International Recruitment and Compliance with OFAC Sanctions
Effective Date: October 4, 2023
Last Updated: November 14, 2023

1. Purpose
The purpose of this policy is to ensure that our recruitment team maintains compliance with international laws and regulations, specifically those related to the Office of Foreign Assets Control (OFAC) sanctions, while recruiting international students. This policy also serves to manage financial risk associated with student refunds.

2. Scope
This policy applies to all members of the recruitment team involved in the recruitment of international students.

3. Policy Statement
Whenever the recruitment team expands its recruitment efforts to a new country, a standard procedure will be followed to confirm the country's status in relation to OFAC sanctions and prior experiences related to student refunds.

Further, the recruitment team will, on an annual basis, submit the complete list of countries from which we are actively recruiting to legal counsel. Annual submission and subsequent checks by legal for OFAC sanctions will remediate potential contravention of compliance.

3.1 OFAC Sanctions Compliance
Before initiating recruitment activities in a new country, the recruitment team must consult with the legal department. The designated contact is New York Institute of Technology’s General Counsel, who will be responsible for confirming whether or not there are active OFAC sanctions against the prospective country. Recruiting activities in a new country shall not commence until clearance is obtained from the legal department.

3.2 Student Refund Experiences
In addition to the OFAC sanctions check, the recruitment team shall review past experiences with issuing refunds to students from the prospective country. For countries where significant problems have been encountered in refunding students, recruitment activities shall not be expanded.

3.3 Financial Banking Systems
The recruitment team must be aware that financial banking systems are closely aligned with OFAC sanctions. Therefore, it is essential to liaise with the finance department to understand the possible implications of recruiting from a particular country before proceeding.

4. Compliance
Failure to comply with this policy may result in disciplinary action, up to and including termination.

5. Policy Review
This policy will be reviewed on an annual basis to ensure its relevance and effectiveness.