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ACAMS CGSS Exam Syllabus Topics:

Section	Objectives
Topic 1: Sanctions Evasion and Typologies	- Common evasion techniques - Red flags and investigative indicators
Topic 2: Compliance Operations and Enforcement	- Regulatory expectations and enforcement actions - Case management and investigations
Topic 3: Sanctions Governance and Risk Management	- Policies, procedures, and internal controls - Enterprise sanctions risk assessment
Topic 4: Screening and Monitoring Systems	- Name matching and alert management - Customer and transaction screening
Topic 5: Foundations of Global Sanctions Compliance	- Key sanctions terminology and typologies - Sanctions regulatory landscape (UN, OFAC, EU, UK)

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ACAMS Certified Global Sanctions Specialist Sample Questions (Q10-Q15):

NEW QUESTION # 10
The Office of Foreign Assets Control has focused on sanctions risks in mergers and acquisitions by undertaking which action?

A. Discouraging mergers and acquisitions in its framework for compliance commitment
B. Putting out joint guidance with the Securities and Exchange Commission that highlights the sanctions risks of mergers and acquisitions
C. Considering enforcement actions against companies that knowingly fail to do sufficient due diligence
D. Pursuing enforcement actions against companies that fail to do sufficient due diligence

Answer: D

Explanation:
Sanctions and Compliance Domains outline that OFAC has explicitly emphasized the importance of pre- and post-acquisition sanctions due diligence in mergers and acquisitions. OFAC has pursued enforcement actions against companies that failed to conduct adequate sanctions due diligence or did not integrate compliance controls after acquiring foreign subsidiaries.
OFAC's enforcement history shows cases in which companies inherited violations because they continued business through acquired entities that were already engaged in sanctioned conduct. OFAC clearly identifies failure to conduct sufficient sanctions due diligence as grounds for enforcement. It does not merely "consider" such actions, nor has it issued joint SEC guidance to warn about MandA sanctions risks. OFAC also does not discourage mergers and acquisitions; instead, it stresses compliance integration and strong due diligence.
Reference from Sanctions and Compliance Domains:
OFAC expectations for sanctions due diligence in mergers and acquisitions.
Enforcement actions taken for failure to conduct adequate pre-acquisition and post-acquisition compliance reviews.
Compliance requirements for inherited liabilities through acquired subsidiaries.

NEW QUESTION # 11
While reviewing a transaction screening alert, an analyst noted that a payment message made reference to a port in a sanctioned country. The payment was to a company based in a country neighboring the sanctioned country. Which action should the analyst take?

A. Approve the payment since the parties in the payment are not based in a sanctioned country or are not subject to sanctions.
B. Review if the beneficiary party's country applies sanctions on the neighboring country; if not, the payment can be approved.
C. Request the underlying documents and shipment details to ensure there is no involvement of a sanctioned party, port, or sanctioned country goods.
D. Reject the payment and request the remitter to remove any reference to sanctioned country port in the payment message.

Answer: C

Explanation:
Sanctions and Compliance Domains outline that references to sanctioned ports, locations, or shipping routes in payment instructions require further investigation. Even when the transaction parties are not located in a sanctioned jurisdiction, involvement of a sanctioned port or movement of prohibited goods can trigger sanctions exposure.
The correct approach is to obtain supporting documents such as shipping documents, invoices, bills of lading, and routing information to confirm whether the shipment, goods, transport path, or third parties have any sanctioned involvement. Approving or rejecting a payment without verification contradicts sanctions screening standards.
Reference from Sanctions and Compliance Domains:
Requirements to investigate references to sanctioned locations in trade or payment messages.
Guidance on obtaining underlying documents to assess sanctions exposure.
Expectations for verifying goods, ports, and shipment paths.

NEW QUESTION # 12
Which unit function has been identified as critical to managing sanctions risks?

A. Human resources
B. Third-party due diligence firms
C. Credit risk management
D. Audit and testing

Answer: D

NEW QUESTION # 13
Which exogenous events sporadically derailed the changes in general of punishing Cuba?

A. Cuban air force shooting down US aircraft
B. Competition over Florida's electoral votes in the 1992 presidential election
C. Democratic presidential nomination
D. Burglar arrest at the Democratic National Committee office
E. Capture by Iranian-backed terrorists of US hostages

Answer: A,B

NEW QUESTION # 14
When effectiveness and externalities do not encourage the use of incentives what can happen?

A. It can punish or reward particular policies
B. The relative effectiveness of incentives decreases
C. The economic incentives will be preferred over economic threats
D. The trade-off between political externalities/effectiveness can create provocative dilemmas
E. This can affect the effectiveness of the economic statecraft

Answer: D

NEW QUESTION # 15
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