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Another FAANG Enforcement Action: Microsoft pays just under $3 million

Settlement Agreement between the U.S. Department of the Treasury’s Office of Foreign Assets Control and Microsoft Corporation

Release Date


The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) today announced a settlement with Microsoft Corporation (“Microsoft”), a multinational technology company headquartered in Redmond, Washington. Microsoft has agreed to remit $2,980,265.86 to settle its potential civil liability for 1,339 apparent violations of the Cuban Assets Control Regulations, the Iranian Transactions and Sanctions Regulations, the Syrian Sanctions Regulations, and the Ukraine-/Russia-Related Sanctions Regulations involving the exportation of services or software from the United States to comprehensively sanctioned jurisdictions and to Specially Designated Nationals or blocked persons. The settlement amount reflects OFAC’s determination that Microsoft’s conduct was non-egregious and voluntarily self-disclosed.

OFAC Notice

And the enforcement information document:

So, for you keeping score at home, the failings include due diligence failures (including some evasion by Microsoft Russia staff), lack of screening for 50 Percent Rule parties, and lack of screening outside of Latin script names…


OFAC Notice

Enforcement Information

Categories: 50% Rule Civil Monetary Penalties Crimea Ukraine sanctions Cuba Sanctions Enforcement Actions Iranian Sanctions OFAC Updates Ukraine sanctions


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