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| Section | Objectives |
|---|---|
| Topic 1: Foundations of Global Sanctions Compliance | - Sanctions regulatory landscape (UN, OFAC, EU, UK) - Key sanctions terminology and typologies |
| Topic 2: Sanctions Governance and Risk Management | - Enterprise sanctions risk assessment - Policies, procedures, and internal controls |
| Topic 3: Screening and Monitoring Systems | - Name matching and alert management - Customer and transaction screening |
| Topic 4: Sanctions Evasion and Typologies | - Common evasion techniques - Red flags and investigative indicators |
| Topic 5: Compliance Operations and Enforcement | - Case management and investigations - Regulatory expectations and enforcement actions |
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NEW QUESTION # 12
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: C
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 # 13
A person is designated by the UK and EU. This person owns and controls a company with subsidiaries in diversified industries. Which scenario presents a warning sign for sanctions evasion?
Answer: C
Explanation:
Sanctions and Compliance Domains highlight that sanctioned individuals may attempt to evade restrictions by transferring assets, ownership rights, or operational control to family members or close associates. These transfers may appear legitimate but are often structured to conceal continuing beneficial ownership or influence.
Asset transfers to relatives or trusted associates are recognized as classic sanctions evasion red flags across EU and UK ownership and control guidance.
Opening bank accounts in non-aligned jurisdictions may create exposure, but the specific red flag of evasion is the movement of assets to associates. Changes in corporate strategy or reduced trading activity are not inherently indicative of sanctions evasion.
Reference:
UK and EU ownership/control evasion typologies.
Sanctions evasion red flags involving relatives and close associates.
NEW QUESTION # 14
According to the Wolfsberg Guidance, the most important factor a financial institution should take into consideration for developing an in-house sanctions screening system is:
Answer: D
Explanation:
The Wolfsberg Guidance on Sanctions Screening emphasizes data quality as the most important factor when developing or maintaining a screening system. High-quality, accurate, complete, and consistently structured data is essential to ensure proper matching, reduce false positives, and avoid missed true matches.
Even with strong IT capabilities or defined risk appetite, a screening system will fail if the underlying data is incomplete or inaccurate.
Reference:
Wolfsberg Guidance: primacy of data quality in sanctions screening.
Importance of accurate customer and transaction data for effective matching.
NEW QUESTION # 15
Which fields of a payment message are commonly subject to sanctions screening? (Select Three.)
Answer: B,E,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 # 16
Which of the following restrictions were made on Russia for imposing sanctions on Ukraine?
Answer: B,C,E
NEW QUESTION # 17
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