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| Section | Weight | Objectives |
|---|
| Specialized Topics and Emerging Issues | 10% | - Sanctions evasion techniques
- 1. Secondary sanctions awareness
- 2. Shell company detection
- 3. Trade-based money laundering
- Crypto/digital asset sanctions
- 1. Virtual currency service providers
- 2. DeFi and blockchain considerations
|
| Remediation and Reporting | 15% | - Regulatory reporting
- 1. Licensing and exceptions
- 2. Suspicious Activity Reports (SARs)
- 3. Blocking/rejecting transactions
- Sanctions violations handling
- 1. OFAC Voluntary Self-Disclosure
- 2. Self-reporting obligations
- 3. Civil and criminal penalties
|
| Risk Assessment and Compliance Program | 20% | - Sanctions risk assessment methodology
- 1. Risk identification
- 2. Risk mitigation strategies
- 3. Risk monitoring and reporting
- Compliance program components
- 1. Training and awareness
- 2. Policies and procedures
- 3. Governance and oversight
|
| Screening and Monitoring | 25% | - Technology and automation
- 1. AI/ML applications in screening
- 2. System limitations and tuning
- 3. Sanctions screening technology
- Ongoing monitoring
- 1. Counterparty risk assessment
- 2. Real-time transaction monitoring
- 3. Adverse media screening
- Transaction screening
- 1. False positive management
- 2. Name screening methodologies
- 3. Enhanced due diligence
|
| Sanctions Environment and Framework | 15% | - Types of sanctions (comprehensive, sectoral, targeted)
- 1. Travel sanctions
- 2. Financial sanctions
- 3. Trade sanctions
- Overview of sanctions regimes (OFAC, EU, UN, UK)
- 1. Economic sanctions fundamentals
- 2. Sanctions objectives and policy considerations
- 3. Legal authorities and enforcement agencies
|
| Investigation and Escalation | 15% | - Sanctions alerts investigation
- 1. Alert triage and prioritization
- 2. Evidence gathering and documentation
- 3. Decision-making frameworks
- Escalation procedures
- 1. Senior management notification
- 2. Internal escalation pathways
- 3. Legal and compliance consultation
|
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ACAMS Certified Global Sanctions Specialist Sample Questions (Q64-Q69):
NEW QUESTION # 64
Which should be considered when selecting the appropriate watch lists to screen the customer base?
- A. Length of customer relationship
- B. Cash withdrawal patterns
- C. Dollar amount of customer deposits and transactions
- D. Geographic location of customers, products, and services
Answer: D
Explanation:
Selecting watch lists for sanctions screening requires understanding geographic exposure, including customer locations, jurisdictions in which products/services are offered, and locations of trading partners. Sanctions programs vary by region (e.g., OFAC, EU, UN, UK), so geographic impact is essential.
Transaction size, withdrawal patterns, and relationship length are AML considerations but are not primary factors for selecting sanctions watch lists.
Reference:
Risk-based approach to sanctions list selection.
Consideration of geographic exposure to sanctioned jurisdictions.
NEW QUESTION # 65
North Korea's campaign to become a nuclear power first became apparent in March 1993, when it announced that it was withdrawing from a treaty.
Which of the following treaty is this?
- A. Ballistic Missile Launch Notification Agreement
- B. Strategic Arms Limitation Treaty I (Interim Agreement)
- C. Nuclear Non-Proliferation Treaty (NPT)
- D. Intermediate-Range Nuclear Forces Treaty - INF
- E. Treaty on the Prohibition of Nuclear Weapons
Answer: C
NEW QUESTION # 66
Fuzzy logic uses several common algorithms, including:
- A. inequalities lists.
- B. big data.
- C. whitelists.
- D. phonetics.
Answer: D
Explanation:
Sanctions and Compliance Domains explain that fuzzy logic screening includes phonetic algorithms (e.g., Soundex, Metaphone) to identify variations in the spelling or pronunciation of names. This allows a screening tool to detect near matches and transliteration differences that would not match under exact-match logic.
Inequality lists, big data, and whitelists are not fuzzy matching algorithms. Whitelists are used for reducing false positives, not matching logic.
Reference:
Use of phonetic-based algorithms in fuzzy matching.
Screening methodologies for variant spellings and transliterations.
NEW QUESTION # 67
Which of the following are UK government departments and agencies involved in sanctions:
- A. Foreign & Commonwealth Office
- B. HM Revenue & Customs (HMRC)
- C. HM Treasury
- D. Department for International Trade
Answer: A,B,C,D
NEW QUESTION # 68
A wire transfer alerts for a potential match in a region known for transshipment bordering a sanctioned jurisdiction. The payment field information does not match the transport document or invoice list. The customer refuses to provide any explanatory information. Which is the most appropriate next step?
- A. Provide the counterparty bank with an executed mutual legal assistance treaty to gather the requested explanatory information.
- B. Convene a compliance committee to formally reprimand the customer for refusing to cooperate with an ongoing investigation in an effort to obtain the explanatory information.
- C. Reject the transaction, noting the discrepancies contained in the description of goods on the transport document, the invoice, and the payment order.
- D. Request that law enforcement serve a subpoena to the customer requiring the production of the requested explanatory information.
Answer: C
Explanation:
Sanctions and Compliance Domains provide that a financial institution must not execute a transaction when significant unresolved discrepancies exist, especially in high-risk transshipment regions. When:
* documentation does not match payment details, and
* the customer refuses to provide required information,
the institution cannot proceed. Without clarity, the transaction may involve diversion, routed shipments, or indirect dealings with sanctioned entities.
Rejection is appropriate because blocking only applies when a confirmed sanctions match exists. Reprimanding customers, forcing subpoenas, or engaging mutual legal assistance procedures are not required or appropriate steps in sanctions transaction handling.
Reference from Sanctions and Compliance Domains:
Requirements to reject a transaction when discrepancies cannot be resolved.
Need for customer cooperation in sanctions investigations.
Standards for handling high-risk transshipment-related alerts.
NEW QUESTION # 69
......
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