Enforcement Release: February 12, 2026
IMG Academy, LLC Settles with OFAC for $1.7 Million Related to Apparent Violations of Counternarcotics Sanctions
IMG Academy, a school and athletic training facility headquartered in Bradenton, Florida, has agreed to pay $1,720,000 to settle its potential civil liability for apparent violations of OFAC counternarcotics sanctions. Over five consecutive years, IMG Academy repeatedly transacted with two individuals whom OFAC sanctioned based upon their ties to a sanctioned Mexican-based drug cartel.
The settlement amount reflects OFAC’s determination that IMG Academy’s apparent violations were non-egregious and not voluntarily self-disclosed. It also reflects IMG Academy’s substantial cooperation with OFAC and remedial measures taken since IMG Academy became aware of the apparent violations. More broadly, this enforcement action highlights the importance of institutions across a wide variety of sectors, including academic institutions, implementing effective, risk-based controls to avoid sanctions violations and prevent illicit actors...
1) This is the first OFAC civil enforcement action against a college or university since Augsburg College (2006). From a legal basis standpoint, there is nothing groundbreaking about an enforcement action arising from contracts with SDNs, who would have an interest in the transaction forming the contract and all transactions engaged in pursuant to the contracts. Notably, the way OFAC arrives at violation totals of 89 and 83 is to regard the contracts with the SDNs as “blocked” agreements, and then to consider all payments pursuant to those contracts to be dealings in the blocked contracts, even though in most (if not all) cases the payments were made through third parties.
From a factual standpoint, the enforcement action is novel inasmuch as it arises from transactions for the benefit of children of blocked persons, and by an educational institution...