Overview
- U.S. Treasury’s sanctions office said IMG will pay $1.72 million to settle 89 apparent violations tied to two individuals designated under the Foreign Narcotics Kingpin Act.
- The violations stemmed from enrollment contracts and tuition payments routed through third-party wires from Mexico and stored credit cards, which allowed sanctioned persons to access U.S. services and the financial system.
- OFAC deemed the matter non‑egregious and not voluntarily self‑disclosed, citing IMG’s failure to conduct basic sanctions screening despite having payer names matching the SDN List.
- One student’s tuition ran up to about $98,867 annually from 2018 until graduation in 2023, while another paid up to $102,235 per year during 2020–2022, according to OFAC.
- Officials credited IMG’s cooperation and remediation, noting a risk‑based sanctions program and a legal officer‑led lookback after a 2023 ownership change, and warned that schools and other nontraditional sectors face comparable sanctions risk.