Sanctions screening for schools and universities: a practical compliance guide
SecurePoint Education
The New Education Compliance Reality in 2026
2026 Edition · 8-page PDF
The February 2026 IMG Academy enforcement action was a turning point for schools. OFAC made clear that schools are not exempt from the sanctions prohibitions that bind every U.S. person, and said that, as a starting point, it may be advisable to screen students, counterparties to tuition agreements, and payors. 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
- What the IMG Academy settlement showed about OFAC enforcement and schools
- Who a school screens beyond the student: parents, payors, sponsors, donors, visiting faculty, and vendors
- The five compliance failures that recur in education
- Why a payment processor's own screening is not the institution's
- A five-pillar framework for a documented screening workflow
- A 90-day action plan, and the questions trustees should ask
Why this matters now
The IMG Academy case settled 89 apparent violations for $1.72 million: tuition agreements with, and payments from, two parents on the SDN List. Among the aggravating factors, OFAC found reckless disregard, including that the school did not screen parties whose names were on the public SDN List.
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.