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Certified Global Sanction Specialist (CGSS) Chapter 5 Already Graded A+

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5-1 Generally, what is involved in a sanction’s investigation? 5-1 A sanctions investigation is the process of obtaining, evaluating, recording, and storing information about an individual or legal entity with whom one is conducting business, in response to an alert indicating a possible sanctions violation. Investigations often begin with simple checks before progressing to further investigation such as account review, customer outreach, and possible escalation to the compliance function. 5-2 As one of the first steps in an investigation, what is a simple check? 5-2 Simple checks are one of the first steps in an investigation. Essentially, they are the initial actions taken to discount or confirm a sanctions link. An example of a simple check includes comparing data about a sanction target with a firm's Know Your Customer (KYC) data. 5-3 What are the five steps comprising a typical sanctions investigation? 5-3 Although the details of every investigation are unique, most investigations share a common process. Case investigation teams and alert management teams often use a five-step decision tree to determine which alerts can reasonably be discounted and which alerts warrant an investigation: 1. Determine whether a sanctions restriction applies to the case under investigation. 2. Determine what types of restrictions the applicable sanctions impose. 3. Determine whether the sanctions that might apply have actually been violated. 4. Determine how the sanctions violation occurred. 5. Record and document the findings.


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