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OFAC RESOURCES

MISBO convened a CFO Roundtable on 10/15/2026 to review and discuss the Office of Foreign Assets Control (OFAC) and how schools are handling compliance. 
What Is OFAC, and Why Does It Matter?
Overview Of OFAC Guidance On An Effective Sanctions Compliance Framework And Applicability Beyond The United States

The Office of Foreign Assets Control (OFAC), part of the U.S. Department of the Treasury, administers and enforces economic and trade sanctions against designated countries, individuals, and organizations. These sanctions are intended to advance U.S. foreign policy and national security objectives by restricting financial transactions and other dealings with sanctioned parties. Although OFAC regulations have existed for decades, recent enforcement actions involving independent schools have brought renewed attention to the issue. Schools may encounter OFAC risks through tuition payments, application fees, donations, vendor relationships, international programs, and other financial transactions.

OFAC maintains a list of Specially Designated Nationals (SDNs), identifying individuals and organizations subject to sanctions. Schools must also be aware of the 50% Rule, under which an entity may be considered sanctioned if one or more sanctioned parties collectively own 50% or more of it, even when the entity itself does not appear on the sanctions list.

Importantly, OFAC operates under a strict liability standard. A school can violate sanctions regulations without knowing that a transaction was prohibited. The 2026 NAIS legal presentation identified potential civil penalties of $377,700 per violation or twice the transaction amount. Actual penalties depend on the circumstances, including whether the school maintained a reasonable compliance program and took appropriate corrective action.

The good news is that OFAC recognizes that compliance programs should be proportionate to an organization's risk. A small day school with limited international transactions does not necessarily need the same screening infrastructure as a large boarding school with extensive international enrollment. The objective is a reasonable, documented, risk-based approach.

RESOURCES
 OFAC Sites