Sanctions Evasion Reference

IMG Academy: tuition paid by third parties for two designated parents

A Florida sports academy paid OFAC $1.72m in 2026 after enrolling the children of two individuals designated for cartel ties over five years, with tuition wired by non-designated third parties, mostly in Mexico.

period

2018–2026

outcome

Settlement

parties

IMG Academy, LLC

reviewed

2026-09-20

Cite this page
APA 7 
Sanctions Evasion Reference. (2026, September 20). IMG Academy: tuition paid by third parties for two designated parents. https://sanctionsevasion.org/cases/img-academy-tuition-2026/
Chicago 
Sanctions Evasion Reference. “IMG Academy: tuition paid by third parties for two designated parents.” Last reviewed September 20, 2026. https://sanctionsevasion.org/cases/img-academy-tuition-2026/.
BibTeX 
@misc{ser-cases-img-academy-tuition-2026,
  author = {{Sanctions Evasion Reference}},
  title  = {IMG Academy: tuition paid by third parties for two designated parents},
  year   = {2026},
  note   = {Last reviewed 2026-09-20},
  url    = {https://sanctionsevasion.org/cases/img-academy-tuition-2026/}
}

The date is when this page was last reviewed, not when it was first published.

Penalties imposed

AuthorityDate AmountNote
OFAC 2026-02-12 $1,720,000 89 apparent violations; non-egregious, not voluntarily self-disclosed (OFAC had already opened an investigation). Base penalty $1,720,000.

A domestic institution with no export business, caught by who paid it.

What happened

Between 2018 and 2022, according to OFAC, IMG Academy signed yearly tuition agreements with two individuals designated under the Kingpin Act for supporting a Mexican drug trafficking organisation, for the enrolment of their children. It renewed the agreements each year, five times for one and twice for the other. Each agreement made the parent unconditionally responsible for the child’s account. Annual obligations ran up to about $98,900 for one parent and $102,200 for the other.

The parents mostly paid by wire transfer from non-designated third-party individuals and entities, primarily in Mexico, into the academy’s US bank account, and by credit cards kept on file. When an account had a balance at year end, it was carried into the next year’s agreement. OFAC counted 89 dealings between 2019 and 2025: six agreements and 83 payments.

The penalty

Non-egregious. The base was the schedule amount, $1,720,000, and the settlement was the same figure. IMG Academy told OFAC as soon as it learned of the issue, but OFAC had already begun an investigation, so it did not count as a voluntary self-disclosure. OFAC’s main criticism was that the parents gave names that matched their SDN entries and that “minimal due diligence at any point” would have shown they were sanctioned. It credited a compliance programme built after a June 2023 ownership change, and cooperation.

What the record shows

  • The payer was not the person. Payments from third parties in another country are a normal business pattern and also the way a designated person can pay without appearing.
  • The name matched. This was not an ownership-layer problem: the parents used their own names.

See third-country bank accounts.

Techniques this case demonstrates

Enforcement documents and sources

  1. Enforcement release: IMG Academy, LLC Settles with OFAC for $1.7 Million. U.S. Department of the Treasury, Office of Foreign Assets Control, 2026. Enforcement release, 2026-02-12, US$1,720,000.
  2. Economic Sanctions Enforcement Guidelines, Appendix A to 31 CFR Part 501. U.S. Department of the Treasury, Office of Foreign Assets Control, 2026. Sections I (definitions), II (responses), III (general factors), V.B (penalty calculation).

All enforcement cases