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ACAMS CGSS Exam Syllabus Topics:

Section	Weight	Objectives
Remediation and Reporting	15%	- Regulatory reporting 1. Blocking/rejecting transactions 2. Licensing and exceptions 3. Suspicious Activity Reports (SARs) - Sanctions violations handling 1. Self-reporting obligations 2. Civil and criminal penalties 3. OFAC Voluntary Self-Disclosure
Sanctions Environment and Framework	15%	- Types of sanctions (comprehensive, sectoral, targeted) 1. Travel sanctions 2. Trade sanctions 3. Financial sanctions - Overview of sanctions regimes (OFAC, EU, UN, UK) 1. Sanctions objectives and policy considerations 2. Economic sanctions fundamentals 3. Legal authorities and enforcement agencies
Investigation and Escalation	15%	- Sanctions alerts investigation 1. Evidence gathering and documentation 2. Decision-making frameworks 3. Alert triage and prioritization - Escalation procedures 1. Senior management notification 2. Legal and compliance consultation 3. Internal escalation pathways
Screening and Monitoring	25%	- Ongoing monitoring 1. Adverse media screening 2. Counterparty risk assessment 3. Real-time transaction monitoring - Transaction screening 1. Name screening methodologies 2. False positive management 3. Enhanced due diligence - Technology and automation 1. AI/ML applications in screening 2. Sanctions screening technology 3. System limitations and tuning
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. DeFi and blockchain considerations 2. Virtual currency service providers
Risk Assessment and Compliance Program	20%	- Sanctions risk assessment methodology 1. Risk mitigation strategies 2. Risk monitoring and reporting 3. Risk identification - Compliance program components 1. Governance and oversight 2. Training and awareness 3. Policies and procedures

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ACAMS Certified Global Sanctions Specialist Sample Questions (Q70-Q75):

NEW QUESTION # 70
A sanctions analyst receives a letter of credit (LC) request that shows the carrier is a possible match under the Specially Designated Nationals and Blocked Persons List. Which action should the analyst take?

A. Immediately reject the payment and close the customer account.
B. Immediately reject the LC and list the company name internally.
C. File a report to the regulator and reject the LC.
D. Use secondary sources to obtain more identifiers and information.

Answer: D

Explanation:
Sanctions and Compliance Domains state that when a potential sanctions match occurs, the first step is to conduct a proper investigation to determine whether the alert is a true match or false positive. This includes obtaining additional identifiers such as addresses, IMO numbers, registration numbers, or corporate details.
Immediate rejection or reporting is only appropriate after confirming a true match. Premature rejection without verification violates due diligence expectations. Closing the customer account is not justified without confirmed sanctions involvement.
Reference:
Investigation procedures for potential sanctions matches.
Requirements to gather additional identifiers before determining match status.

NEW QUESTION # 71
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. Geographic location of customers, products, and services
D. Dollar amount of customer deposits and transactions

Answer: C

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 # 72
Why the First Circuit has imposed a Rule 11 sanction upon counsel in a "frivolous" habeas corpus proceeding?

A. To district court for consideration of whether sanctions were appropriate
B. Petitioner was pursuing traditional habeas relief
C. Because sanctions are appropriate 'only in the most egregious circumstances and where the court has specifically found that penalties are necessary, that other remedies are insufficient and that its application of Rule 11 is tailored to the wrong found
D. Petitioner was not pursuing traditional habeas relief
E. The petitioner sought the purely civil effect of preventing his deportation from happening.

Answer: D,E

NEW QUESTION # 73
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. Review if the beneficiary party's country applies sanctions on the neighboring country; if not, the payment can be approved.
B. Reject the payment and request the remitter to remove any reference to sanctioned country port in the payment message.
C. Approve the payment since the parties in the payment are not based in a sanctioned country or are not subject to sanctions.
D. Request the underlying documents and shipment details to ensure there is no involvement of a sanctioned party, port, or sanctioned country goods.

Answer: D

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 # 74
Who must comply with Office of Foreign Assets Control regulations in all circumstances?

A. Foreign financial institutions without a US nexus
B. US persons, including all US citizens and permanent resident aliens
C. Foreign persons in possession of US-origin goods
D. Foreign companies with US subsidiaries

Answer: B

Explanation:
OFAC regulations apply broadly to US persons, which include US citizens, permanent residents, entities organized under US law, and individuals located in the United States. These obligations apply regardless of where the US person is physically located.
Foreign companies, foreign financial institutions, or foreign persons are only obligated under OFAC regulations when a US nexus exists (e.g., US origin goods, US dollars, US-based transactions). US persons, however, must always comply.
Reference:
Definition of "US persons" under OFAC regulations.
Global applicability of OFAC rules to US citizens and permanent residents.

NEW QUESTION # 75
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