ACAMS - Association of Certified Anti-Money Laundering Specialists Global Sanctions Compliance Questions and Answers

Question 1

A financial institution's transaction monitoring system flags a potential name match between a party in a wire transfer and an individual on the OFAC Specially Designated Nationals (SDN) list.
What is the most critical initial step the compliance officer should take?

Accepted Answer

Investigate the alert to determine if it is a true match or a false positive.

Answer

Immediately block the transaction and report it to the authorities.

Answer

Contact the customer to inquire about the purpose of the transaction.

Answer

Reject the transaction and return the funds to the originator.

Question 2

According to the U.S. Office of Foreign Assets Control (OFAC) "50 Percent Rule," an entity that is not explicitly named on the SDN list is still considered blocked if it is:

Accepted Answer

owned 50 percent or more, directly or indirectly, in the aggregate by one or more blocked persons.

Answer

controlled, but not owned, by one or more blocked persons.

Answer

publicly known to conduct at least 50 percent of its business with blocked persons.

Answer

located in a country where 50 percent of the government officials are sanctioned.

Question 3

Which of the following is a primary red flag for sanctions evasion through deceptive shipping practices in the maritime industry?

Accepted Answer

Disabling the vessel's AIS transponder for extended periods, especially when near a sanctioned jurisdiction.

Answer

A vessel using a direct and economically efficient shipping route.

Answer

Consistently reporting a vessel's location via its Automatic Identification System (AIS).

Answer

Maintaining the same vessel flag and ownership for several years.

Question 4

A U.S. financial institution receives a payment instruction between two non-U.S., non-sanctioned entities. However, the institution determines the underlying transaction is for services in a comprehensively sanctioned country (e.g., Iran), which is a prohibited activity for U.S. persons. Since no party to the transaction is on the SDN list, what is the proper course of action?

Accepted Answer

Reject the transaction and return the funds to the originator.

Answer

Block the funds in an interest-bearing account.

Answer

Process the transaction since no SDNs are involved.

Answer

Seize the funds and await instructions from law enforcement.

Question 5

Which of the following best describes a comprehensive sanctions program, such as those the U.S. has imposed on North Korea and Cuba?

Accepted Answer

Broad prohibitions on trade, financial transactions, and other dealings with an entire country or geographic region.

Answer

Sanctions that target only specific individuals and entities for activities like terrorism or narcotics trafficking.

Answer

Sanctions that prohibit only the export of defense-related articles and services.

Answer

A requirement for financial institutions to conduct enhanced due diligence on all transactions with a country.

Question 6

A global bank must build its sanctions compliance program to screen against lists from multiple authorities. Which of the following lists is issued by a supranational body, whose resolutions are generally considered binding on all its member states?

Accepted Answer

The United Nations Security Council (UNSC) Consolidated Sanctions List.

Answer

The United Kingdom's HM Treasury Consolidated List.

Answer

The United States' OFAC Specially Designated Nationals (SDN) List.

Answer

The European Union's Consolidated Financial Sanctions List.