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| Section | Objectives |
|---|---|
| Sanctions Governance and Risk Management | - Enterprise sanctions risk assessment - Policies, procedures, and internal controls |
| Foundations of Global Sanctions Compliance | - Key sanctions terminology and typologies - Sanctions regulatory landscape (UN, OFAC, EU, UK) |
| Sanctions Evasion and Typologies | - Red flags and investigative indicators - Common evasion techniques |
| Compliance Operations and Enforcement | - Regulatory expectations and enforcement actions - Case management and investigations |
| Screening and Monitoring Systems | - Name matching and alert management - Customer and transaction screening |
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NEW QUESTION # 83
The Office of Foreign Assets Control has focused on sanctions risks in mergers and acquisitions by undertaking which action?
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 # 84
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 # 85
A financial institution provides banking services to cryptocurrency exchanges. One of their clients is a cryptocurrency exchange that specializes in offering privacy coins and provision of a tumbler/mixer service. Which sanctions-related risk should be considered?
Answer: B
Explanation:
Sanctions and Compliance Domains emphasize that sanctions screening depends on traceable identifiers, transparent transaction histories, and clear counterparties. Privacy coins and mixers/tumblers significantly obscure blockchain transaction trails.
A tumbler or mixer intentionally blends cryptocurrency from multiple sources, making it extremely difficult to determine the origin of funds, the identities of transacting parties, or any links to sanctioned entities. This creates a high sanctions-related risk because sanctioned actors or jurisdictions may exploit these services to disguise involvement.
Privacy coins alone pose risk due to anonymity, but the mixer/tumbler function specifically disrupts sanctions screening capabilities. Financial institutions and exchanges cannot rely on upstream partners to conduct due diligence.
Reference from Sanctions and Compliance Domains:
Risks of anonymity-enhancing technologies (AETs) in sanctions compliance.
Screening limitations created by mixers/tumblers and privacy-preserving blockchain tools.
Guidance highlighting elevated sanctions risks in digital asset transactions lacking traceability.
NEW QUESTION # 86
Among the tasks delegated to committees in connection with refining their own working methods, committees have been requested or required to undertake the following duties.
Which of the following are included in this?
Answer: A,E
NEW QUESTION # 87
What is the primary purpose of Rule 11?
Answer: B,D,E
NEW QUESTION # 88
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