Which are the primary sources of information for a sanctions investigation? (Select Two.)
Answer(s): A,B
Sanctions investigations rely primarily on the factual evidence contained in transaction activity and on authoritative, government-issued sanctions lists. Transaction details provide information on counterparties, payment paths, goods, and purpose. Official blocked-person lists such as OFAC, EU, UN, and national export-control lists provide the authoritative basis for sanctions matching. News, social media, and internal correspondence may supplement context but are not primary sources.
Transaction activity as primary investigative data.Mandatory reliance on official sanctions and export-restriction lists.
For which reason does the Office of Foreign Assets Control allow general licenses for providing legal services to sanctions targets?
Answer(s): A
OFAC authorizes certain legal services through general licenses to ensure compliance with US legal obligations, including constitutional and state requirements, while ensuring such legal assistance does not facilitate prohibited transactions. These licenses allow sanctioned individuals to obtain representation for permitted matters such as contesting designations or defending legal actions.
OFAC General Licenses for legal services.Limitations preventing facilitation of prohibited activity.
A US financial institution finds a customer is listed under the Specially Designated Nationals List in the last Office of Foreign Assets Control (OFAC) update. The customer's accounts are immediately blocked. How quickly should the financial institution report this action to OFAC?
OFAC requires that reports of newly blocked property be submitted within 10 business days of the blocking action. The institution must provide full details of the blocked property and the sanctioned party. Any timeline other than 10 business days fails to meet OFAC's regulatory reporting requirements.
OFAC reporting rule for blocked property within 10 business days.
What is the purpose of internal controls according to A Framework for Office of Foreign Assets Control (OFAC) Compliance Commitments? (Select Three.)
Answer(s): A,E,F
Internal controls are a core pillar of OFAC's Compliance Framework. They ensure that the organization implements compliance activities on time, maintains documented procedures and processes, and reduces the risks identified in its OFAC risk assessment. The framework specifies that controls must be documented, tested, and capable of identifying, escalating, and addressing sanctions-related issues.
OFAC Compliance Framework internal control requirements.Internal controls as mechanisms to operationalize timely compliance and risk mitigation.
Which measures should be incorporated into a comprehensive sanctions framework by a financial institution (FI)? (Select Two.)
Answer(s): D,E
A comprehensive sanctions framework requires well-designed operational controls, including thorough training for staff responsible for alert review and sanctions decision-making. Sanctions and Compliance Domains specify that personnel involved in alert clearing must receive appropriate training to ensure awareness of regulatory expectations, sanctions typologies, and escalation procedures.Additionally, the framework must include robust screening controls supported by documented strategy, governance, list-management processes, alert management rules, and ongoing testing. These elements form core requirements of sanctions compliance programs.Management information reports are restricted to need-to-know distribution, and reliance on "best- efforts" is not compliant. Institutions must implement structured, risk-based controls, not minimal- effort approaches.
Requirements for sanctions training and staff competency.Necessity of a robust sanctions screening program with strategic oversight.Internal governance and control expectations in sanctions frameworks.
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