Page 1 of 141
CSSBeta / Certified Sanctions Specialist (CSS) Exam
QUESTIONS AND VERIFIED ANSWERS WITH
RATIONALES JUST RELEASED
CSSBeta / Certified Sanctions Specialist (CSS) Exam
10 MOSTLY TESTED EXAM COVERAGE AREAS
1. Sanctions Regimes, Goals, Prohibitions and Effects — purpose of sanctions, restrictive
measures, asset freezes, trade restrictions, financial restrictions, sectoral sanctions, embargoes,
secondary sanctions, and consequences of sanctions violations.
2. Sanctions Imposers and Targets — United Nations, United States, OFAC, European Union,
United Kingdom, Canada and other national authorities; designated persons, entities, countries,
sectors and activities.
3. U.S. Sanctions and OFAC — OFAC programs, SDN List, blocked property, prohibited
transactions, general licenses, specific licenses, sanctions authorities, reporting, penalties and
compliance expectations.
4. EU, UK, UN and International Sanctions — differences between major sanctions regimes,
implementation, jurisdiction, asset freezes, travel restrictions, trade measures and international
cooperation.
5. Sanctions Evasion Typologies and Schemes — ownership concealment, false documentation,
intermediaries, front companies, transshipment, indirect payments, vessel changes, shell
companies and other evasion methods.
6. Risk-Based Sanctions Compliance Programs — governance, risk assessment, policies,
procedures, internal controls, management oversight, training, testing, auditing and continuous
improvement.
7. Due Diligence and Sanctions Screening — customer identification, beneficial ownership, list
screening, name matching, false positives, escalation, transaction screening and ongoing
monitoring.
8. Technology and Screening Systems — automated screening, data quality, fuzzy matching,
screening thresholds, system testing, alert management, recordkeeping and technology
controls.
9. Operational Issues and Sanctions Investigations — alert investigation, escalation,
documentation, internal investigations, suspicious activity indicators, transaction review and
decision-making.
10. Enforcement, Violations and Remediation — investigations, regulatory actions, civil and
criminal consequences, voluntary disclosure, root-cause analysis, corrective action and lessons
from enforcement cases.
1.
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A bank receives a payment involving a person listed on a sanctions list. What should the bank normally
do before processing the payment?
A. Process the payment and review it later
B. Ignore the name because the customer is existing
C. Stop or hold the transaction and follow applicable sanctions procedures
D. Ask the customer to choose another payment method
Answer: C
Rationale: A potential sanctions match requires review and appropriate controls before the transaction
is processed.
2.
What is the main purpose of economic sanctions imposed by governments against foreign persons or
activities?
A. To increase ordinary commercial competition
B. To influence behavior without necessarily using military force
C. To reduce all international trade
D. To replace every criminal law
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Answer: B
Rationale: Sanctions are commonly used as an economic and political tool to influence behavior.
3.
A company wants to understand whether a foreign customer presents sanctions risk before establishing
a business relationship. What should it perform?
A. Marketing research only
B. Sanctions due diligence
C. Employee satisfaction testing
D. Product pricing analysis
Answer: B
Rationale: Sanctions due diligence helps identify relevant parties, ownership, jurisdictions and sanctions
risks.
4.
Which organization administers and enforces many United States economic and trade sanctions
programs?
, Page 4 of 141
A. OFAC
B. NATO
C. WTO
D. IMF
Answer: A
Rationale: The U.S. Department of the Treasury's Office of Foreign Assets Control administers many U.S.
sanctions programs.
5.
A screening system generates a possible match because a customer's name resembles a listed person's
name. What should happen next?
A. Automatically reject the customer
B. Automatically approve the customer
C. Conduct additional review to determine whether the match is genuine
D. Delete the screening alert
Answer: C
Rationale: A possible match is not automatically a confirmed match and requires investigation.
CSSBeta / Certified Sanctions Specialist (CSS) Exam
QUESTIONS AND VERIFIED ANSWERS WITH
RATIONALES JUST RELEASED
CSSBeta / Certified Sanctions Specialist (CSS) Exam
10 MOSTLY TESTED EXAM COVERAGE AREAS
1. Sanctions Regimes, Goals, Prohibitions and Effects — purpose of sanctions, restrictive
measures, asset freezes, trade restrictions, financial restrictions, sectoral sanctions, embargoes,
secondary sanctions, and consequences of sanctions violations.
2. Sanctions Imposers and Targets — United Nations, United States, OFAC, European Union,
United Kingdom, Canada and other national authorities; designated persons, entities, countries,
sectors and activities.
3. U.S. Sanctions and OFAC — OFAC programs, SDN List, blocked property, prohibited
transactions, general licenses, specific licenses, sanctions authorities, reporting, penalties and
compliance expectations.
4. EU, UK, UN and International Sanctions — differences between major sanctions regimes,
implementation, jurisdiction, asset freezes, travel restrictions, trade measures and international
cooperation.
5. Sanctions Evasion Typologies and Schemes — ownership concealment, false documentation,
intermediaries, front companies, transshipment, indirect payments, vessel changes, shell
companies and other evasion methods.
6. Risk-Based Sanctions Compliance Programs — governance, risk assessment, policies,
procedures, internal controls, management oversight, training, testing, auditing and continuous
improvement.
7. Due Diligence and Sanctions Screening — customer identification, beneficial ownership, list
screening, name matching, false positives, escalation, transaction screening and ongoing
monitoring.
8. Technology and Screening Systems — automated screening, data quality, fuzzy matching,
screening thresholds, system testing, alert management, recordkeeping and technology
controls.
9. Operational Issues and Sanctions Investigations — alert investigation, escalation,
documentation, internal investigations, suspicious activity indicators, transaction review and
decision-making.
10. Enforcement, Violations and Remediation — investigations, regulatory actions, civil and
criminal consequences, voluntary disclosure, root-cause analysis, corrective action and lessons
from enforcement cases.
1.
, Page 2 of 141
A bank receives a payment involving a person listed on a sanctions list. What should the bank normally
do before processing the payment?
A. Process the payment and review it later
B. Ignore the name because the customer is existing
C. Stop or hold the transaction and follow applicable sanctions procedures
D. Ask the customer to choose another payment method
Answer: C
Rationale: A potential sanctions match requires review and appropriate controls before the transaction
is processed.
2.
What is the main purpose of economic sanctions imposed by governments against foreign persons or
activities?
A. To increase ordinary commercial competition
B. To influence behavior without necessarily using military force
C. To reduce all international trade
D. To replace every criminal law
, Page 3 of 141
Answer: B
Rationale: Sanctions are commonly used as an economic and political tool to influence behavior.
3.
A company wants to understand whether a foreign customer presents sanctions risk before establishing
a business relationship. What should it perform?
A. Marketing research only
B. Sanctions due diligence
C. Employee satisfaction testing
D. Product pricing analysis
Answer: B
Rationale: Sanctions due diligence helps identify relevant parties, ownership, jurisdictions and sanctions
risks.
4.
Which organization administers and enforces many United States economic and trade sanctions
programs?
, Page 4 of 141
A. OFAC
B. NATO
C. WTO
D. IMF
Answer: A
Rationale: The U.S. Department of the Treasury's Office of Foreign Assets Control administers many U.S.
sanctions programs.
5.
A screening system generates a possible match because a customer's name resembles a listed person's
name. What should happen next?
A. Automatically reject the customer
B. Automatically approve the customer
C. Conduct additional review to determine whether the match is genuine
D. Delete the screening alert
Answer: C
Rationale: A possible match is not automatically a confirmed match and requires investigation.
