CGSS Exam Questions and
Answers 100% Pass
What is Sanctions evasion? -✔✔Sanctions evasion is the deliberate act of avoiding or
circumventing sanctions to engage in prohibited activity without being caught.
How many types of Sanctions evasion? -✔✔Evasion can happen in two ways. External
evasion & Internal
External evasion happens when the customer or its third party violates sanctions.
Internal evasion happens when an organization's own staff members commit a
violation, such as stripping.
What is Stripping? -✔✔Stripping is the intentional removal or modification of
information from a record, either by a customer or by an organization's staff, to avoid
detection against a sanctions list.
What is External Stripping? -✔✔External stripping happens when a party outside the
organization removes information from incoming payment messages. This removal is a
deliberate attempt to hide the identity of the sender, recipient, or jurisdiction from
where a payment originated.
What is U-turn payments? -✔✔Stripping is associated with U-turn payments. A U-turn
is a transaction performed by a bank in one country for the benefit of a bank in another
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, country. A bank or other institution from country "A" sends a transaction through a
bank in country "B" using an offshore bank.
Which Sanctions are most often associated with U-turn payments? -✔✔By using a U-
turn payment, it is possible for sanctions evaders to defy the following:
• Targeted sanctions against specific countries
• Inclusion of various entities on the Specially Designated Nationals (SDN) list in an
effort to prevent terrorism
• Individuals named as SDNs.
How U-turn payments evade the sanction targets? -✔✔The evader simply removes the
relevant information from the payment message or wire.
What is the motivation behind striping? -✔✔Other cases are not based on patriotism,
solidarity, or political beliefs. In these cases, a person or entity may offer a bribe to
persuade the bank employee to alter or omit the relevant information. In some cases,
the bribe and the bank employee's personal beliefs may both play a role.
What is the causes of the noncompliance? -✔✔The root causes of the noncompliance
included:
• Inadequate policies to ensure proper reporting of suspicious activity
• Inconsistent policies and lack of transparency within the organization across
jurisdictions
• Failure of the organization to conduct due diligence on its own foreign offices, their
clients, and their practices
• Lack of a proper "compliance culture," which resulted in concerns raised by
compliance staff
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Answers 100% Pass
What is Sanctions evasion? -✔✔Sanctions evasion is the deliberate act of avoiding or
circumventing sanctions to engage in prohibited activity without being caught.
How many types of Sanctions evasion? -✔✔Evasion can happen in two ways. External
evasion & Internal
External evasion happens when the customer or its third party violates sanctions.
Internal evasion happens when an organization's own staff members commit a
violation, such as stripping.
What is Stripping? -✔✔Stripping is the intentional removal or modification of
information from a record, either by a customer or by an organization's staff, to avoid
detection against a sanctions list.
What is External Stripping? -✔✔External stripping happens when a party outside the
organization removes information from incoming payment messages. This removal is a
deliberate attempt to hide the identity of the sender, recipient, or jurisdiction from
where a payment originated.
What is U-turn payments? -✔✔Stripping is associated with U-turn payments. A U-turn
is a transaction performed by a bank in one country for the benefit of a bank in another
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, country. A bank or other institution from country "A" sends a transaction through a
bank in country "B" using an offshore bank.
Which Sanctions are most often associated with U-turn payments? -✔✔By using a U-
turn payment, it is possible for sanctions evaders to defy the following:
• Targeted sanctions against specific countries
• Inclusion of various entities on the Specially Designated Nationals (SDN) list in an
effort to prevent terrorism
• Individuals named as SDNs.
How U-turn payments evade the sanction targets? -✔✔The evader simply removes the
relevant information from the payment message or wire.
What is the motivation behind striping? -✔✔Other cases are not based on patriotism,
solidarity, or political beliefs. In these cases, a person or entity may offer a bribe to
persuade the bank employee to alter or omit the relevant information. In some cases,
the bribe and the bank employee's personal beliefs may both play a role.
What is the causes of the noncompliance? -✔✔The root causes of the noncompliance
included:
• Inadequate policies to ensure proper reporting of suspicious activity
• Inconsistent policies and lack of transparency within the organization across
jurisdictions
• Failure of the organization to conduct due diligence on its own foreign offices, their
clients, and their practices
• Lack of a proper "compliance culture," which resulted in concerns raised by
compliance staff
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