Build a defensible OFAC compliance program — step by step
What an Incomplete Program Looks Like
IMG Academy screened no one — and paid $1.72M
The IMG Academy settlement is the most direct example of a missing compliance program. The school had no OFAC screening at all — not for students, not for payors, not for anyone. Schools that screen some parties but not others face proportionally smaller exposure, but still face enforcement risk.
A complete program covers all four phases — not just the first
Schools with incomplete programs typically cover Phase 1 but miss Phases 2, 3, or 4. Each gap creates enforcement exposure.
Identify: know who you must screen
Map every category of financial counterparty: enrolled students, tuition payors and guarantors, scholarship sponsors, donors, event sponsors, vendors, visiting faculty, and third-party payment agents. If money flows to or from the party, they require screening.
Screen: check before transactions are accepted
Screen all parties against OFAC SDN, OFAC Consolidated, and allied lists before confirming enrollment, accepting donations, or executing payment arrangements. Do not wait for a concern — screen proactively as standard procedure.
Monitor: re-screen when lists update
OFAC lists are updated multiple times per week. Annual re-screening alone misses additions between cycles. Continuous monitoring re-screens all active parties automatically and alerts your compliance team to new matches.
Document: retain records of every screening and decision
For each screening, retain the name, date, lists checked, result, and — for any match — the reviewer's documented decision and rationale. Retain records for at least five years. This documentation is your primary defense in an enforcement review.
Six areas where school compliance programs fail
Screen payors, not just students
The IMG Academy settlement was about unscreened tuition payors — parents making financial transfers. Screening only the enrolled student leaves the most common exposure unaddressed.
Screen donors before accepting gifts
Development programs routinely accept gifts without OFAC screening. Every donor — annual fund, major gift, or event sponsor — is a financial counterparty that must be screened.
Re-screen when lists update
A party clear at enrollment may be added to the SDN list mid-year. Annual re-screening leaves a 12-month gap. Continuous monitoring eliminates this gap.
Document review decisions
Clearing a match without documentation provides no compliance value. Every review must record the rationale: what information was compared, what was found, and why the case was cleared or escalated.
Train the business office, not just compliance
Screening tools are used by business officers, development staff, and DSOs — not just compliance professionals. Training must cover who to screen, when, and how to handle a match.
Cover all campuses and programs
Multi-campus schools and institutions with satellite programs must ensure each location screens independently. A compliant main campus does not cover unscreened satellite operations.
OFAC compliance checklist for schools — FAQ
Common questions from school business officers, compliance managers, and heads of school building their first OFAC program.
Related Resources
Education compliance resources
OFAC Screening for Schools
The enforcement backdrop and why the checklist exists — what OFAC requires of educational institutions.
Learn moreHow to Clear a Screening Alert
Step-by-step adjudication guide for business officers reviewing match alerts.
Learn moreCompliance Evidence Packs
The documentation your program produces — exportable, audit-ready evidence for every screening.
Learn moreContinuous Monitoring
Automated re-screening handles Phase 3 without manual work.
Learn moreOFAC Licensing Paths
What to do when Phase 2 produces a confirmed match — licensing options for schools.
Learn morePlans & Pricing
Compare Standard, Plus, and Enterprise. Unlimited screenings on every plan.
Learn moreRun your checklist against a live compliance program
SecurePoint Education covers all four phases — screen, monitor, review, and document.