The name on the invoice: the IMG Academy settlement, and why consumer-facing businesses are not exempt.
A Florida school typed two sanctioned parents’ real names onto its own contracts for years. A single lookup would have caught it.
Enforcement · 12 Feb 2026
IMG Academy settled with OFAC for $1,720,000 over 89 apparent violations of U.S. counternarcotics sanctions — not through a hidden wire or shell company, but by enrolling the children of two SDN-designated parents under their own, exactly matching names.
What happened
Between 2018 and 2022, IMG signed tuition agreements enrolling the children of two individuals sanctioned under the Kingpin Act, collecting payments largely by wire from Mexico into its U.S. account. Because the conduct was non-egregious but not voluntarily self-disclosed, the base penalty landed at the full schedule amount, $1,720,000, with no self-disclosure discount available.
"Minimal due diligence at any point" would have caught it. OFAC found reckless disregard: IMG never screened counterparties at all, despite full names matching the SDN List at application, enrollment, and signing.
What this means for you
Screening is not just a bank’s job. A U.S. business’s contracts and payments involving a blocked person or blocked property can be prohibited unless exempt or authorized. Civil sanctions liability can apply without knowledge or intent. International recruiting, foreign payors, and overseas offices are reasons to examine exposure; their existence alone does not establish a violation. And watch the money, not just the named party — screening only the student or signer misses the payor.
The distance between a compliant enterprise and this settlement was one lookup against a public list. We help businesses decide what and whom to screen and assess the controls they rely on. Contact Zimmermann Law to talk it through.
Sources: OFAC, IMG Academy, LLC enforcement release (February 12, 2026), pp. 1–4; 31 C.F.R. § 598.202, mandatory U.S. federal prohibitions within their scope. The enrollment relationship began in 2018; OFAC’s apparent-violation period was 2019–2025. Checked October 2, 2026.
This post is for general information and is not legal advice.
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