by a news publication.