Design a defensible school compliance program — documented, adjudicated, preserved
The compliance question
Did you have a documented program — before the flag?
OFAC enforcement under the 'reckless disregard' standard does not require that a school intended to violate sanctions. It asks whether the school had a reasonable program to detect the violation. In the IMG Academy case, zero screenings were performed. A documented program would have produced a different outcome — and, critically, a different settlement posture.
The six pieces of a defensible school program
Scope definition
Written scope across students, tuition payors, sponsors, donors, vendors, and visiting faculty — with rationale for every inclusion and exclusion.
Screening cadence
Configurable screening and re-screening schedules. Configurable automated re-screening against list changes. Continuous monitoring across enrolled parties.
Match review queue
Every potential match routed to the right reviewer with confidence score, matched list, regulatory context, and a decision template.
Adjudication record
Every clear / hold / escalate / reject decision captured with reviewer identity, timestamp, rationale, and regulatory citation.
Licensing workflow
Guided assessment, Specific License drafting, license tracking, expiration alerts, retroactive re-alerts — the full OFAC licensing lifecycle.
Evidence export
Self-contained evidence packs. 10-year audit log. SIEM/data-lake forwarding on Enterprise.
From flag to documented decision
Every step logged. Every reviewer identified. Every decision defensible.
Match surfaces
Screening returns a potential match with confidence score, matched list, sanctions program, and country context. The clear-and-close path is guarded, not defaulted.
Reviewer adjudicates
Reviewer compares name, date of birth, nationality, and payment context. Rationale captured in the case note. Decision template enforces a written justification before the record closes.
Licensing path (if applicable)
On a hold, the licensing engine surfaces General / Specific License options, drafts an application letter, and tracks the license to expiration. Counsel reviews every output.
Evidence pack exported
Auditor-ready PDF + CSV bundle captures the full decision — screening, match, reviewer, rationale, licensing status, regulatory citation. 10-year retention on the immutable log behind it.
Next steps
Where compliance leads start
Education Launch
30-day implementation — configured, documented, trained.
Learn moreOFAC Licensing
The revenue-preservation workflow in detail.
Learn moreAudit & Recordkeeping
What a school needs to retain, and for how long.
Learn moreSchool Compliance Checklist
A phased program-build guide.
Learn moreFlagged Payor Workflow
What to do in the first 24 hours after a hit.
Learn moreEducation White Paper
The full compliance guide for schools and universities.
Learn moreFor Business Offices
The finance and tuition-protection lens.
Learn moreFor Advancement
The development and donor-intake lens.
Learn moreCompliance-lead FAQ
What program owners and counsel ask first.
Book a school compliance review
A working session with your compliance lens. We walk your actual program scope, adjudication routing, and licensing posture.