Trade Compliance Brief - Export Control and Sanctions Insights

OFAC Sanctions & Schools: The $1.7 Million IMG Academy Settlement Explained


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When Elite Sports Meets International Sanctions.

In this episode, we break down a shocking enforcement action from the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). IMG Academy, the world-renowned athletic training facility in Bradenton, Florida, has agreed to a $1,720,000 settlement for apparent violations of counternarcotics sanctions.


What happened? Between 2018 and 2022, IMG Academy entered into yearly tuition contracts with two individuals—referred to as SDN 1 and SDN 2—who were sanctioned for their ties to a Mexican drug cartel. Despite the individuals using their real names, which matched the OFAC SDN List, the school failed to conduct basic sanctions screening.


Inside this episode:

  • The Details: How the academy processed 89 transactions totaling over $1.7 million for the children of sanctioned "Kingpins".


  • The "Reckless Disregard": Why OFAC determined that minimal due diligence could have prevented these violations.

  • The Pivot: How a change in ownership and a new Chief Legal Officer in 2023 led to a total compliance overhaul.


  • The Warning: Why academic institutions and "domestic" businesses are now in the crosshairs of global sanctions enforcement.


Whether you are a compliance officer, a sports fan, or a business leader, this case is a massive wake-up call that "knowing your customer" is no longer optional.

Original Source: https://ofac.treasury.gov/media/935006/download?inline

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Trade Compliance Brief - Export Control and Sanctions InsightsBy Pete