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Independent schools cannot afford an April Fools approach to sanctions screening. Review the OFAC risks hiding in your daily tuition and payment workflows.
2 min readBy SecurePoint USA
April 1st is about practical jokes. Compliance failures are not funny, especially when schools handle tuition, prominent donors, international sponsors, and a web of third-party vendors.
Most schools are not built to catch sanctions exposure in day-to-day finance operations. Payments can come from parents, relatives, off-shore businesses, or opaque third parties.
Don't wait for your auditors to find a gap. Look at these five critical intervention points where unverified funds can accidentally enter your operating accounts.
Are you screening the actual source of the funds, or just the student on the enrollment contract?
Often obscure the true geographic origin of a payment. Relatives footing the bill must be screened against the SDN list.
Development offices celebrating large gifts must coordinate with the business office to ensure the donor is not a sanctioned entity.
Onboarding a new software provider or physical contractor? Screening accounts-payable payees is a common control, because U.S. persons generally cannot pay a blocked person, whatever the service.
Can you prove you ran a check six months ago? Ephemeral "I Googled them" checks leave nothing to show.
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