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Certified Global Sanctions Specialist Questions 36–40 (page: 9)

Updated On: 10-Feb-2026

According to the 2019 Wolfsberg Guidance on Sanctions Screening, which is related to the fundamental pillars of sanctions screening programs?

  1. External audit
  2. Risk assessment
  3. Risk management
  4. External reporting

Answer(s): B

Explanation:

The Wolfsberg 2019 Guidance identifies risk assessment as a foundational component of sanctions screening programs. Screening systems, list management, and alert handling must reflect the institution's assessed sanctions risk exposure.

External audit and reporting are relevant compliance functions but are not listed as fundamental pillars of screening programs in the Wolfsberg framework. Risk management is a broader corporate discipline, while screening specifically starts with a clear sanctions risk assessment.


Reference:

Wolfsberg 2019 Guidance on Sanctions Screening fundamentals.

Requirement that screening be risk-based and aligned with sanctions risk assessment outcomes.



Which information should be considered while investigating a potential sanctions violation? (Select Two.)

  1. The customer's dual residence in a sanctioned country and a non-sanctioned country
  2. The customer's IP addresses
  3. The customer's transactions of 10,000 USD or EUR or higher
  4. The customer's incoming and outgoing wire transfers involving non-sanctioned countries
  5. The customer's salary

Answer(s): A,B

Explanation:

Sanctions and Compliance Domains emphasize the importance of identity, residency, location indicators, and digital footprints when assessing potential sanctions violations.

Dual residency in a sanctioned country may trigger sanctions exposure because residency can determine jurisdictional reach. Likewise, IP addresses reveal the customer's actual geographic location during transactions and are critical in identifying hidden connections to sanctioned jurisdictions.

Transaction size thresholds, routine salary information, or transfers within non-sanctioned countries do not directly indicate sanctions violations.


Reference:

Analysis of geographic indicators such as residency and IP information.

Importance of location-based data in determining sanctions exposure.



Which commodities are allowed to be exported to sanctioned countries under the Office of Foreign Assets Control general license on humanitarian grounds?

  1. Gold and other luxury items
  2. Iron and steel
  3. Agricultural commodities, medicine, or medical devices
  4. Crude oil and petroleum products

Answer(s): C

Explanation:

OFAC general licenses commonly authorize the export of agricultural commodities, medicine, and medical devices to sanctioned countries under humanitarian exemptions. These items are recognized as essential goods and are generally permitted even in comprehensive sanctions programs, provided specific conditions are met.

Luxury goods such as gold, raw materials like iron and steel, and petroleum-related products are typically prohibited or require specific licensing.


Reference:

OFAC humanitarian general licenses for agricultural and medical goods.

Exclusion of luxury and industrial commodities from humanitarian authorizations.



A person is designated by the UK and EU. This person owns and controls a company with subsidiaries in diversified industries.
Which scenario presents a warning sign for sanctions evasion?

  1. Opening of bank accounts in jurisdictions with no alignment to UK and EU sanctions
  2. Changes in corporate strategy to diversify further into different industries
  3. Cessation of trading or operational activities in some subsidiaries
  4. Transfer of assets to family members or close associates

Answer(s): D

Explanation:

Sanctions and Compliance Domains highlight that sanctioned individuals may attempt to evade restrictions by transferring assets, ownership rights, or operational control to family members or close associates. These transfers may appear legitimate but are often structured to conceal continuing beneficial ownership or influence.

Asset transfers to relatives or trusted associates are recognized as classic sanctions evasion red flags across EU and UK ownership and control guidance.

Opening bank accounts in non-aligned jurisdictions may create exposure, but the specific red flag of evasion is the movement of assets to associates. Changes in corporate strategy or reduced trading activity are not inherently indicative of sanctions evasion.


Reference:

UK and EU ownership/control evasion typologies.

Sanctions evasion red flags involving relatives and close associates.



A shell company deceptively acquires equipment on behalf of the ultimate purchaser from a sanctioned country. This deceptive tactic includes:

  1. concealment of the final destination.
  2. consolidation of goods.
  3. sham divestment.
  4. reorganization of ownership interests.

Answer(s): A

Explanation:

Using a shell company to procure goods on behalf of a sanctioned end-user commonly involves concealing the true final destination. Sanctions and Compliance Domains describe this as a primary evasion technique in illicit procurement chains, where shell companies mask the ultimate recipient, shipment routing, and country of origin or destination.

Consolidation of goods and changes in ownership structure may occur in other schemes but the key deceptive tactic in this question is the concealment of the actual final destination.


Reference:

Illicit procurement and diversion typologies involving shell companies.

Concealment of end-users and destination as a sanctions evasion indicator.



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