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ACAMS CGSS Exam Syllabus Topics:

Section	Weight	Objectives
Topic 1: Investigation and Escalation	15%	- Escalation procedures 1. Senior management notification 2. Legal and compliance consultation 3. Internal escalation pathways - Sanctions alerts investigation 1. Decision-making frameworks 2. Alert triage and prioritization 3. Evidence gathering and documentation
Topic 2: Screening and Monitoring	25%	- Technology and automation 1. AI/ML applications in screening 2. Sanctions screening technology 3. System limitations and tuning - Ongoing monitoring 1. Adverse media screening 2. Real-time transaction monitoring 3. Counterparty risk assessment - Transaction screening 1. False positive management 2. Enhanced due diligence 3. Name screening methodologies
Topic 3: Remediation and Reporting	15%	- Regulatory reporting 1. Licensing and exceptions 2. Blocking/rejecting transactions 3. Suspicious Activity Reports (SARs) - Sanctions violations handling 1. OFAC Voluntary Self-Disclosure 2. Self-reporting obligations 3. Civil and criminal penalties
Topic 4: Specialized Topics and Emerging Issues	10%	- Crypto/digital asset sanctions 1. Virtual currency service providers 2. DeFi and blockchain considerations - Sanctions evasion techniques 1. Shell company detection 2. Trade-based money laundering 3. Secondary sanctions awareness
Topic 5: Risk Assessment and Compliance Program	20%	- Sanctions risk assessment methodology 1. Risk monitoring and reporting 2. Risk identification 3. Risk mitigation strategies - Compliance program components 1. Governance and oversight 2. Policies and procedures 3. Training and awareness
Topic 6: Sanctions Environment and Framework	15%	- Overview of sanctions regimes (OFAC, EU, UN, UK) 1. Legal authorities and enforcement agencies 2. Sanctions objectives and policy considerations 3. Economic sanctions fundamentals - Types of sanctions (comprehensive, sectoral, targeted) 1. Trade sanctions 2. Financial sanctions 3. Travel sanctions

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ACAMS Certified Global Sanctions Specialist Sample Questions (Q81-Q86):

NEW QUESTION # 81
According to the assessment of Humanitarian vulnerability, the following are often more vulnerable, may be discriminated against and have lower incomes except?

A. The poor
B. The disabled
C. Refugees
D. The elderly
E. Disadvantaged ethnic groups

Answer: B

NEW QUESTION # 82
Independent testing related to sanctions screening should be conducted by which group with adequate technology expertise?

A. A team that conducts investigations
B. A team that manages risk assessments
C. A team that manages the institution's screening lists
D. A team that is from internal audit

Answer: D

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 # 83
According to OFSI, financial sanctions can be imposed with the following purposes, except:

A. Protect the value of assets that have been misappropriated from a country until these assets can be repatriated
B. Coerce a regime, or individuals within a regime, into changing their behavior
C. Increase the value of assets that have been misappropriated from a country until these assets can be repatriated
D. Signal disapproval, stigmatizing and potentially isolating a regime or individual
E. Constrain a target by denying them access to key resources needed to continue their offending behavior

Answer: C

NEW QUESTION # 84
A person designated by the Office of Foreign Assets Control (OFAC) as a Specially Designated National (SDN) sets up a company in a tax haven country to receive income from a consultancy business. Which is correct with respect to the company?

A. It is not subject to OFAC sanctions
B. It cannot be sanctioned by OFAC because it is set up in a tax haven country.
C. It can transact freely in USD through a bank account held with a non-US Bank.
D. It cannot transact through a US Bank, as it is owned by an SDN.

Answer: D

Explanation:
Under OFAC's 50 Percent Rule, any entity owned 50% or more by one or more SDNs is considered automatically blocked, even if it is not explicitly listed. The jurisdiction of incorporation (e.g., tax haven) does not exempt the entity from OFAC sanctions.
Because the SDN owns the company, the entity is also subject to OFAC prohibitions and cannot transact through the US financial system, including any USD-clearing banks, whether located inside or outside the United States.
Options B, C, and D are incorrect because OFAC sanctions apply regardless of where the company is registered and because USD transactions create a US nexus.
Reference:
OFAC 50 Percent Rule on ownership and blocking.
Prohibitions on US financial institutions processing transactions involving SDNs or SDN-owned entities.

NEW QUESTION # 85
Which statement best describes the difference between the requirements for calculating beneficial ownership for sanctions due diligence (SDD) and calculating beneficial ownership for AML in the US?

A. AML requirements identify a beneficial owner as a person who owns more than 51% of a legal entity, whereas the Office of Foreign Assets Control applies the 25% Rule to legal entity ownership for SDD.
B. AML requirements identify a beneficial owner as a person who owns more than 50% of a legal entity, whereas the Office of Foreign Assets Control applies the 25% Rule to legal entity ownership for SDD.
C. AML requirements identify a beneficial owner as a person who owns more than 25% of a legal entity, whereas the Office of Foreign Assets Control applies the 50% Rule to legal entity ownership for SDD.
D. AML requirements identify a beneficial owner as a person who owns more than 20% of a legal entity, whereas the Office of Foreign Assets Control applies a higher threshold to legal entity ownership for SDD.

Answer: C

Explanation:
US AML requirements (such as the Customer Due Diligence Rule) define a beneficial owner as an individual who owns 25% or more of a legal entity. OFAC, however, applies the 50% Rule for sanctions due diligence: an entity is considered owned by a sanctioned person if the designated person holds, individually or collectively, 50% or more of the entity.
The AML 25% standard is not used for determining whether an entity is treated as sanctioned; instead, OFAC's ownership threshold is fixed at 50%. The correct distinction is the difference between AML's 25% threshold and OFAC's 50% Rule.
Reference from Sanctions and Compliance Domains:
Beneficial ownership thresholds under US AML customer due diligence rules.
OFAC's 50% Rule for sanctions ownership determinations.

NEW QUESTION # 86
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