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| Section | Objectives |
|---|---|
| Topic 1: Sanctions Governance and Risk Management | - Policies, procedures, and internal controls - Enterprise sanctions risk assessment |
| Topic 2: Foundations of Global Sanctions Compliance | - Key sanctions terminology and typologies - Sanctions regulatory landscape (UN, OFAC, EU, UK) |
| Topic 3: Screening and Monitoring Systems | - Name matching and alert management - Customer and transaction screening |
| Topic 4: Sanctions Evasion and Typologies | - Red flags and investigative indicators - Common evasion techniques |
| Topic 5: Compliance Operations and Enforcement | - Case management and investigations - Regulatory expectations and enforcement actions |
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NEW QUESTION # 47
North Korea's campaign to become a nuclear power first became apparent in March 1993, when it announced that it was withdrawing from a treaty.
Which of the following treaty is this?
Answer: B
NEW QUESTION # 48
A US financial institution finds a customer is listed under the Specially Designated Nationals List in the last Office of Foreign Assets Control (OFAC) update. The customer's accounts are immediately blocked. How quickly should the financial institution report this action to OFAC?
Answer: A
Explanation:
OFAC requires that reports of newly blocked property be submitted within 10 business days of the blocking action. The institution must provide full details of the blocked property and the sanctioned party. Any timeline other than 10 business days fails to meet OFAC's regulatory reporting requirements.
Reference:
OFAC reporting rule for blocked property within 10 business days.
NEW QUESTION # 49
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:
Answer: D
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 # 50
There are three types of PBE: isolation, pooling, and semi-separation. In which category of PBE do the two forms of actor give the same signal?
Answer: B
NEW QUESTION # 51
Independent testing related to sanctions screening should be conducted by which group with adequate technology expertise?
Answer: B
Explanation:
Sanctions and Compliance Domains state that independent testing and auditing must be conducted by a group separate from the sanctions operations and screening management teams. Internal audit is typically the independent function with sufficient technology and control expertise to assess system performance, threshold calibration, governance, and rule sets.
Teams involved in day-to-day operations (investigations, list management, risk assessment) cannot test their own work due to conflicts of interest.
Reference:
OFAC and industry expectations for independent testing.
Internal audit as the designated independent review function.
NEW QUESTION # 52
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