Question 1

Was IMG Academy a boarding school?

Accepted Answer

Yes. IMG Academy is a Florida-based boarding school for elite student athletes. The February 2026 OFAC settlement — $1,718,000 for 89 apparent violations — involved tuition payments accepted from two parents who were Specially Designated Nationals with ties to Mexican drug cartels. The school never screened them despite their names appearing on the public SDN list.

Question 2

Why do boarding schools have more OFAC exposure than day schools?

Accepted Answer

Boarding schools collect substantially more revenue per student: full-year tuition, room and board, activity fees, and optional programs can exceed $70,000–$90,000 annually. That means a single unscreened family represents a much larger OFAC violation potential than a day school payment. Boarding schools also tend to have higher international enrollment, increasing exposure to sanctioned jurisdictions.

Question 3

Should boarding schools screen the student or the parent?

Accepted Answer

Both. The student is the enrolled party; the parent or guardian is the tuition payor. OFAC regulations apply to the financial transaction, so anyone sending money to the institution must be screened. The IMG Academy case specifically involved tuition payments from parents on the SDN list — not the students themselves.

Question 4

What does "reckless disregard" mean in the IMG Academy context?

Accepted Answer

OFAC found that IMG Academy acted with "reckless disregard" because the names of sanctioned individuals were publicly available on the OFAC SDN list and the school made no effort to check. Under OFAC regulations, failing to consult a freely available public list when processing substantial financial transactions is treated as willful ignorance, not an honest mistake.

Question 5

How often should a boarding school re-screen enrolled families?

Accepted Answer

At minimum: at enrollment, before each academic year, and whenever a sanctioned list is updated. SecurePoint Education runs continuous re-screening in the background, so schools are automatically alerted if a previously cleared family is later added to an OFAC or allied list. Annual-only screening is not sufficient given how frequently lists change.

Question 6

Do boarding schools need to screen alumni donors?

Accepted Answer

Yes. Alumni and parent donors are financial counterparties. Accepting a gift — regardless of amount — from an SDN-listed individual is an OFAC violation. Schools with active development programs should screen all donors before processing gifts, not just major gifts above a threshold.

Boarding schools carry compounded OFAC risk — and a $1.72M settlement proves it

IMG Academy: $1.72M for accepting tuition from SDN-listed parents

Six reasons residential schools face compounded OFAC risk

High per-student revenue

International enrollment dependency

Multi-year financial relationships

Residential payments from third parties

Alumni giving programs

Gap year and exchange programs

Screen throughout the enrollment lifecycle — not just at admission

Pre-enrollment: screen the student and all payors

Annual re-enrollment: re-screen before each academic year

Continuous monitoring: automated re-screening on list updates

Alert adjudication: document every review decision

Screen entire enrollment rosters — then monitor continuously

OFAC screening for boarding schools — FAQ

Education compliance resources

OFAC Screening for Schools

Tuition Payor Screening

Continuous Monitoring

OFAC Licensing Paths

Education White Paper

Plans & Pricing

Boarding schools are an OFAC enforcement target — screen before enrollment