NAIS and NBOA both recommend a documented OFAC screening program for every independent school
Industry Guidance
NAIS and NBOA both recommend OFAC screening for independent schools
The National Association of Independent Schools and the National Business Officers Association have each published guidance recommending that private K-12 schools implement documented sanctions screening programs. The February 2026 IMG Academy settlement — $1.72M for accepting tuition from SDN-listed parents — made the enforcement risk concrete.
OFAC applies to every financial relationship — not just enrollment
Tuition-paying parents and guardians
Every party making tuition payments — regardless of citizenship or country of origin — must be screened against OFAC sanctions lists before enrollment is confirmed.
Annual fund and major donors
Development officers must screen donors before accepting gifts. This includes annual fund contributors, capital campaign donors, and pledged gifts.
Corporate and event sponsors
Companies and organizations sponsoring school events, athletic programs, or facilities must be screened before sponsorship agreements are signed.
Scholarship and grant grantors
Third-party organizations providing scholarship funds, merit grants, or need-based aid to students must be screened as financial counterparties.
Vendors and service providers
Contractors, construction firms, and service providers receiving payment from school funds require screening, particularly for larger contract values.
Third-party tuition payment agents
International families sometimes route tuition through third-party agents or education consultants. The routing entity must also be screened.
Private School Dashboard
Unified screening across enrollment, development, and finance
A single dashboard lets your business office and development team see screening status across all parties — tuition payors, donors, and sponsors.
- Separate queues for enrollment, donations, and vendor screening
- Role-based access so development staff only see donor records
- Automated alerts when a screened party appears on an updated list
- Evidence packs exportable for board review or external audit
OFAC screening for private schools — FAQ
Common questions from independent school business officers, CFOs, and heads of school.
Related Resources
Education compliance resources
OFAC Screening for Schools
The enforcement backdrop: why OFAC applies to all educational institutions and what the IMG Academy case established.
Learn moreSponsor & Donor Screening
Due diligence for annual fund contributions, major gifts, endowments, and corporate sponsorships.
Learn moreCompliance Evidence Packs
Audit-ready documentation for every screening decision — designed for auditor and board requests.
Learn moreContinuous Monitoring
Automated re-screening keeps your school current without manual checks.
Learn moreOFAC Licensing Paths
A flagged donor or sponsor does not always mean forgoing the relationship. Explore licensing options.
Learn morePlans & Pricing
Compare Standard, Plus, and Enterprise. Unlimited screenings on every plan.
Learn moreBuild a documented OFAC program — before the next enforcement action
Most private schools are live within 48 hours. No IT integration required.