The U.S. Department of the Treasury's Office of Foreign Assets Control recently took a somewhat novel enforcement action against a Florida-based children's sports education academy relating to the enrollment — unbeknownst to the academy — of the children of drug cartel members.
This action highlighted the increased enforcement risk of cartel-linked transactions and the breadth of the agency's expectations that even purely domestic companies screen all available information against relevant U.S. sanctions lists.
On Feb. 12, OFAC announced a $1.72 million settlement with IMG Academy LLC, a well-known Florida sports training and boarding school, for apparent violations of the Foreign Narcotics Kingpin Sanctions Regulations, one of several U.S. sanctions regimes that target individuals and entities linked to foreign drug cartels.
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