Practice Test Geeks(RCMS) Registered Compliance Management Specialist Certification Practice Test
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Sanctions & Trade Compliance Flashcards

7 cards from real RCMS practice questions. Tap to flip, then mark Knew It or Still Learning — missed cards come back until you master them.

Read the first 7 Sanctions & Trade Compliance flashcards as text

  1. What is the significance of the 'knowledge' standard in the EAR's 'red flags' doctrine for export compliance?

    Answer: Exporters who ignore obvious warning signs are deemed to have knowledge of illegal end-use

    Under EAR, 'knowledge' includes willful blindness — if an exporter ignores red flags suggesting illegal end-use, they are treated as having known of the violation.

  2. Which OFAC sanctions program uses a 'sectoral' approach that restricts specific financial transactions rather than imposing comprehensive country-wide prohibitions?

    Answer: Russia/Ukraine sanctions (Directives under E.O. 13662)

    OFAC's Russia/Ukraine-related Directives impose sectoral sanctions targeting specific transaction types (e.g., new debt over certain maturities) for designated sectors, rather than blocking all dealings.

  3. A Voluntary Self-Disclosure (VSD) submitted to OFAC can reduce a civil monetary penalty by what maximum percentage under OFAC's enforcement guidelines?

    Answer: 50%

    OFAC's enforcement guidelines provide that a timely, complete, and accurate VSD can reduce the base civil monetary penalty by up to 50%.

  4. Under ITAR, which category of controlled articles requires the most stringent export controls due to their direct application in space launch vehicles and strategic missiles?

    Answer: USML Category IV (Launch Vehicles, Guided Missiles, Ballistic Missiles)

    USML Category IV covers launch vehicles, guided missiles, ballistic missiles, rockets, torpedoes, bombs, and mines — among the most sensitive ITAR-controlled items.

  5. When assessing sanctions compliance risk for a new correspondent banking relationship, which factor is considered highest risk?

    Answer: A correspondent whose customer base is concentrated in OFAC-sanctioned jurisdictions

    A correspondent bank whose customer base is heavily concentrated in sanctioned jurisdictions poses the highest risk, as transactions may involve prohibited parties routed through the relationship.

  6. What distinguishes a 'general license' from a 'specific license' in OFAC's sanctions framework?

    Answer: General licenses authorize categories of transactions for all eligible parties; specific licenses authorize particular transactions for named parties

    General licenses are published in the Code of Federal Regulations and authorize entire categories of transactions without requiring individual application; specific licenses are granted to named applicants for particular transactions.

  7. A compliance audit reveals that a U.S. company's foreign parent directed it to refuse business with Israeli entities in order to comply with an Arab League boycott. What U.S. law does this violate?

    Answer: Export Administration Act anti-boycott provisions (EAR Part 760)

    EAR Part 760 prohibits U.S. persons from participating in or supporting unsanctioned foreign boycotts, including the Arab League boycott of Israel.