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ACAMS Certified Global Sanctions Specialist Sample Questions (Q73-Q78):

NEW QUESTION # 73
Which are common channels used to circumvent sanctions? (Select Three.)

A. Correspondent banking
B. Shell companies
C. Online banking
D. Trade finance
E. Corporate banking
F. Retail banking

Answer: A,B,D

Explanation:
Sanctions evasion commonly occurs through:
* Trade finance - manipulating bills of lading, transshipment, falsified documents.
* Correspondent banking - indirect access to the financial system through other banks.
* Shell companies - concealment of ownership, diversion of goods, and masking sanctioned parties.
Corporate, online, and retail banking may have risks but are not primary evasion channels highlighted in sanctions-evasion typologies.
Reference:
Sanctions evasion indicators involving trade, correspondent networks, and shell structures.
OFAC advisories on high-risk payment channels.

NEW QUESTION # 74
With which of the following procedural conditions EU should comply with for resorting to countermeasures?

A. Calling upon the third (target) State to cease the violation.
B. Calling upon the International justice of the law.
C. Notifying its intention to take resources.
D. Suggesting negotiations.
E. Respecting the principle of proportionality.

Answer: A,D,E

NEW QUESTION # 75
In which scenarios will the Office of Foreign Assets Control's 50% Rule apply to Entity C? (Select Three.)

A. Blocked Person X owns 50% of Entity A. Entity A owns 50% (1 share) of Entity C. Blocked Person X owns 1 share directly in Entity C.
B. Blocked Person X owns 50% of Entity A and 25% of Entity B. Entities A and B each own 25% of Entity C.
C. Blocked Person X owns 50% of Entity A and 50% of Entity B. Entities A and B own 25% of Entity C each.
D. Blocked Entity A owns 50% of Entity B. Entity B owns 50% of Entity C.
E. Blocked Entity A owns 49.99% of Entity B. Entity B owns 49.99% of Entity C.
F. Blocked Person X owns 50% (1 share) of Entity A. Entity A owns 50% (1 share) of Entity B. Entity B owns 50% (1 share) of Entity C.

Answer: A,D,F

Explanation:
The OFAC 50% Rule states:
* Any entity owned 50% or more - directly or indirectly - by an SDN or SDN-owned entity is itself automatically blocked.
* Ownership is cumulative through all tiers.
Apply the rule:
✔ A - Blocked Person X has direct + indirect ownership in Entity C exceeding 50% → Blocked.
✔ C - Ownership cascades: SDN → A → B → C; each at 50%. Result: Entity C is blocked.
✔ D - Blocked Entity A (>50%) → owns B (>50%) → owns C (>50%). All downstream entities are blocked.
Not blocked:
* B = 25% + 25% = 50% but SDN does not directly own A or B - the SDN owns A and B, but A and B each are not blocked themselves because ownership is not aggregated across separate entities unless they hold shares. Therefore, C is not blocked.
* E = Only 25% flows into Entity C.
* F = Neither ownership chain reaches 50%.
Reference:
OFAC 50% Rule on direct and indirect ownership.
OFAC guidance on cascading ownership and aggregation requirements.

NEW QUESTION # 76
According to OFSI, the asset freeze as a financial sanction generally involves the further steps, except:

A. Prohibited to make funds or economic resources available, directly or indirectly for a designated person
B. Prohibited to make funds or economic resources available, directly or indirectly for a benefit
C. Prohibited to deal with the frozen funds or economic resources
D. Changes in ownership of the frozen funds or economic resources
E. Prohibited to engage in actions that, directly or indirectly, circumvent the financial sanctions prohibitions

Answer: D

NEW QUESTION # 77
There are three types of PBE: isolation, pooling, and semi-separation. In which category of PBE do the two forms of actor give the same signal?

A. Non-pooling equilibria
B. None of the above
C. Semi-separating equilibria
D. pooling equilibria
E. Separating equilibria

Answer: D

NEW QUESTION # 78
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