Question 1

Do colleges and universities have higher OFAC exposure than K-12 schools?

Accepted Answer

Yes, in terms of scope. Universities face exposure across more departments and transaction types: the registrar and student accounts office handles tuition from international students; the research office processes grants with foreign sponsors; the development office accepts gifts and endowment contributions from international donors; and the provost office hosts visiting faculty and exchange scholars. Each creates a separate category of OFAC obligation.

Question 2

Does OFAC screening apply to research grants from foreign sponsors?

Accepted Answer

Yes. If a foreign government agency, research institution, or private company on the SDN list is funding university research, accepting those funds is an OFAC violation. Principal investigators and the sponsored programs office should screen all grant counterparties — including overseas sub-awardees — before executing grant agreements.

Question 3

How should a university handle an international student whose tuition payor is flagged?

Accepted Answer

Do not immediately deny enrollment. A screening flag is a potential match, not a confirmed violation. The compliance team should review the match — compare the name, date of birth, nationality, and context — and document the decision. If the match is a true positive (confirmed SDN match), consult legal counsel about OFAC licensing options before taking action. SecurePoint Education's licensing assessment tool identifies whether a General or Specific License may be available.

Question 4

What is a university's obligation regarding foreign gifts under OFAC?

Accepted Answer

Under OFAC regulations, accepting a gift from an SDN-listed individual or entity is a prohibited transaction. Universities must screen foreign donors — particularly those giving above a de minimis threshold — before processing gifts. Endowment pledges from foreign governments or sovereign wealth funds require enhanced due diligence.

Question 5

Are visiting faculty and exchange scholars subject to OFAC screening?

Accepted Answer

Yes. Visiting faculty, postdoctoral researchers, and exchange scholars from foreign countries may be from sanctioned jurisdictions or on the SDN list. Universities should screen visiting scholars at the time of appointment, before any compensation or stipend is paid.

Question 6

Who at a university is responsible for OFAC compliance?

Accepted Answer

OFAC compliance is a shared responsibility across multiple offices: student accounts (tuition), sponsored programs (research grants), development and alumni relations (donations), and HR or provost's office (faculty). SecurePoint Education supports role-based access so each office sees only its relevant screening queue, while the chief compliance officer has a consolidated view.

Higher education's OFAC exposure spans every department that touches money

Six distinct OFAC risk categories in higher education

International student tuition

Research grants from foreign sponsors

Foreign gifts and endowment contributions

Visiting faculty and exchange scholars

Study abroad and exchange partnerships

Technology transfer and licensing

A cross-departmental screening program built for higher education

Student accounts: screen at enrollment and before each semester

Sponsored programs: screen before grant agreements are executed

Development office: screen donors before gifts are processed

Compliance office: monitor continuously and review alerts

Audit-ready documentation for every department and every screening

OFAC compliance for colleges and universities — FAQ

Education compliance resources

Screening International Students

OFAC Screening for Schools

Sponsor & Donor Screening

OFAC Licensing Paths

Education White Paper

Plans & Pricing

A university-wide OFAC program — built in days, not months