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| Section | Weight | Objectives |
|---|---|---|
| Topic 1: Sanctions Due Diligence | 20% | - Ongoing monitoring and record keeping - Risk assessment and categorization - Customer and counterparty due diligence requirements - Enhanced due diligence for high-risk scenarios |
| Topic 2: Sanctions Investigations and Asset Freezing | 17.5% | - Investigation protocols and procedures - Asset freezing, seizure and restriction measures - Disposition of frozen assets - Reporting obligations to authorities |
| Topic 3: Sanctions Evasion Techniques | 17.5% | - Trade-based money laundering and sanctions circumvention - Common evasion methods and typologies - Digital and emerging risks in evasion - Use of intermediaries, shell companies and complex structures |
| Topic 4: Sanctions Screening | 20% | - Sanctions lists and designated parties - Screening methodologies and tools - Matching logic, false positives and resolution - Transaction and relationship screening |
| Topic 5: Governance and Enforcement | 25% | - Enforcement mechanisms and penalties - Compliance obligations and governance structures - Regulatory bodies and authorities - International sanctions frameworks |
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NEW QUESTION # 76
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 # 77
In Resolution 661 (1990), the Council requested all States to avoid:
Answer: B,C,D
NEW QUESTION # 78
Which of the following is needed to pay salary and related expenses to the designated person?
Answer: C
NEW QUESTION # 79
EU Restrictive Measures apply: (Select Two.)
Answer: C,D
Explanation:
EU Restrictive Measures apply to all persons and entities within the territory of the EU, including airspace and territorial waters, and to any vessel or aircraft under the jurisdiction of an EU Member State. This establishes that sanctions obligations extend to vessels registered under EU jurisdictions regardless of location.
EU sanctions also apply to all legal persons, entities, and bodies incorporated or constituted under the law of an EU Member State, even when those entities operate entirely outside EU territory. Legal incorporation under EU law creates an ongoing obligation to comply with EU sanctions.
EU ownership by itself does not trigger sanctions applicability, so a non-EU company that is 45% owned by an EU national does not fall under EU Restrictive Measures. Additionally, arrangements such as double-taxation conventions or participation in customs union agreements do not extend the territorial or legal applicability of EU sanctions to non-EU jurisdictions.
Reference from Sanctions and Compliance Domains:
Territorial applicability of EU sanctions, including vessels and aircraft under Member State jurisdiction.
Applicability to companies incorporated under EU Member State law regardless of geographic operations.
Legal and territorial definitions outlining the scope of EU Restrictive Measures.
NEW QUESTION # 80
In which situation should a financial institution sanctions team perform a historical review or lookback?
Answer: C
Explanation:
A historical review or lookback is warranted when previously unidentified data elements, missing reference data, or newly discovered customer attributes are detected that may have impacted earlier screening results. Sanctions and Compliance Domains explain that such scenarios indicate that past alerts may not have been correctly generated or evaluated, necessitating a retrospective review.
Routine list updates or daily refreshes do not automatically trigger lookbacks. New sanctions programs may require enhanced forward-looking monitoring, but only missing or newly uncovered data affecting past screening results justify a historical lookback.
Reference:
Requirements for lookbacks when gaps in screening data are discovered.
Identification of previously missing identifiers as a trigger for retrospective review.
NEW QUESTION # 81
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