Avaya disclosed in its Annual Report filed with the SEC for fiscal year 2018: "During Avaya’s recent review of its compliance practices in regards to sanctions regulations administered by the Office of Foreign Assets Control (“OFAC”) of the U.S. Department of the Treasury, Avaya determined that AISL processed a sales order received through HKT for an end user identified as MelliBank PLc Hong Kong Branch (“MBHK”). Though this entity is not specifically identified on OFAC’s Specially Designated Nationals and Blocked Persons List, it is designated as a Specially Designated National and Blocked Persons (“SDN”) as a result of the SDN designation of its ultimate parent company in 2016 pursuant to Executive Order 13599. The gross revenues Avaya received from the sale were $4,954.01 and the net profits from the sale were $2,031.15. Once the sale to MBHK was discovered, Avaya terminated all agreements and dealings with MBHK, including a sales and maintenance agreement. Avaya does not intend to engage in any future activities, transactions or dealings with MBHK.

Avaya filed a voluntary disclosure with OFAC on April 4, 2018 regarding the matter described above. Avaya remains committed to complying fully with U.S. sanctions laws and regulations and has devoted significant resources to its global trade compliance program. Avaya is in the process of implementing various enhancements to strengthen its existing global trade compliance procedures and plans to work with HKT on implementation of other remedial measures, including an improvement plan designed to prevent future exposure to persons targeted under U.S. sanctions."

"It is our business practice to adhere to local as well as international trade requirements for cross-border
transactions. Notwithstanding the isolated occurrence referenced in the disclosure, Avaya maintains best-in-class processes and procedures to ensure that incidents such as MelliBank do not re-occur." (5/27/2020)