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ACAMS CGSS Exam Syllabus Topics:

Section	Weight	Objectives
Topic 1: Sanctions Evasion Techniques	17.5%	- Digital and emerging risks in evasion - Use of intermediaries, shell companies and complex structures - Trade-based money laundering and sanctions circumvention - Common evasion methods and typologies
Topic 2: Sanctions Investigations and Asset Freezing	17.5%	- Reporting obligations to authorities - Asset freezing, seizure and restriction measures - Investigation protocols and procedures - Disposition of frozen assets
Topic 3: Sanctions Screening	20%	- Matching logic, false positives and resolution - Transaction and relationship screening - Screening methodologies and tools - Sanctions lists and designated parties
Topic 4: Sanctions Due Diligence	20%	- Customer and counterparty due diligence requirements - Ongoing monitoring and record keeping - Enhanced due diligence for high-risk scenarios - Risk assessment and categorization
Topic 5: Governance and Enforcement	25%	- Regulatory bodies and authorities - International sanctions frameworks - Compliance obligations and governance structures - Enforcement mechanisms and penalties

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ACAMS Certified Global Sanctions Specialist Sample Questions (Q88-Q93):

NEW QUESTION # 88
A non-US based manufacturing company exports goods to a country comprehensively sanctioned by the US. The manufacturing company directs payments to its USD-denominated bank account at a non-US bank. Buyer and/or jurisdiction do not appear in the payment order. This is an example of:

A. sanctions evasion.
B. permissible activity.
C. black market peso exchange.
D. missing trader fraud.

Answer: A

Explanation:
Using a USD-denominated account creates a US nexus, because USD transactions must clear through the US financial system. Routing payments through USD accounts while obscuring the sanctioned jurisdiction or buyer is a known sanctions-evasion technique.
This is especially true in cases involving comprehensive sanctions (e.g., Iran, North Korea, Cuba), where attempts to hide identifying information in payment orders show intent to evade regulatory controls.
Reference:
OFAC guidance on US nexus in USD transactions.
Evasion indicators including concealment of sanctioned jurisdictions or parties.

NEW QUESTION # 89
The 1993 rule excuses only represented parties from some of its requirements. Therefore, like the previous rule, it does apply fully to pro se litigants. In the case of the United States v. Barker, 182 F.R.D. 661, 662-64 (S.D. Ga. 1998) what is the action of the court towards the pro se litigant?

A. Enjoining pro se litigant from filing additional lawsuits in future unless certain conditions met.
B. Awarding sanctions against pro se litigant pursuant to Bankruptcy Rule.
C. Suspending sanctions order for 30 days, giving pro se plaintiff the opportunity to explain.
D. Monetarily sanctioning a represented party for violation of Rule 11(b)(2).
E. Imposing monetary sanctions towards pro se litigant.

Answer: A,E

NEW QUESTION # 90
Which of the following best describes the Supreme Court's rule with respect to overruling criminal penalties imposed for misrepresentations in court filings?

A. The relevant documents referred to in, and exhibited with, the said affidavit which must include true copies of the judgments with which the application is concerned that is, both of the court below and the court of the first instance verified by affidavit must be provided
B. The respondent may, if he so desires, file in reply to a counter affidavit not later than two days before the hearing date
C. False statements in judicial proceedings are not punishable under 18 U.S.C. § 1001, the federal false-statements statute
D. An order shall apply to the Court from the court below in civil cases, and to matters related thereto

Answer: C

NEW QUESTION # 91
A manager of a correspondent bank relationship discovers that a respondent bank has expanded its business operations. Which factors are relevant to identifying and assessing sanctions risk exposure? (Select Three.)

A. The location of the respondent bank's operations
B. The respondent bank's products and services
C. The licensing authorities of the respondent bank and its branches
D. The representatives of the respondent's bank
E. The business activity of the respondent bank's customers
F. The registration number of the respondent's bank

Answer: A,B,C

Explanation:
Sanctions and Compliance Domains specify that correspondent banking relationships require a comprehensive assessment of the respondent bank's sanctions risk exposure. Relevant factors include:
* Licensing authorities - Banks licensed in jurisdictions with weak sanctions controls, inadequate supervision, or misaligned regulatory frameworks pose heightened risk. Regulatory oversight directly influences sanctions compliance effectiveness.
* Location of operations - Geographies influence exposure to sanctioned countries, transshipment risks, proliferation financing threats, and proximity to high-risk jurisdictions. Geographic expansion may introduce new sanctions obligations and monitoring requirements.
* Products and services offered - Certain products (e.g., trade finance, cross-border payments, payable-through accounts) carry inherently higher sanctions risk. As respondent banks expand their service offerings, the correspondent institution must reassess associated risks.
The registration number is not relevant to sanctions exposure. Bank representatives may factor into KYC but are not core sanctions-risk elements. The respondent's customers' business activity is considered indirectly through the respondent bank's controls and risk profile, but primary assessment focuses on the bank's licensing, geography, and product set.
Reference:
Sanctions risk assessment expectations for correspondent banking relationships.
Consideration of licensing, geographic exposure, and product/service risk.
Regulatory requirements for understanding respondent bank activities and oversight.

NEW QUESTION # 92
The attorney should confer directly with the client to verify the accuracy of the claims. In McGhee v. Sanilac County, 934 F.2d 89, 93 (6th Cir. 1991), under what circumstances did the appellate court reversed decision not to sanction?

A. Where the attorney could not have been reasonably obtained by local counsel
B. Where attorney certified that he informed both husband and wife as to alternatives under the bankruptcy code and he had in fact only informed the wife.
C. Upon attorney who discussed general content of amended complaint with clients prior to filing but did not inform clients of exact wording of new allegations, which proved to be false.
D. Where attorney neglected to ask the client whether allegedly defamatory statements were actually false
E. Where forwarding attorney had not advised them of an earlier adverse ruling.

Answer: D

NEW QUESTION # 93
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