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

NEW QUESTION # 81
How often should a financial institution refresh and update its screening lists to meet regulatory expectations?

Answer: D

Explanation:
Sanctions and Compliance Domains and regulatory authorities such as OFAC, EU, and OFSI require institutions to update sanctions lists as quickly as possible after a new designation or change is published.
Weekly, biweekly, or monthly cycles are insufficient and can result in missed designations. Financial institutions must adopt systems that update sanctions lists promptly to maintain compliance and avoid facilitating prohibited transactions.
Reference:
Regulatory expectation for immediate or prompt sanctions list updates.
Screening list management best practices for timeliness and accuracy.


NEW QUESTION # 82
An entity not listed by the Office of Foreign Assets Control is attempting to open a bank account in the US. During the screening process, an employee learns that the entity's ownership exceeds the 50% aggregate Specially Designated National ownership threshold. How should the employee proceed?

Answer: D

Explanation:
Under OFAC's 50 Percent Rule, any entity that is owned 50% or more-individually or in aggregate-by one or more Specially Designated Nationals (SDNs) is considered automatically blocked, even if not explicitly listed.
Financial institutions must treat such entities as if they are SDNs. Therefore, the account cannot be opened. Senior management approval cannot override OFAC regulations, and altering ownership to bypass sanctions is prohibited facilitation.
Reference:
OFAC 50 Percent Rule and automatic blocking requirements.
Prohibition on opening accounts or facilitating transactions for SDN-owned entities.


NEW QUESTION # 83
While reviewing a transaction screening alert, an analyst noted that a payment message made reference to a port in a sanctioned country. The payment was to a company based in a country neighboring the sanctioned country. Which action should the analyst take?

Answer: D

Explanation:
Sanctions and Compliance Domains outline that references to sanctioned ports, locations, or shipping routes in payment instructions require further investigation. Even when the transaction parties are not located in a sanctioned jurisdiction, involvement of a sanctioned port or movement of prohibited goods can trigger sanctions exposure.
The correct approach is to obtain supporting documents such as shipping documents, invoices, bills of lading, and routing information to confirm whether the shipment, goods, transport path, or third parties have any sanctioned involvement. Approving or rejecting a payment without verification contradicts sanctions screening standards.
Reference from Sanctions and Compliance Domains:
Requirements to investigate references to sanctioned locations in trade or payment messages.
Guidance on obtaining underlying documents to assess sanctions exposure.
Expectations for verifying goods, ports, and shipment paths.


NEW QUESTION # 84
Which should be considered when selecting the appropriate watch lists to screen the customer base?

Answer: C

Explanation:
Selecting watch lists for sanctions screening requires understanding geographic exposure, including customer locations, jurisdictions in which products/services are offered, and locations of trading partners. Sanctions programs vary by region (e.g., OFAC, EU, UN, UK), so geographic impact is essential.
Transaction size, withdrawal patterns, and relationship length are AML considerations but are not primary factors for selecting sanctions watch lists.
Reference:
Risk-based approach to sanctions list selection.
Consideration of geographic exposure to sanctioned jurisdictions.


NEW QUESTION # 85
In the event of a sanctions violation, the inclusion of a sanctions clause in a trade contract can:

Answer: A

Explanation:
Sanctions and Compliance Domains state that sanctions clauses in trade contracts are used to:
* clarify prohibited activities,
* define obligations of the parties in case sanctions become applicable, and
* ensure business partners understand compliance expectations.
A sanctions clause cannot enforce a contract when sanctions apply (B), cannot assign liability for regulatory fines (C) beyond legal requirements, and cannot operate as a license (D). Only regulators (e.g., OFAC, EU authorities) can authorize activities by issuing licenses.
Reference:
Trade contract sanctions clauses and their function.
Legal requirements surrounding sanctions clauses and regulatory authority.


NEW QUESTION # 86
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