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ACAMS CGSS Exam Syllabus Topics:

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

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ACAMS Certified Global Sanctions Specialist Sample Questions (Q24-Q29):

NEW QUESTION # 24
For which of the following an OFSI license is required?

A. Payment for groceries.
B. To set off a debt.
C. To issue or allow the redemption of vouchers, coupons, or reward points.
D. Goods of low value and purely for personal consumption, such as food, water, or electricity or gas for domestic use.
E. To write off a debt.

Answer: B,C,E

NEW QUESTION # 25
Under the 1993 Rule 11, as under the prior rule, parties have the continued obligation to mitigate damages resulting from a Rule 11 violation.
Which of the following may relate to this situation?

A. Thomas v. Capital Sec. Serv., 836 F.2d 866, 879 (5th Cir. 1988) - "A party seeking Rule 11 costs and attorneys' fees has a duty to mitigate those expenses by correlating his response, in hours and funds expended, to the merit of the claims."
B. Hamil v. Mobex Managed Servs. Co., 208 F.R.D. 247, 250 (N.D. Ind. 2002) - "[A] party must request Rule 11 sanctions as soon as practicable after discovery of a Rule 11 violation."
C. Pollution Control Indus. of Am. v. Van Gundy, 21 F.3d 152, 156 (7th Cir. 1994) - Vacating sanctions against plaintiffs and remanding for appropriate award where defendants had a duty to mitigate costs but failed to raise the dispositive issue in a prompt and cost-efficient manner.
D. United Food & Commercial Workers Union Local No. 115 v. Armour & Co., 106 F.R.D. 345, 349-50 (N.D. Cal. 1985) - Court reduced fee request because counsel over-litigated the case.
E. Danvers v. Danvers, 959 F.2d 601, 605 (6th Cir. 1992) - Remanded for reduction of sanctions award where defendant's attorney spent several hours researching and preparing for discovery on meritless action rather than moving to dismiss.

Answer: B

NEW QUESTION # 26
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. The petitioner sought the purely civil effect of preventing his deportation from happening.
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. Petitioner was pursuing traditional habeas relief

Answer: B,D

NEW QUESTION # 27
By viewing sanctions as aggregate consequences of competing interest group pressures, the public-choice approach demonstrates that economic benefit per se is not a central factor in deciding the essence of the sanctions packages enforced by the sanctioning countries.
As far as the target country is concerned, the sanctions in part affect the political balance by:

A. Sending messages or positive news to different classes of people within the target nation.
B. Sending messages or positive news to different classes of people in the supporting nation.
C. Sending messages or warnings to different classes of people within the target nation.
D. Receiving messages or positive news to different classes of people within a target nation.
E. Receiving warnings or threats to particular classes of people within the target nation.

Answer: C

NEW QUESTION # 28
"Al-Falah Company", registered in Dubai, wants to open an account at a financial institution. Through due diligence, the compliance team finds out that "El-Fallah Investments", based in Iraq, is under UN sanctions for facilitating terrorism financing. The listed Chief Executive Officer (CEO) of the sanctioned entity is not the same as the CEO of the potential client. How should the compliance team proceed?

A. The potential client should not be onboarded and the regulator must be notified.
B. This is a near match, thus the client should only be onboarded depending on the financial institution's risk appetite.
C. There are enough similarities to pursue further investigation before a decision can be made.
D. There is insufficient reason to escalate the case for further investigation and the client can be onboarded.

Answer: C

Explanation:
Sanctions and Compliance Domains state that when entities share similar names, regions, or other characteristics with a sanctioned party - even when executive leadership differs - the institution must perform enhanced due diligence to rule out affiliation, ownership, or control links.
The similarity in names ("Al-Falah" vs. "El-Fallah"), geographic proximity, and the involvement of UN-sanctioned terrorism-related activity require deeper investigation. Compliance teams must confirm corporate records, ownership structure, purpose, and possible indirect connections before making a determination.
Automatic rejection is premature without evidence. Onboarding without further investigation is inappropriate.
Reference:
Name similarity and geographic proximity as sanctions escalation triggers.
Requirements for enhanced due diligence when possible indirect links exist.

NEW QUESTION # 29
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