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ACAMS CGSS Exam Syllabus Topics:

Section	Objectives
Foundations of Global Sanctions Compliance	- Sanctions regulatory landscape (UN, OFAC, EU, UK) - Key sanctions terminology and typologies
Sanctions Governance and Risk Management	- Policies, procedures, and internal controls - Enterprise sanctions risk assessment
Screening and Monitoring Systems	- Name matching and alert management - Customer and transaction screening
Sanctions Evasion and Typologies	- Common evasion techniques - Red flags and investigative indicators
Compliance Operations and Enforcement	- Regulatory expectations and enforcement actions - Case management and investigations

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ACAMS Certified Global Sanctions Specialist Sample Questions (Q22-Q27):

NEW QUESTION # 22
A bank is processing a trade finance transaction and has a legal obligation to complete the transaction. After completing its sanctions review, the bank determines there are multiple red flags indicative of counterfeiting. Which are the appropriate next steps for handling the transaction?

A. Process the transaction and refer the transaction for further investigation by the bank's financial intelligence unit.
B. Reject the transaction and file a report on the transaction with the appropriate regulator.
C. Block the transaction, place the funds in an interest-bearing account, and file a report on the transaction.
D. File a suspicious activity report and notify the customer of the red flags identified during the review.

Answer: B

Explanation:
Sanctions and Compliance Domains specify that when a transaction shows significant sanctions or illicit-trade red flags, a bank must avoid executing the transaction if it risks breaching sanctions restrictions. If the bank identifies discrepancies, counterfeiting indicators, or potential sanctions violations, the transaction must be rejected unless a blocking requirement applies.
Blocking applies only when a sanctioned party or property interest is identified. In this scenario, because there are red flags but no confirmed designated person, the appropriate action is to reject the transaction and file the relevant report with the competent authority.
Banks should not process the transaction and investigate later, nor should they disclose red-flag details to customers. Reporting requirements prohibit tipping-off in such regulatory contexts.
Reference from Sanctions and Compliance Domains:
Guidance on rejection versus blocking in trade finance risks.
Reporting obligations when red flags indicate possible sanctions exposure.
Prohibition on providing details of internal investigations to customers.

NEW QUESTION # 23
If an Athenian citizen was unjustly murdered in another state and that state refused to punish the murderer what was authorized under Athenian law for the victims' relatives?

A. Holding three citizens of that state until restitution is completed
B. Seizing ten nationals of that state
C. Seizing three nationals of that state
D. Holding three citizens of that state until the assassin surrenders
E. Use military force to attack that State

Answer: A,C,D

NEW QUESTION # 24
A bank has a zero-tolerance policy for conducting activity with sanctioned entities or countries. The bank is asked to act as an intermediary to process a remittance. An analyst blocks the remittance because its destination is a sanctioned country. Which is the appropriate step for the analyst to take?

A. Process the wire and file a suspicious activity report to the regulator.
B. Escalate the wire for consideration and processing.
C. Reject and return the remittance and notify the sending bank of the return for compliance reasons.
D. Process the wire because it falls under a license/exemption to sanctions for the provision.

Answer: C

Explanation:
When a bank has a zero-tolerance stance regarding sanctioned jurisdictions and no applicable license or exemption exists, the appropriate response is to reject and return the remittance, informing the sending bank that the transaction cannot be processed for sanctions compliance reasons.
Escalation for consideration is inconsistent with a zero-tolerance policy. Filing a SAR does not authorize processing a prohibited payment. Processing on the assumption of a license without one presents regulatory violations.
Reference:
Requirement to reject prohibited transactions absent authorization.
Policy alignment with sanctions prohibitions and geographic restrictions.

NEW QUESTION # 25
Which has an obligation to accept and carry out UN Security Council Resolutions?

A. All members of the UN
B. Only members of the Security Council
C. Only countries that are targets of the resolution
D. Only permanent members of the Security Council

Answer: A

Explanation:
Under the UN Charter, all United Nations member states are obligated to accept and carry out decisions of the UN Security Council. Sanctions and Compliance Domains emphasize that UN Security Council Resolutions issued under Chapter VII are binding on all UN members, not just Security Council members or targeted states.
Only member states have this obligation. Permanent membership or targeted status does not change the scope of obligation.
Reference from Sanctions and Compliance Domains:
UN Charter obligations for all Member States to implement Security Council Resolutions.
Binding nature of Chapter VII resolutions across all UN members.

NEW QUESTION # 26
A non-governmental organization (NGO) is actively searching for international supporting projects, which could involve the use of designated banks. The NGO:

A. may continue the search, as NGOs are always exempt from sanctions for humanitarian activity.
B. may continue the search, however, NGOs can be indirectly impacted by sanctions.
C. may continue the search so long as it complies with the restrictions from its home country's jurisdiction.
D. should stop the search, as the use of designated banks is prohibited for NGOs.

Answer: B

Explanation:
Sanctions and Compliance Domains state that NGOs are not exempt from sanctions laws. Even humanitarian organizations must ensure that they do not transact through designated banks, sanctioned parties, or sanctioned jurisdictions unless authorized through applicable exemptions or licenses.
Furthermore, NGOs can be indirectly affected by sanctions when engaging in international work, especially when the banking sector of a target region is designated. Therefore, they may continue operating, but must fully consider sanctions exposure, including the involvement of designated banks.
Statements that NGOs are automatically exempt are factually incorrect. Compliance depends on the sanctions program, jurisdiction, and licensing conditions.
Reference:
Sanctions applicability to NGOs and humanitarian organizations.
Indirect sanctions impact when designated banks are involved.

NEW QUESTION # 27
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