CGSS ACAMS Certified Global Sanctions Specialist (ACAMS CGSS) Free Practice Exam Questions (2025 Updated)

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.

Sanctions evasion indicators in trade documentation include:

• Multiple amendments designed to obscure the parties involved – a classic red flag indicating concealment of the real counterparty.

• Falsified or tampered shipping documents – used to hide sanctioned routes, ports, or vessels.

• Conflicting end-user documentation – a major warning sign of diversion or concealment of sanctioned recipients.

Cash withdrawals (E) and online payment instructions (F) are AML indicators, but not directly sanctions evasion indicators. Docking at non-sanctioned countries (D) is not suspicious unless used as part of concealment, which is not indicated here.

Sanctions and Compliance Domains emphasize that sanctions screening depends on traceable identifiers, transparent transaction histories, and clear counterparties. Privacy coins and mixers/tumblers significantly obscure blockchain transaction trails.

A tumbler or mixer intentionally blends cryptocurrency from multiple sources, making it extremely difficult to determine the origin of funds, the identities of transacting parties, or any links to sanctioned entities. This creates a high sanctions-related risk because sanctioned actors or jurisdictions may exploit these services to disguise involvement.

Privacy coins alone pose risk due to anonymity, but the mixer/tumbler function specifically disrupts sanctions screening capabilities. Financial institutions and exchanges cannot rely on upstream partners to conduct due diligence.

References from Sanctions and Compliance Domains:

Risks of anonymity-enhancing technologies (AETs) in sanctions compliance.

Screening limitations created by mixers/tumblers and privacy-preserving blockchain tools.

Guidance highlighting elevated sanctions risks in digital asset transactions lacking traceability.

Sanctions and Compliance Domains specify that correspondent banking relationships require a comprehensive assessment of the respondent bank’s sanctions risk exposure. Relevant factors include:

• Licensing authorities – Banks licensed in jurisdictions with weak sanctions controls, inadequate supervision, or misaligned regulatory frameworks pose heightened risk. Regulatory oversight directly influences sanctions compliance effectiveness.

• Location of operations – Geographies influence exposure to sanctioned countries, transshipment risks, proliferation financing threats, and proximity to high-risk jurisdictions. Geographic expansion may introduce new sanctions obligations and monitoring requirements.

• Products and services offered – Certain products (e.g., trade finance, cross-border payments, payable-through accounts) carry inherently higher sanctions risk. As respondent banks expand their service offerings, the correspondent institution must reassess associated risks.

The registration number is not relevant to sanctions exposure. Bank representatives may factor into KYC but are not core sanctions-risk elements. The respondent’s customers’ business activity is considered indirectly through the respondent bank’s controls and risk profile, but primary assessment focuses on the bank’s licensing, geography, and product set.

Enhanced due diligence is required when trade transactions involve jurisdictions near sanctioned countries due to the increased risk of transshipment, diversion, and sanctions evasion.

Sanctions and Compliance Domains highlight two core focus areas:

• verifying the identities and ultimate beneficial owners of all involved parties, and

• validating the shipment details, including routing, goods description, and movement patterns.

These elements are critical where geographic proximity raises sanctions exposure. While reviewing commercial terms and pricing may be part of general trade finance due diligence, the primary sanctions-specific EDD requirements focus on beneficial ownership and shipment details.

References from Sanctions and Compliance Domains:

Enhanced due diligence expectations for trade involving high-risk regions.

Requirements to verify UBOs to detect potential sanctioned ownership.

Importance of shipment route verification to detect diversion to sanctioned jurisdictions.

Cigars, particularly those originating from Cuba or other embargoed jurisdictions, fall under both EU and US export sanctions restrictions. Under US OFAC regulations, Cuban-origin goods—including cigars—are strictly prohibited from import, export, resale, or re-export by US persons. EU sanctions may also restrict trade with embargoed or designated jurisdictions.

Textbooks, toys, and art reproductions generally do not fall under export prohibitions unless tied to dual-use concerns or specific jurisdictions, which is not indicated here. Cigars present the most direct and well-established sanctions risk.

Sanctions screening systems rely on key personal identifiers to distinguish between true matches and false positives. The Sanctions and Compliance Domains highlight that the most essential variables for screening individuals include name, date of birth, and identification numbers. These identifiers significantly enhance matching accuracy and reduce false positives, especially when screening against common or high-frequency names.

Location, account numbers, and employers are not primary screening variables for matching against sanctions lists. Although these fields may support enhanced due diligence, they are not core identity attributes used for automated sanctions screening.

References from Sanctions and Compliance Domains:

Essential identity attributes required for automated sanctions screening.

Use of names, birth dates, and identification numbers to improve match accuracy.

Guidance on minimizing false positives using reliable personal identifiers.

Sanctions and Compliance Domains state that institutions may notify the customer that their funds have been blocked or frozen, provided the notification does not reveal internal compliance processes or compromise legal obligations.

The customer may also be directed to the competent authority (such as OFAC or a national sanctions regulator) to seek guidance or licensing relief.

There is no blanket prohibition against notifying the customer; however, the institution must provide factual notification without offering legal advice or operational details.

Sanctions and Compliance Domains identify "weak aliases" as variations of names that do not robustly identify an individual. These include:

• Nicknames – informal or shortened versions (“Alex” vs. “Aleksandr”), often used for concealment.

• Names with numbers – identifiers that are easily fabricated and not tied to legitimate naming conventions.

Middle names, titles, or long names are normal cultural variations and not considered weak aliases for screening purposes.