February 2026 · 8-minute read
NAIS & NBOA Schools:
Your OFAC Compliance Playbook After the IMG Academy Settlement
The NAIS Thrive 2026 conference in Seattle put OFAC compliance on the agenda. Here is a practical guide for school leaders and business officers who need to act now.
Two events in February 2026 have changed the compliance landscape for independent schools and universities forever. First, OFAC settled with IMG Academy for $1.72 million — the first major sanctions enforcement action against a school. Second, the NAIS Thrive 2026 conference brought OFAC compliance to the center of every school leader's agenda.
If you attended the conference — or heard about it from colleagues — this guide translates the discussion into concrete steps your school can take this week. If you are a NBOA member or business officer, the financial compliance section is written for you.
Timeline: How We Got Here
Pre-2026
Schools assumed OFAC was a bank problem
OFAC regulations have always applied to all U.S. persons and entities. But enforcement focused on banks and trading companies. Schools had no precedent to worry about.
Early February 2026
IMG Academy settlement announced — $1.72M for 89 violations
A Florida boarding school paid $1.72 million for accepting tuition from two parents on the SDN list. OFAC cited "reckless disregard" — the names were publicly available.
February 25–27, 2026
NAIS Thrive 2026 in Seattle — OFAC becomes a conference topic
School leaders, heads of school, CFOs, and board members gather. OFAC compliance sessions draw standing-room crowds. NBOA issues guidance.
Now
Schools are searching for solutions
School administrators and business officers are evaluating screening tools. The question is no longer "if" but "how fast" schools can implement sanctions screening.
What NAIS & NBOA Are Telling Schools
Both organizations have released guidance since the IMG Academy settlement. Here is what they are recommending.
NAIS Guidance
National Association of Independent Schools
- Screen all parties involved in enrollment and tuition payment
- Establish a written OFAC compliance policy
- Designate a compliance officer or point person
- Implement ongoing monitoring, not one-time checks
- Maintain auditable records of all screening decisions
NBOA Guidance
National Business Officers Association
- Screen the full "money chain" — not just the student
- Include tuition payors, sponsors, donors, and wire originators
- Integrate screening into accounts receivable workflows
- Prepare for 10-year federal recordkeeping requirements
- Budget for compliance tooling in the 2026-27 fiscal year
Your 5-Step OFAC Compliance Playbook
Based on NAIS/NBOA guidance, OFAC enforcement patterns, and our experience screening for defense contractors. Practical steps you can start this week.
Designate a compliance point person
This does not require hiring a new role. Assign responsibility to your CFO, business officer, or admissions director. The key is accountability — someone who owns the process and can demonstrate it to auditors.
Identify who to screen
Build a roster of everyone involved in financial transactions: students, parents/guardians, tuition payors, scholarship sponsors, donors, visiting faculty, and vendors. The IMG Academy case proved that screening students alone is not enough.
Select a screening tool
Generic bank compliance tools are not designed for education workflows. Look for a platform that offers enrollment-stage screening, batch roster uploads, automated re-screening, and education-specific audit reports. SecurePoint USA is the only platform built for this use case.
Define your screening triggers
Screen at enrollment, re-enrollment, when receiving payments, when processing refunds, and when accepting donations. Set up automated re-screening whenever OFAC updates its lists (roughly every two weeks).
Document everything
OFAC enforcement decisions heavily weigh whether an institution had a compliance program. Even if a match is a false positive, documenting that you screened, reviewed, and cleared the match demonstrates due diligence. Immutable audit logs and evidence packs are your best protection.
Why “Defense-Grade” Matters for Schools
SecurePoint USA was not built in a classroom. It was built for defense contractors, aerospace manufacturers, and ITAR-regulated facilities — organizations where a compliance failure means losing a government contract or facing criminal penalties. That same screening engine, with the same immutable audit logs and evidence packs, now protects educational institutions.
Multi-list global coverage
OFAC SDN, BIS Entity List, UN, EU, UK sanctions, and more. Unlimited screenings on every plan — never ration your compliance.
Education-specific workflows
Enrollment screening, batch roster uploads, tuition payor verification, automated re-screening. Built for how schools actually work.
Audit-ready evidence packs
Every screening, match review, and clearance decision logged with timestamps. Export evidence bundles for auditors, regulators, or board reporting.
What Schools Are Searching For Right Now
Based on post-conference search trends and our conversations with school administrators, these are the questions driving research right now:
If you found this article searching for any of these terms, you are in the right place.