White Paper
Sanctions screening for schools and universities: a practical compliance guide
Everything school CFOs, business officers, and compliance leads need to know about OFAC screening requirements, documented workflows, and audit-ready evidence.
SecurePoint Education
OFAC Sanctions Screening for Educational Institutions
2026 Edition · 12 pages
The February 2026 IMG Academy enforcement action was a turning point for schools. OFAC made clear that educational institutions are subject to the same sanctions compliance requirements as banks and defense contractors. This white paper provides a practical framework for school CFOs and business officers to build a screening program that is proportionate, documented, and audit-ready.
Key takeaways
- Why OFAC enforcement now applies directly to educational institutions
- The six categories of parties schools must screen (beyond students)
- How the IMG Academy settlement changed the compliance landscape for schools
- What NAIS and NBOA recommend for independent school OFAC programs
- How to build a documented screening workflow that satisfies auditors
- What evidence packs and audit trails schools need to maintain
Why this matters now
Before the IMG Academy case, most schools assumed OFAC enforcement was limited to financial institutions. The $1.72 million settlement for 89 violations proved otherwise. OFAC cited “reckless disregard” — a standard that applies whenever names are publicly available on the SDN list and an institution fails to check.
Schools that accept international tuition, donations, or research funding from foreign sources are at risk. This white paper provides a step-by-step framework to move from zero screening to a documented compliance program — without requiring an enterprise IT buildout.
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