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ACAMS CGSS Exam Syllabus Topics:

SectionWeightObjectives
Topic 1: Sanctions Environment and Framework15%- Types of sanctions (comprehensive, sectoral, targeted)
  • 1. Financial sanctions
  • 2. Travel 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
Topic 2: Investigation and Escalation15%- Sanctions alerts investigation
  • 1. Evidence gathering and documentation
  • 2. Alert triage and prioritization
  • 3. Decision-making frameworks
- Escalation procedures
  • 1. Senior management notification
  • 2. Legal and compliance consultation
  • 3. Internal escalation pathways
Topic 3: Risk Assessment and Compliance Program20%- Compliance program components
  • 1. Training and awareness
  • 2. Governance and oversight
  • 3. Policies and procedures
- Sanctions risk assessment methodology
  • 1. Risk mitigation strategies
  • 2. Risk identification
  • 3. Risk monitoring and reporting
Topic 4: Specialized Topics and Emerging Issues10%- Crypto/digital asset sanctions
  • 1. DeFi and blockchain considerations
  • 2. Virtual currency service providers
- Sanctions evasion techniques
  • 1. Shell company detection
  • 2. Trade-based money laundering
  • 3. Secondary sanctions awareness
Topic 5: Remediation and Reporting15%- Sanctions violations handling
  • 1. OFAC Voluntary Self-Disclosure
  • 2. Self-reporting obligations
  • 3. Civil and criminal penalties
- Regulatory reporting
  • 1. Suspicious Activity Reports (SARs)
  • 2. Blocking/rejecting transactions
  • 3. Licensing and exceptions
Topic 6: Screening and Monitoring25%- Ongoing monitoring
  • 1. Real-time transaction monitoring
  • 2. Adverse media screening
  • 3. Counterparty risk assessment
- Transaction screening
  • 1. Enhanced due diligence
  • 2. False positive management
  • 3. Name screening methodologies
- Technology and automation
  • 1. AI/ML applications in screening
  • 2. Sanctions screening technology
  • 3. System limitations and tuning

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ACAMS Certified Global Sanctions Specialist Sample Questions (Q48-Q53):

NEW QUESTION # 48
ABC Industries is a legal entity owned by Entity X (30%), Entity Y (25%), and Entity Z (45%). Entity X is a Specially Designated National (SDN) under OFAC sanctions, and Entity Y is owned (80%) by an OFAC SDN. Is ABC Industries a blocked entity under OFAC sanctions?

Answer: D

Explanation:
OFAC's 50 Percent Rule requires aggregation of ownership by SDNs and entities owned 50% or more by SDNs.
Ownership breakdown:
* Entity X (SDN) → 30%
* Entity Y (owned 80% by an SDN) → treated as an SDN → contributes 25%
* Total SDN-derived ownership = 30% + 25% = 55%
Since aggregate SDN ownership exceeds 50%, ABC Industries is automatically considered a blocked entity, even though Entity Z is not sanctioned.
Options B and C are incorrect because explicit listing is not required-ownership triggers blocking. Option A is incorrect because one SDN at 30% alone is insufficient, but combined ownership is.
Reference:
OFAC 50 Percent Rule (aggregation principle).
Treatment of entities majority-owned by SDNs as SDNs for ownership calculations.


NEW QUESTION # 49
In which way do notification and tipping-off differ?

Answer: D

Explanation:
Sanctions and Compliance Domains explain:
* Tipping-off is prohibited, as it may alert a customer that they are under investigation, impairing regulatory or law-enforcement action. Institutions must implement controls to prevent it.
* Notification, however, refers to permitted communication - such as informing a customer that their funds were frozen - when required or allowed by law (e.g., EU asset-freeze requirements), without revealing investigative details.
Tipping-off and notification serve entirely different purposes. Regulatory frameworks explicitly warn entities against tipping-off but do allow certain forms of notification that comply with legal obligations.
Reference:
Regulatory prohibition on tipping-off.
Permitted customer notifications regarding asset freezes or legal procedures.


NEW QUESTION # 50
Which control mechanism is used to increase transparency and ensure quality of reviews and subsequent decisions?

Answer: D

Explanation:
A four-eye check is a standard internal control requiring two independent reviewers to validate decisions, ensuring accuracy, transparency, and reducing the risk of error or inappropriate clearance of alerts.
Sanctions and Compliance Domains identify this as a critical component of the alert-handling process, enabling oversight and minimizing compliance failures.
Fuzzy matching is a screening technique, not a control mechanism. Batch screening and threshold calibration relate to system functionality, not independent quality assurance.
Reference:
Internal control expectations in sanctions compliance programs.
Dual-review ("four-eye") mechanism for alert quality assurance.


NEW QUESTION # 51
Asset freezing legislation generally permits a person to make the following payments into a frozen account without the need for a licence from OFSI, so long as those funds are frozen after being paid in which of the following?

Answer: A


NEW QUESTION # 52
Under what objective does the Security Council has imposed sanctions to facilitate the return of refugees and displaced persons in the Former Republic of Yugoslavia (FRY)?

Answer: A


NEW QUESTION # 53
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