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| Section | Weight | Objectives |
|---|
| Remediation and Reporting | 15% | - Regulatory reporting
- 1. Licensing and exceptions
- 2. Blocking/rejecting transactions
- 3. Suspicious Activity Reports (SARs)
- Sanctions violations handling
- 1. Self-reporting obligations
- 2. Civil and criminal penalties
- 3. OFAC Voluntary Self-Disclosure
|
| Investigation and Escalation | 15% | - Escalation procedures
- 1. Internal escalation pathways
- 2. Senior management notification
- 3. Legal and compliance consultation
- Sanctions alerts investigation
- 1. Alert triage and prioritization
- 2. Decision-making frameworks
- 3. Evidence gathering and documentation
|
| Sanctions Environment and Framework | 15% | - Overview of sanctions regimes (OFAC, EU, UN, UK)
- 1. Sanctions objectives and policy considerations
- 2. Legal authorities and enforcement agencies
- 3. Economic sanctions fundamentals
- Types of sanctions (comprehensive, sectoral, targeted)
- 1. Trade sanctions
- 2. Travel sanctions
- 3. Financial sanctions
|
| Risk Assessment and Compliance Program | 20% | - Compliance program components
- 1. Training and awareness
- 2. Policies and procedures
- 3. Governance and oversight
- Sanctions risk assessment methodology
- 1. Risk mitigation strategies
- 2. Risk identification
- 3. Risk monitoring and reporting
|
| Screening and Monitoring | 25% | - Transaction screening
- 1. Enhanced due diligence
- 2. Name screening methodologies
- 3. False positive management
- Ongoing monitoring
- 1. Real-time transaction monitoring
- 2. Counterparty risk assessment
- 3. Adverse media screening
- Technology and automation
- 1. System limitations and tuning
- 2. AI/ML applications in screening
- 3. Sanctions screening technology
|
| Specialized Topics and Emerging Issues | 10% | - Sanctions evasion techniques
- 1. Secondary sanctions awareness
- 2. Shell company detection
- 3. Trade-based money laundering
- Crypto/digital asset sanctions
- 1. Virtual currency service providers
- 2. DeFi and blockchain considerations
|
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ACAMS Certified Global Sanctions Specialist Sample Questions (Q18-Q23):
NEW QUESTION # 18
A shell company deceptively acquires equipment on behalf of the ultimate purchaser from a sanctioned country. This deceptive tactic includes:
- A. consolidation of goods.
- B. reorganization of ownership interests.
- C. sham divestment.
- D. concealment of the final destination.
Answer: D
Explanation:
Using a shell company to procure goods on behalf of a sanctioned end-user commonly involves concealing the true final destination. Sanctions and Compliance Domains describe this as a primary evasion technique in illicit procurement chains, where shell companies mask the ultimate recipient, shipment routing, and country of origin or destination.
Consolidation of goods and changes in ownership structure may occur in other schemes but the key deceptive tactic in this question is the concealment of the actual final destination.
Reference:
Illicit procurement and diversion typologies involving shell companies.
Concealment of end-users and destination as a sanctions evasion indicator.
NEW QUESTION # 19
The actions of the US President on sanctions differ according to the sort of nation he is sanctioning. All three types of nations have different decision calculations, and the calculation changes from the decision to apply to the decision to amend sanctions.
Specifically, the President penalizes non-Latin American and non-Communist countries for:
- A. Economic reasons
- B. Personal reasons
- C. International causes
- D. Domestic reasons
Answer: C,D
NEW QUESTION # 20
According to OFSI, the asset freeze as a financial sanction generally involves the further steps, except:
- A. Prohibited to make funds or economic resources available, directly or indirectly for a designated person
- B. Prohibited to deal with the frozen funds or economic resources
- C. Prohibited to make funds or economic resources available, directly or indirectly for a benefit
- D. Prohibited to engage in actions that, directly or indirectly, circumvent the financial sanctions prohibitions
- E. Changes in ownership of the frozen funds or economic resources
Answer: E
NEW QUESTION # 21
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 no right to exercise their civil rights
- B. They have reserved the right to safeguard themselves and their integrity
- C. They can take action as they see fit to uphold justice and justice
- D. They are bound to obey the Security Council
- E. They will cease their hostilities
Answer: B,C
NEW QUESTION # 22
Under an asset freeze it is generally prohibited to do the following except?
- A. deal with the frozen funds or economic resources, belonging to or owned, held or controlled by a designated person
- B. make funds or economic resources available, indirectly, to, or for the benefit of, a designated person
- C. make funds or economic resources available, directly to, or for the benefit of, a designated person
- D. None of the above
- E. engage in actions that, directly or indirectly, circumvent the financial sanctions prohibitions
Answer: D
NEW QUESTION # 23
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