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ACAMS Certified Global Sanctions Specialist Sample Questions (Q99-Q104):

NEW QUESTION # 99
Which statement best describes the difference between the requirements for calculating beneficial ownership for sanctions due diligence (SDD) and calculating beneficial ownership for AML in the US?

A. AML requirements identify a beneficial owner as a person who owns more than 50% of a legal entity, whereas the Office of Foreign Assets Control applies the 25% Rule to legal entity ownership for SDD.
B. AML requirements identify a beneficial owner as a person who owns more than 25% of a legal entity, whereas the Office of Foreign Assets Control applies the 50% Rule to legal entity ownership for SDD.
C. AML requirements identify a beneficial owner as a person who owns more than 20% of a legal entity, whereas the Office of Foreign Assets Control applies a higher threshold to legal entity ownership for SDD.
D. AML requirements identify a beneficial owner as a person who owns more than 51% of a legal entity, whereas the Office of Foreign Assets Control applies the 25% Rule to legal entity ownership for SDD.

Answer: B

Explanation:
US AML requirements (such as the Customer Due Diligence Rule) define a beneficial owner as an individual who owns 25% or more of a legal entity. OFAC, however, applies the 50% Rule for sanctions due diligence: an entity is considered owned by a sanctioned person if the designated person holds, individually or collectively, 50% or more of the entity.
The AML 25% standard is not used for determining whether an entity is treated as sanctioned; instead, OFAC's ownership threshold is fixed at 50%. The correct distinction is the difference between AML's 25% threshold and OFAC's 50% Rule.
Reference from Sanctions and Compliance Domains:
Beneficial ownership thresholds under US AML customer due diligence rules.
OFAC's 50% Rule for sanctions ownership determinations.

NEW QUESTION # 100
Similar State-level constraints apply both in the target country and in third countries.
Which of the following statements supports the corresponding argument in respect of the target country?

A. The offer of assistance can be perceived as an act of revenge.
B. All of the above
C. The provision of assistance may not be used as a benefit for being cooperative.
D. The offer of assistance can be perceived not as a pledge, but as a menace.
E. The offer of assistance can be seen not as a challenge but as a reward.

Answer: D

NEW QUESTION # 101
What type of sanctions are imposed against indicated persons operating in targeted field(s) of a country's economy?

A. Comprehensive sanctions
B. Sectoral sanctions
C. Individual sanctions
D. Corporate sanctions

Answer: B

Explanation:
Sectoral sanctions target specific sectors of a foreign country's economy, such as defense, energy, mining, or financial services. These sanctions apply to persons or entities operating within those sectors and often restrict specific types of transactions (e.g., certain financing or technology transfers).
Comprehensive sanctions cover entire jurisdictions. Individual or corporate sanctions apply to specific persons or companies but are not sector-based.
Reference:
Definition of sectoral sanctions using economic sector targeting.
Distinction between sectoral and comprehensive sanctions.

NEW QUESTION # 102
A sanctions analyst reviews payment requests from a sanctioned country. After investigation, it appears that the request represents a medicine export from a pharmaceutical company to a sanctioned country. Which step should the analyst take next?

A. Check for applicable general licenses or exemptions.
B. Reject the payment.
C. Review the counterparty.
D. Demand a specific license.

Answer: A

Explanation:
In sanctions compliance frameworks applied globally by bodies such as OFAC, the EU, the UN, the UK, Canada, and Australia, transactions involving humanitarian goods, including medicine and medical supplies, are treated under specific regulatory categories. These frameworks include humanitarian exemptions, general licenses, and permitted transactions for medical or health-related items. The standard compliance expectation requires an analyst to determine whether the activity is already authorized before taking restrictive action.
The Sanctions and Compliance Domains specify that when a transaction involves potential humanitarian goods, the analyst must confirm whether a general license or exemption applies. General licenses commonly authorize exports of medicines, medical devices, and humanitarian materials to sanctioned jurisdictions. The rule requires verification of these authorizations prior to escalation, rejection, or requesting a specific license.
If a general license exists for the type of goods or activity, the transaction may proceed in accordance with regulatory conditions. Only when no exemption or general license applies should a specific license be sought. Therefore, the correct immediate step for the analyst is to check applicable general licenses or exemptions related to medical exports.
Reference from Sanctions and Compliance Domains:
Regulatory requirements relating to humanitarian exemptions under sanctions programs.
General license structures for medical and humanitarian goods in sanctions regimes.
Compliance procedures directing analysts to verify authorizations or exemptions before rejecting or escalating transactions.
Standard sequencing: determine applicability of general licenses or exemptions prior to requesting a specific license.

NEW QUESTION # 103
The actions of the US President on sanctions differ according to the sort of nation he is sanctioning. All three types of nations have different decision calculations, and the calculation changes from the decision to apply to the decision to amend sanctions.
Specifically, the President penalizes non-Latin American and non-Communist countries for:

A. Economic reasons
B. Domestic reasons
C. Personal reasons
D. International causes

Answer: B,D

NEW QUESTION # 104
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