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ACAMS CGSS (Certified Global Sanctions Specialist) exam is a rigorous and comprehensive assessment of professionals' knowledge and expertise in the global sanctions industry. CGSS exam is designed to ensure that candidates possess a deep understanding of the global sanctions landscape, including the laws, regulations, and best practices that govern sanctions compliance.

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ACAMS Certified Global Sanctions Specialist Sample Questions (Q75-Q80):

NEW QUESTION # 75
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?

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 # 76
Which of the following replaced the United Nations Special Commission (UNSCOM) in late 1999?

Answer: D


NEW QUESTION # 77
A non-governmental organization (NGO) is actively searching for international supporting projects, which could involve the use of designated banks. The NGO:

Answer: B

Explanation:
Sanctions and Compliance Domains state that NGOs are not exempt from sanctions laws. Even humanitarian organizations must ensure that they do not transact through designated banks, sanctioned parties, or sanctioned jurisdictions unless authorized through applicable exemptions or licenses.
Furthermore, NGOs can be indirectly affected by sanctions when engaging in international work, especially when the banking sector of a target region is designated. Therefore, they may continue operating, but must fully consider sanctions exposure, including the involvement of designated banks.
Statements that NGOs are automatically exempt are factually incorrect. Compliance depends on the sanctions program, jurisdiction, and licensing conditions.
Reference:
Sanctions applicability to NGOs and humanitarian organizations.
Indirect sanctions impact when designated banks are involved.


NEW QUESTION # 78
Those in the virtual currency industry are required to prevent sanctioned persons from exploiting virtual currency to undermine US foreign policy and national security interests. Which internal controls are most appropriate?

Answer: D

Explanation:
Effective internal controls for virtual asset service providers include:
* Sanctions screening of users, wallets, and transactions.
* IP blocking/geolocation controls to stop access from sanctioned jurisdictions.
* Keyword screening for wallet names, addresses, or known illicit indicators.
* Reviewing and enforcing end-user agreements, including prohibitions on using the platform for sanctioned activity.
Other options include unnecessary or ineffective controls (downsizing staff, screening employees, or vendor-only screening), which are not aligned with sanctions-control best practices.
Reference:
OFAC Guidance for the Virtual Currency Industry.
Controls for preventing sanctioned-person access to digital assets.


NEW QUESTION # 79
A compliance analyst at a UK-based company is reviewing a transaction alert for Entity A. A representative provided documentation that a UK Asset Freeze individual reduced their stake in Entity A from 70% to 30% shortly after they became subject to sanctions. Which steps should the analyst recommend first?

Answer: D

Explanation:
Under UK OFSI rules, entities owned or controlled by a designated person remain subject to asset freeze restrictions. A reduction in ownership from above 50% to below 50%, particularly when occurring immediately after designation, requires enhanced due diligence to determine whether the divestment is genuine or merely an attempt to evade sanctions.
Sanctions and Compliance Domains emphasize the need for verification when documentation claims ownership reduction. Institutions must confirm authenticity, timing, beneficiaries of the transfer, and any continuing control influence by the designated person.
Approving the transaction before verification, removing screening, or rejecting without confirming details contradicts UK sanctions compliance expectations. Enhanced due diligence is the required first step.
Reference from Sanctions and Compliance Domains:
OFSI ownership and control criteria, including obligations when ownership reductions occur post-designation.
Requirements for enhanced due diligence to confirm legitimacy of divestment or restructuring.
Risk indicators of sanctions evasion through rapid ownership structure changes.


NEW QUESTION # 80
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