OFAC Enforcement Action Against IMG Academy, LLC: Implications for Schools, Universities, and Other Academic Institutions

Published
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2

Why it matters

Core Event: On February 12, 2026, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced a $1.72 million settlement with IMG Academy, LLC, a Bradenton, Florida-based school and athletic training facility, for violations of counternarcotics sanctions.[1][6]

What Happened: Between 2019 and 2025, IMG Academy entered into yearly tuition enrollment agreements and processed payments from two individuals designated as Specially Designated Nationals (SDNs) under the Foreign Narcotics Kingpin Designation Act for their ties to a sanctioned Mexican drug cartel.[1][6] These transactions resulted in 89 apparent violations of the Foreign Narcotics Kingpin Sanctions Regulations. IMG Academy failed to conduct required sanctions screening checks despite having full name details that matched OFAC's SDN List, allowing sanctioned individuals access to U.S. academic and athletic training services.[1]

Key Actors: IMG Academy; the U.S. Department of the Treasury's OFAC; and two sanctioned individuals with ties to a Mexican-based drug trafficking organization.[1][6]

Why It's Newsworthy: The case demonstrates OFAC's enforcement expectations across all sectors, including educational institutions. While IMG Academy's violations were deemed non-egregious and the penalty was reduced due to mitigating factors—including the institution's lack of prior violations, immediate remedial action, implementation of a new sanctions compliance program following an ownership change in June 2023, and cooperation during investigation—the enforcement action serves as a cautionary reminder for schools and universities to implement effective, risk-based sanctions compliance controls.[1][2][5]

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