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| Section | Weight | Objectives |
|---|
| Remediation and Reporting | 15% | - Regulatory reporting
- 1. Suspicious Activity Reports (SARs)
- 2. Blocking/rejecting transactions
- 3. Licensing and exceptions
- Sanctions violations handling
- 1. Civil and criminal penalties
- 2. Self-reporting obligations
- 3. OFAC Voluntary Self-Disclosure
|
| Investigation and Escalation | 15% | - Sanctions alerts investigation
- 1. Evidence gathering and documentation
- 2. Decision-making frameworks
- 3. Alert triage and prioritization
- Escalation procedures
- 1. Senior management notification
- 2. Legal and compliance consultation
- 3. Internal escalation pathways
|
| Specialized Topics and Emerging Issues | 10% | - Sanctions evasion techniques
- 1. Shell company detection
- 2. Trade-based money laundering
- 3. Secondary sanctions awareness
- Crypto/digital asset sanctions
- 1. DeFi and blockchain considerations
- 2. Virtual currency service providers
|
| Risk Assessment and Compliance Program | 20% | - Sanctions risk assessment methodology
- 1. Risk mitigation strategies
- 2. Risk identification
- 3. Risk monitoring and reporting
- Compliance program components
- 1. Policies and procedures
- 2. Training and awareness
- 3. Governance and oversight
|
| Sanctions Environment and Framework | 15% | - Overview of sanctions regimes (OFAC, EU, UN, UK)
- 1. Economic sanctions fundamentals
- 2. Legal authorities and enforcement agencies
- 3. Sanctions objectives and policy considerations
- Types of sanctions (comprehensive, sectoral, targeted)
- 1. Financial sanctions
- 2. Trade sanctions
- 3. Travel sanctions
|
| Screening and Monitoring | 25% | - Ongoing monitoring
- 1. Adverse media screening
- 2. Real-time transaction monitoring
- 3. Counterparty risk assessment
- Technology and automation
- 1. System limitations and tuning
- 2. Sanctions screening technology
- 3. AI/ML applications in screening
- Transaction screening
- 1. False positive management
- 2. Enhanced due diligence
- 3. Name screening methodologies
|
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ACAMS Certified Global Sanctions Specialist Sample Questions (Q76-Q81):
NEW QUESTION # 76
Which are common misconceptions related to an effective sanctions program? (Select Two.)
- A. A US citizen has been working in the EU and thus, US sanctions do not apply.
- B. A company must assess sanctions risks during the due diligence phase of a merger and acquisition.
- C. An individual sending a USD wire that automatically involves the US sanctions.
- D. The individual or entity is not explicitly named on a sanctions list, therefore there are no potential sanctions risk.
- E. Parties involved in import or export and related transactions could be subject to financial sanctions.
Answer: C,D
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 # 77
Which fields of a payment message are commonly subject to sanctions screening? (Select Three.)
- A. Remitter and beneficiary
- B. Currency and notional value of the transaction
- C. Free text fields
- D. Effective day of the payment
- E. Sender's internal payment reference number
- F. Agents, intermediaries, and financial institutions
Answer: A,C,F
Explanation:
Sanctions and Compliance Domains specify that sanctions screening must include all fields that contain names, identifiers, or descriptive information that could reveal a connection to a sanctioned party or jurisdiction. This includes:
* Remitter and beneficiary fields - Core parties to the transaction must always be screened.
* Agents, intermediaries, correspondent banks, and financial institutions - These fields often contain additional parties that may be sanctioned or present sanctions exposure.
* Free text fields - These can include narrative descriptions, vessel names, ports, goods, or locations that may represent sanctions risk.
Currency, value, dates, and internal references do not contain identifiers relevant to sanctions screening and therefore are not required screening fields.
Reference:
Screening obligations across all relevant message fields containing parties or descriptive identifiers.
Inclusion of free-text and intermediary fields in standard sanctions screening scope.
NEW QUESTION # 78
If the efforts for settlement between member states failed, and even the League council report failed to reach unanimity, how can member states resolve their problem?
- A. They have reserved the right to safeguard themselves and their integrity
- B. They can take action as they see fit to uphold justice and justice
- C. They have no right to exercise their civil rights
- D. They will cease their hostilities
- E. They are bound to obey the Security Council
Answer: A,B
NEW QUESTION # 79
The Council noted that, in order to ensure that Iraq did not increase its capacity to re-arm, states were required to continue to prevent the sale, supply, or provision to Iraq.
Which of the following items is NOT included in this?
- A. technology relating to arms and related material, chemical and biological weapons, ballistic missiles with a range greater than 150km, and nuclear weapons
- B. arms and related material
- C. personnel or training or technical support services relating to arms and related material, chemical and biological weapons, ballistic missiles with a range greater than 150km, and nuclear weapons
- D. items relating to chemical and biological weapons, ballistic missiles with a range greater than 150km, and nuclear weapons
- E. nuclear weapons and activities such as nuclear testing
Answer: E
NEW QUESTION # 80
If the individual or entity you are dealing with matches all the information on the consolidated list, this is likely to be which of the following:
- A. Individual match
- B. Anonymous match
- C. Name match
- D. Consolidated match
- E. Target match
Answer: E
NEW QUESTION # 81
......
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