Certified Global Sanction Specialist (CGSS) Chapter 2 Download To Score An A+
2-1 What is sanctions evasion? 2-1 Sanctions evasion is the deliberate attempt to remove or conceal the involvement of sanctioned places, entities, or individuals in a transaction or series of transactions. When sanctions evasion is successful, a business that would have been flagged, taxed, restricted, or prohibited is allowed to proceed unhindered. 2-2 Define counterparty and explain how an institution establishes a counterparty relationship. 2-2 A counterparty is the other side of a transaction—the seller where the customer is the buyer, or vice versa. An institution establishes counterparty relationships with other third-party participants in a transaction for an established customer. Another way to establish a counterparty relationship is to provide a service to an individual or entity that has not established a full customer relationship. Such a relationship usually exists only for the life of the transaction itself. 2-3 Explain why the customer relationship, including understanding the customer's geographic footprint, is so important to a firm's sanctions compliance program. 2-3 The customer relationship should be the primary defense against sanctions evasion. It is important to fully understand the nature of the customer, the businesses the customer is engaged in, the structure of the company and the individuals behind it, and where and with whom the company does business. With this knowledge, an institution is better armed to detect any activity that does not have a valid business purpose and does not make sense for the customer. A key risk area related to customers is jurisdiction or geography. It's important to understand a customer's geo- graphic footprint, e.g., information about individuals such as: •Nationality (current and former)
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