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ACAMS CGSS Exam Actual Questions
Certified Global Sanctions Specialist (Page 9 )

Updated On: 7-Aug-2026
Page 4 of 22
PDF with 194 Questions

Which has an obligation to accept and carry out UN Security Council Resolutions?

  1. All members of the UN
  2. Only permanent members of the Security Council
  3. Only members of the Security Council
  4. Only countries that are targets of the resolution

Answer(s): A

Explanation:

Under the UN Charter, all United Nations member states are obligated to accept and carry out decisions of the UN Security Council. Sanctions and Compliance Domains emphasize that UN Security Council Resolutions issued under Chapter VII are binding on all UN members, not just Security Council members or targeted states.

Only member states have this obligation. Permanent membership or targeted status does not change the scope of obligation.

Reference from Sanctions and Compliance Domains:

UN Charter obligations for all Member States to implement Security Council Resolutions.

Binding nature of Chapter VII resolutions across all UN members.



A compliance officer needs to make a decision regarding an organization's sanctions screening process.
Which decision is correct?

  1. Exclude vendors and other intermediaries from the screening.
  2. Include only customers and their transactions in the screening.
  3. Include all business activities of the organization in the screening.
  4. Exclude beneficial owners of distributors from the screening.

Answer(s): C

Explanation:

Sanctions and Compliance Domains state that screening must be applied to all relevant business activities and relationships that can expose an organization to sanctions risk. This includes customers, vendors, intermediaries, distributors, beneficial owners, and any party involved in transactions, supply chains, or service delivery.

Limiting screening only to customers is inconsistent with sanctions compliance expectations. Excluding vendors, intermediaries, or beneficial owners can expose an organization to significant sanctions violations due to indirect dealings with sanctioned parties. Comprehensive coverage of all business activities is the standard approach in an effective sanctions compliance program.

Reference from Sanctions and Compliance Domains:

Requirements for comprehensive sanctions screening across all relevant business relationships.

Inclusion of customers, intermediaries, vendors, distributors, and beneficial owners.

Risk-based approach requiring full coverage of business activities to prevent indirect sanctions exposure.



According to the UK's Office of Financial Sanctions Implementation, an entity is considered to be owned directly or indirectly if a person:

  1. holds 50% of the shares or voting rights of the entity.
  2. has the right to sign agreements on behalf of the entity based on the issued power of attorney.
  3. has the right to appoint or remove a majority of the board of directors of the entity.
  4. holds more than 25% of the shares or voting rights of the entity.

Answer(s): A

Explanation:

The UK Office of Financial Sanctions Implementation (OFSI) applies the ownership and control test to determine whether an entity is considered owned or controlled by a designated person. Under OFSI rules, a person is deemed to own an entity if they hold, directly or indirectly, more than 50% of the shares or voting rights. This threshold also applies when determining indirect ownership through corporate structures.

Powers such as signing authority or power of attorney do not constitute ownership. The right to appoint or remove the majority of a board may indicate control but not ownership. Any threshold below 50% does not satisfy the OFSI ownership criteria.

Reference from Sanctions and Compliance Domains:

OFSI ownership threshold requiring more than 50% of shares or voting rights.

Distinction between ownership and other types of influence or authority.



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?

  1. Reject the payment and request the remitter to remove any reference to sanctioned country port in the payment message.
  2. Request the underlying documents and shipment details to ensure there is no involvement of a sanctioned party, port, or sanctioned country goods.
  3. Approve the payment since the parties in the payment are not based in a sanctioned country or are not subject to sanctions.
  4. Review if the beneficiary party's country applies sanctions on the neighboring country; if not, the payment can be approved.

Answer(s): B

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.



The US Treasury adopts a mechanism of secondary sanctions to enforce compliance with its regulations.
Which statement best describes the concept of secondary sanctions?

  1. Sanctions which apply to more than one country
  2. Sanctions which impose restrictions on persons not directly subject to US jurisdiction
  3. Sanctions which are transferred to a bank through its correspondent banking relationship
  4. When an entity has been sanctioned for the second time

Answer(s): B

Explanation:

The concept of secondary sanctions refers to sanctions imposed by the United States on non-US persons or entities that engage in certain activities involving sanctioned jurisdictions, individuals, or sectors. These sanctions apply even though the affected parties are not ordinarily subject to US jurisdiction.

Secondary sanctions are used to discourage foreign actors from engaging in conduct that undermines US sanctions objectives. They do not reflect repeated sanctions, nor are they tied to correspondent banking. They impose consequences irrespective of geographical or jurisdictional boundaries, provided the activity meets defined US sanctionable criteria.

Reference from Sanctions and Compliance Domains:

US Treasury framework defining secondary sanctions and applicability to non-US persons.

Distinction between primary and secondary sanctions.



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