On February 12, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced a $1.72 million settlement with IMG Academy LLC, the elite Bradenton, Florida-based boarding school and sports training institution. OFAC found that IMG Academy had accepted tuition, lodging, and other fees from two parents who were on a sanctions list for providing financial support to a Mexican drug trafficking organization and its principal leader. This outcome may well have been avoided through basic sanctions screening.
The tuition transactions for the two student-athletes amounted to nearly 90 violations of counter-narcotics sanctions over the span of four years. Critically, OFAC noted that the names of the parents, which IMG invoiced and communicated with directly, matched entries on the Specially Designated National (“SDN”) list, and that “minimal due diligence at any point throughout this process would have revealed that these customers were sanctioned.” OFAC’s press release noted mitigating factors, including that IMG cooperated with the investigation and took immediate remedial steps after discovering the violations, such as hiring a chief legal officer to conduct a lookback and implementing a risk-based sanctions program.
This case carries a broader lesson – that sanctions exposure extends beyond traditional financial and trade sectors. OFAC emphasized that academic institutions with international students, third-party payors, or foreign relationships must implement effective screening, risk assessment, and compliance controls to prevent sanctioned parties from accessing US commerce. As OFAC’s enforcement release made clear, transnational criminal organizations participate in the ordinary economy – sending children to school, purchasing real estate, and investing in businesses – meaning institutions that do not view themselves as “sanctions relevant” may still find themselves in direct contact with sanctioned individuals through direct commercial activity.
The situation with IMG Academy serves as a stark reminder that OFAC obligations apply to all US persons and entities regardless of industry, and for non-financial institutions operating in an increasingly globalized market, the message is clear: sanctions compliance is not optional, and the cost of neglecting it can be severe.
This case highlights the pervasiveness of sanctions risk across a wide variety of sectors and institutions. Even for entities operating largely domestically, the presence of international touchpoints creates opportunities for impermissible dealings with sanctioned actors, inadvertently or otherwise.
https://ofac.treasury.gov/media/935006/download?=inline
