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ACAMS CGSS Exam Syllabus Topics:

Section	Weight	Objectives
Investigation and Escalation	15%	- Escalation procedures 1. Senior management notification 2. Legal and compliance consultation 3. Internal escalation pathways - Sanctions alerts investigation 1. Decision-making frameworks 2. Alert triage and prioritization 3. Evidence gathering and documentation
Remediation and Reporting	15%	- Regulatory reporting 1. Suspicious Activity Reports (SARs) 2. Licensing and exceptions 3. Blocking/rejecting transactions - Sanctions violations handling 1. Self-reporting obligations 2. OFAC Voluntary Self-Disclosure 3. Civil and criminal penalties
Screening and Monitoring	25%	- Transaction screening 1. Enhanced due diligence 2. Name screening methodologies 3. False positive management - Ongoing monitoring 1. Counterparty risk assessment 2. Adverse media screening 3. Real-time transaction monitoring - Technology and automation 1. AI/ML applications in screening 2. System limitations and tuning 3. Sanctions screening technology
Specialized Topics and Emerging Issues	10%	- Sanctions evasion techniques 1. Trade-based money laundering 2. Shell company detection 3. Secondary sanctions awareness - Crypto/digital asset sanctions 1. DeFi and blockchain considerations 2. Virtual currency service providers
Sanctions Environment and Framework	15%	- Types of sanctions (comprehensive, sectoral, targeted) 1. Financial sanctions 2. Travel sanctions 3. Trade sanctions - Overview of sanctions regimes (OFAC, EU, UN, UK) 1. Sanctions objectives and policy considerations 2. Legal authorities and enforcement agencies 3. Economic sanctions fundamentals
Risk Assessment and Compliance Program	20%	- Compliance program components 1. Training and awareness 2. Governance and oversight 3. Policies and procedures - Sanctions risk assessment methodology 1. Risk monitoring and reporting 2. Risk mitigation strategies 3. Risk identification

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ACAMS Certified Global Sanctions Specialist Sample Questions (Q101-Q106):

NEW QUESTION # 101
Which is a key sanctions risk posed by transshipment and intermediary points?

A. The ultimate recipient of goods and/or their jurisdiction may be unclear.
B. The submission of all relevant documentation prior to the transshipment.
C. The large cash amounts readily exchanged at ports.
D. The collection of data on exposure to intermediary points.

Answer: A

Explanation:
Transshipment and intermediary hubs present sanctions risks because they obscure the true origin, destination, and end-user of goods. High-risk jurisdictions use intermediary shipping points to bypass controls, hide diversion routes, and disguise connections to sanctioned countries or entities.
Documentation may be incomplete, manipulated, or replaced during transshipment, making the true jurisdiction unclear-the core risk.
Reference:
Sanctions evasion via transshipment and intermediary locations.
Risks relating to concealment of end-users and destinations.

NEW QUESTION # 102
Which are common misconceptions related to an effective sanctions program? (Select Two.)

A. The individual or entity is not explicitly named on a sanctions list, therefore there are no potential sanctions risk.
B. A US citizen has been working in the EU and thus, US sanctions do not apply.
C. A company must assess sanctions risks during the due diligence phase of a merger and acquisition.
D. Parties involved in import or export and related transactions could be subject to financial sanctions.
E. An individual sending a USD wire that automatically involves the US sanctions.

Answer: A,E

Explanation:
Sanctions and Compliance Domains outline several misunderstandings commonly held by businesses. One misconception is that any USD transaction automatically triggers US sanctions applicability; while USD transactions may be routed through the US financial system, sanctions analysis depends on transaction content, parties involved, and jurisdictional reach, not solely the currency.
Another misconception is assuming no sanctions risk exists if a party is not listed by name. Sanctions regimes include indirect application through ownership and control rules, sectoral sanctions, activity-based sanctions, and geographic sanctions. Entities may be sanctioned due to association, ownership, or activity even if not individually named.
Statements regarding import/export exposure and MandA due diligence are correct program requirements. US sanctions can still apply to US citizens regardless of where they reside or work.
Reference from Sanctions and Compliance Domains:
Misconceptions regarding currency and sanctions applicability.
Misunderstandings about named-party sanctions versus ownership/activity-based risks.
Clarification on US person obligations regardless of residence.

NEW QUESTION # 103
Dealing with economic resources generally means using the economic resources to obtain funds, goods, or services in the following way except?

A. Hiring them
B. Investing them
C. Trading them
D. Selling them
E. Mortgaging them

Answer: B,C

NEW QUESTION # 104
Tobacco was produced and marketed in Rhodesia under the Tobacco Marketing Act of 1936. This act stipulated that all flue-cured tobacco over 95 percent of the total crop and the most valuable type of leaf be sold exclusively by individual growers at open competitive auction in Salisbury.
What are other formations were put forward?

A. International recognition
B. Government authority responsible for overseeing the industry
C. Publicity for future benefits
D. Honor for the massive reproduction of crops

Answer: B

NEW QUESTION # 105
Which action should an institution take after freezing funds for a customer who became an EU-sanctioned subject?

A. Notify the customer about the freezing.
B. Inform the applicable authorities about the freezing.
C. Freeze accounts of the customer's family members that have accounts within the same financial institution.
D. Transfer the funds to another financial institution where the customer has another account.

Answer: B

Explanation:
EU sanctions require financial institutions to immediately freeze the funds or economic resources of designated persons and promptly report the freeze to the competent national authority. Reporting is mandatory to ensure oversight and enforcement.
Banks must not transfer frozen funds, and they must not freeze accounts of family members unless those individuals are also designated or otherwise meet ownership/control criteria. Institutions also do not notify the customer directly, as doing so may undermine regulatory requirements.
Reference:
EU asset-freeze reporting obligations to competent authorities.
Prohibitions on transferring frozen assets or applying freezes to non-designated persons.

NEW QUESTION # 106
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