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2026 CGSS Study Materials | Reliable CGSS: Certified Global Sanctions Specialist 100% Pass

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ACAMS Certified Global Sanctions Specialist Sample Questions (Q34-Q39):

NEW QUESTION # 34
Which directs the Office of Foreign Assets Control to list non-US persons as Specially Designated Nationals?

A. UN Security Council Resolutions
B. Executive Orders issued by the US President
C. Sectoral Sanctions Identifications issued by the US Treasury Department
D. Financial Action Task Force Recommendations

Answer: B

Explanation:
OFAC designations-including designating non-US persons-are authorized through Executive Orders (EOs) issued by the President under statutory authority such as IEEPA or the Trading With the Enemy Act. Executive Orders define which categories of persons or entities may be designated and direct OFAC to act.
Sectoral Sanctions Identifications relate to sectoral sanctions, not full SDN designation. FATF recommendations are global AML standards, not OFAC authorities. UN resolutions may influence US sanctions but are not the legal authority directing SDN listings.
Reference:
Executive Orders as legal authority for OFAC SDN designations.
Relationship between US statutory authority and OFAC implementation.

NEW QUESTION # 35
Your obligation to report to OFSI is in addition to any other non-financial sanctions reporting obligations you may have and that includes the following except?

A. Reporting required by your regulator
B. Submitting Suspicious Activity Reports (SARs) to the National Crime Agency (NCA) under the Proceeds of Crime Act 2002.
C. Report under section 19 of the Terrorism Act 2000.
D. Sunbmisson of designations made under ATCSA 2001
E. Report under the OFSI Data Protection Act 1998

Answer: D,E

NEW QUESTION # 36
Courts agree that attorneys' inquiry into the legal and factual basis of their claims need only be reasonable under the circumstances.
Which of the following relates to this?

A. Chris & Todd, Inc. v. Arkansas Dep't of Fin. & Admin., 125 F.R.D. 491, 494 (E.D. Ark. 1989) Sanctions imposed upon the attorney who discussed general content of amended complaint with clients prior to filing but did not inform clients of the exact wording of new allegations, which proved to be false.
B. Wigod v. Chicago Mercantile Exch., 981 F.2d 1510, 1523 (7th Cir. 1992) - Upholding sanctions award against plaintiff's attorney who failed to interview attorneys who represented the plaintiff in related proceedings and other available witnesses.
C. Rodriguez v. Local 112, Int'l Fed'n of Technical Eng'rs, No. Civ. 870142, 1989 U.S. Dist. LEXIS 9071, at *15 (D. Mass. Aug. 3, 1989) - Documents refuting allegations of discrimination complaint available from the state agency.
D. Vernon v. Port Authority of N.Y., 95 Civ. 4594 (PKL), 2003 U.S. Dist. LEXIS 9566, at *17-18 (S.D.N.Y. June 6, 2003) - Declining to award sanctions on the attorney for misstating status of discovery record where the attorney was new to the case, prior attorney's files had been destroyed, and information was not apparent from the record.
E. Zenith Elecs. Corp. v. Exzec, Inc., No. 93 C 5041, 1997 U.S. Dist. LEXIS 20762, at *38-41 (N.D. Ill. Dec. 24, 1997) - Use of "information and belief" pleading not sanctionable at early stages of litigation where facts are complex.

Answer: D,E

NEW QUESTION # 37
A financial institution's decision to adjust the degree of sensitivity of a screening tool should be based on its transaction volume and:

A. personnel training.
B. number of staff.
C. management commitment.
D. risk assessment.

Answer: D

Explanation:
Sanctions and Compliance Domains state that screening calibration must be tied directly to a financial institution's sanctions risk assessment, which evaluates products, customer base, geography, delivery channels, and transaction volume. Sensitivity adjustments must be justified by an institution's assessed sanctions exposure.
Staff levels or training do not determine screening thresholds; these are operational considerations. Management commitment supports governance but does not form the technical basis for calibration decisions.
Reference:
Screening calibration tied to sanctions risk assessments.
Threshold adjustments must reflect actual sanctions exposure and transaction characteristics.

NEW QUESTION # 38
When are the economic sanctions more likely to attain symbolic objectives?

A. When the sender is independent
B. When sender and target both are independent
C. When the target is independent
D. When the target is more dependent on the sender
E. When the sender is more dependent on the target

Answer: E

NEW QUESTION # 39
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