OFAC Sanctions Pose Unique Compliance Risks For Independent Schools

The US Department of Treasury's Office of Foreign Assets Control (OFAC) recently published an enforcement release (the Release) announcing a $1.7 million settlement with IMG Academy (IMG), an independent school located in Bradenton, Florida, to settle IMG's potential liability for violating OFAC counternarcotics sanctions. All independent schools, particularly those that enroll international students, are strongly encouraged to promptly implement measures to mitigate potential risk and inadvertent violations of US sanctions laws.

In Depth

Background

The OFAC advances US foreign policy and national security objectives by administering and enforcing US economic and trade sanctions. Among other activities, these sanctions generally restrict dealings by US persons (including any entities organized under US law and any inpiduals who are US citizens, legal permanent residents, or physically located in the US) with embargoed jurisdictions and designated entities and inpiduals, such as