What the OFAC’s Enforcement Action Against IMG Academy Means for Private Schools, Colleges and Universities
Cory Flashner and Molly Connolly co-authored a Westlaw Today article analyzing the implications of a recent Office of Foreign Assets Control (OFAC) enforcement action for educational institutions.
The article examines how OFAC’s strict liability standard can create significant exposure even without intent, emphasizing that sanctions compliance “is no longer optional” for institutions with international students, donors, and cross-border payment flows.
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