ACAMS Certified Global Sanctions Specialist (ACAMS CGSS) CGSS Exam Dumps: Updated Questions & Answers (November 2025)

Under the UN Charter, all United Nations member states are obligated to accept and carry out decisions of the UN Security Council. Sanctions and Compliance Domains emphasize that UN Security Council Resolutions issued under Chapter VII are binding on all UN members, not just Security Council members or targeted states.

Only member states have this obligation. Permanent membership or targeted status does not change the scope of obligation.

References from Sanctions and Compliance Domains:

UN Charter obligations for all Member States to implement Security Council Resolutions.

Binding nature of Chapter VII resolutions across all UN members.

Sanctions and Compliance Domains highlight that sanctioned individuals may attempt to evade restrictions by transferring assets, ownership rights, or operational control to family members or close associates. These transfers may appear legitimate but are often structured to conceal continuing beneficial ownership or influence.

Asset transfers to relatives or trusted associates are recognized as classic sanctions evasion red flags across EU and UK ownership and control guidance.

Opening bank accounts in non-aligned jurisdictions may create exposure, but the specific red flag of evasion is the movement of assets to associates. Changes in corporate strategy or reduced trading activity are not inherently indicative of sanctions evasion.

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 and Compliance Domains state that when a potential sanctions match occurs, the first step is to conduct a proper investigation to determine whether the alert is a true match or false positive. This includes obtaining additional identifiers such as addresses, IMO numbers, registration numbers, or corporate details.

Immediate rejection or reporting is only appropriate after confirming a true match. Premature rejection without verification violates due diligence expectations. Closing the customer account is not justified without confirmed sanctions involvement.

When a potential sanctions match is detected, the required first action is to determine whether the alert represents a true match or a false positive. This involves comparing identifiers, reviewing customer documentation, and gathering additional details.

CDD is important but is not the specific required action at the moment of match investigation. The priority is confirming whether the entity is indeed the sanctioned party.

Sanctions and Compliance Domains specify that sanctions screening must include all fields that contain names, identifiers, or descriptive information that could reveal a connection to a sanctioned party or jurisdiction. This includes:

• Remitter and beneficiary fields – Core parties to the transaction must always be screened.

• Agents, intermediaries, correspondent banks, and financial institutions – These fields often contain additional parties that may be sanctioned or present sanctions exposure.

• Free text fields – These can include narrative descriptions, vessel names, ports, goods, or locations that may represent sanctions risk.

Currency, value, dates, and internal references do not contain identifiers relevant to sanctions screening and therefore are not required screening fields.

Under OFAC’s 50 Percent Rule, any entity that is owned 50% or more—individually or in aggregate—by one or more Specially Designated Nationals (SDNs) is considered automatically blocked, even if not explicitly listed.

Financial institutions must treat such entities as if they are SDNs. Therefore, the account cannot be opened. Senior management approval cannot override OFAC regulations, and altering ownership to bypass sanctions is prohibited facilitation.

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.

UN sanctions are imposed by the UN Security Council as part of its mandate to maintain international peace and security. They are intended to influence behavior, prevent conflict, suppress terrorism, and stabilize global security conditions.

While asset freezes and travel bans are common measures (option D), they are examples, not the fundamental reason for imposing sanctions. Option C describes the overarching purpose.

The Wolfsberg Guidance identifies that effective sanctions screening depends on high-quality, risk-relevant reference data. Institutions must regularly review and remove outdated or irrelevant data to avoid generating unnecessary alerts and ensure screening outputs remain meaningful. Maintaining accurate and current data reduces noise and increases the productivity of alerts.

The Guidance also emphasizes that institutions may use “good guy lists” to reduce false positives, but these lists must be maintained in a controlled way to ensure they do not unintentionally suppress alerts that could indicate sanctions risk. Proper governance must accompany good-guy lists so that risk-relevant entities are not excluded from screening.

The Guidance does not support reducing thresholds to generate more alerts, nor does it promote removing low-risk parties without structured criteria. It also does not recommend manual jurisdiction-specific screening as a method of improving alert quality.

References from Sanctions and Compliance Domains:

Wolfsberg principles on management of reference data for sanctions screening.

Guidance on proper use and governance of “good guy lists.”

Recommendations for ensuring alerts remain relevant, accurate, and risk-based.