The U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) recently imposed a fine of $1.75 million against IMG Academy for violations of U.S. sanctions laws related to its acceptance of tuition payments from foreign payors. U.S. sanctions are administered by OFAC, which sets forth regulations on dealings with embargoed countries and maintains the Specially Designated Nationals and Blocked Persons List (SDN List), which identifies individuals and entities with whom U.S. persons are generally prohibited from engaging in transactions. 

In this matter, IMG Academy accepted tuition payments from parents who appeared on the SDL list due to their affiliation with a Mexican drug trafficking organization. Basic screening of parents and payors against the SDN List, or conducting routine due diligence, would likely have identified the sanctions risk.

On Monday, April 13 at 1 p.m. we will be joined by attorneys from Venable LLC’s International Trade and Logistics Group to discuss this settlement and its relevance to our independent schools.

You can register to join that conversation here.

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