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Certified Global Sanctions Specialist Questions 41–45 (page: 10)

Updated On: 10-Feb-2026

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

  1. Every week
  2. Every two weeks
  3. Every three weeks
  4. As quickly as possible

Answer(s): 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.



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?

  1. Reject or decline the account opening and add the entity name to the internal watch list to avoid further business activity.
  2. Obtain senior management approval to proceed with the account opening.
  3. Request that the customer alters the ownership percentage to enable them to open the account.
  4. Authorize the account opening as this entity is not considered to be restricted.

Answer(s): A

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.



Based on EU best practices with respect to sanctions exemptions, which payment may a financial institution process for a designated person?

  1. Newspaper subscription
  2. Salary
  3. Taxi ride
  4. Luxury clothing purchase

Answer(s): A

Explanation:

EU best practices allow processing of payments that fall under permitted exemptions such as basic needs and reasonable living expenses. These may include essential subscriptions such as newspapers or communication services, provided proper authorization or notification is followed.

Salary payments generally require strict conditions and may not be allowed directly for designated persons. Taxi rides and luxury purchases are not considered basic or essential needs and cannot be processed.


Reference:

EU restrictive measures exemptions for basic needs and essential services.

Conditions for processing payments for designated persons.



In which situation should a financial institution sanctions team perform a historical review or lookback?

  1. When the Specially Designated Nationals List is updated
  2. When screening lists are successfully loaded during a daily refresh
  3. When previously unidentified data points are detected by screening systems
  4. When a new sanctions program is introduced

Answer(s): 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.



Who must comply with Office of Foreign Assets Control regulations in all circumstances?

  1. Foreign companies with US subsidiaries
  2. Foreign financial institutions without a US nexus
  3. Foreign persons in possession of US-origin goods
  4. US persons, including all US citizens and permanent resident aliens

Answer(s): D

Explanation:

OFAC regulations apply broadly to US persons, which include US citizens, permanent residents, entities organized under US law, and individuals located in the United States. These obligations apply regardless of where the US person is physically located.

Foreign companies, foreign financial institutions, or foreign persons are only obligated under OFAC regulations when a US nexus exists (e.g., US origin goods, US dollars, US-based transactions). US persons, however, must always comply.


Reference:

Definition of "US persons" under OFAC regulations.

Global applicability of OFAC rules to US citizens and permanent residents.



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