CSS CSS Sanctions Program Types & Target Identification 1 — Questions and Answers
Question 1: Which type of sanctions program targets an entire country or geographic region rather than specific individuals or entities?
- Comprehensive sanctions (Correct answer)
- List-based sanctions
- Sectoral sanctions
- Secondary sanctions
Correct answer: Comprehensive sanctions
Comprehensive sanctions impose broad restrictions on all dealings with a specific country or territory, such as the historic Cuba and Iran embargoes.
Question 2: OFAC's Specially Designated Nationals (SDN) List primarily targets which category of persons?
- Only foreign governments
- Individuals and entities whose assets are blocked under U.S. sanctions programs (Correct answer)
- Only financial institutions
- Only companies involved in weapons trade
Correct answer: Individuals and entities whose assets are blocked under U.S. sanctions programs
The SDN List includes individuals, entities, and vessels whose assets are blocked and with whom U.S. persons are generally prohibited from dealing.
Question 3: What is the key distinction between primary and secondary sanctions?
- Primary sanctions apply to U.S. persons; secondary sanctions can penalize non-U.S. persons for dealings with sanctioned parties (Correct answer)
- Secondary sanctions are more severe than primary sanctions
- Primary sanctions target governments; secondary sanctions target individuals
- There is no meaningful legal distinction between the two
Correct answer: Primary sanctions apply to U.S. persons; secondary sanctions can penalize non-U.S. persons for dealings with sanctioned parties
Primary sanctions prohibit U.S. persons from transacting with sanctioned parties, while secondary sanctions create risk for non-U.S. persons who conduct certain business with sanctioned targets.
Question 4: Sectoral sanctions under OFAC's Sectoral Sanctions Identifications (SSI) List differ from SDN designations because they:
- Block all assets of listed entities
- Impose targeted restrictions on specific sectors rather than blocking all transactions (Correct answer)
- Apply only to energy companies
- Are enforced by the Department of Justice, not OFAC
Correct answer: Impose targeted restrictions on specific sectors rather than blocking all transactions
SSI sectoral sanctions restrict specific types of transactions (e.g., new debt or equity) in targeted sectors like Russian finance and energy, without fully blocking the listed entity.
Question 5: A vessel placed on OFAC's SDN List is typically identified by which unique identifier?
- IMO number (Correct answer)
- SWIFT BIC code
- DUNS number
- IATA code
Correct answer: IMO number
Ships designated on the SDN List are identified by their International Maritime Organization (IMO) number, which is a permanent vessel identifier.
Question 6: Which sanctions program specifically targets narcotics traffickers and was authorized by the Kingpin Act?
- Transnational Criminal Organizations (TCO) program
- Foreign Narcotics Kingpin Sanctions program (Correct answer)
- Counter Narcotics Finance program
- Drug Interdiction Sanctions program
Correct answer: Foreign Narcotics Kingpin Sanctions program
The Foreign Narcotics Kingpin Sanctions program, authorized by the Narcotics Trafficking Sanctions Regulations and the Kingpin Act, targets significant narcotics traffickers and their associates.
CSS CSS Sanctions Program Types & Target Identification 1
Which type of sanctions program targets an entire country or geographic region rather than specific individuals or entities?