[2026] New CGSS exam Free Sample Questions to Practice
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The ACAMS CGSS exam is designed to be comprehensive and challenging, covering a range of topics related to sanctions compliance. It is divided into several sections, including a section on regulations and legal frameworks, a section on sanctions risk assessment and management, and a section on the development and implementation of sanctions compliance programs.
NEW QUESTION # 59
Which are common channels used to circumvent sanctions? (Select Three.)
- A. Trade finance
- B. Shell companies
- C. Online banking
- D. Retail banking
- E. Corporate banking
- F. Correspondent banking
Answer: A,B,F
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 # 60
Asset freezing legislation generally permits a person to make which of the following payments into a frozen account without the need for a license from OFSI, so long as those funds are frozen after being paid in:
- A. Any payments due to a designated person under contracts, agreement or obligations that were concluded or arose before the date the person became sanctioned
- B. Any interest or earnings that is not on the account
- C. Any payment from an unknown source
- D. Any interest or earnings on the account
Answer: A,D
NEW QUESTION # 61
Under an asset freeze it is generally prohibited to do the following except?
- A. make funds or economic resources available, directly to, or for the benefit of, a designated person
- B. deal with the frozen funds or economic resources, belonging to or owned, held or controlled by a designated person
- C. engage in actions that, directly or indirectly, circumvent the financial sanctions prohibitions
- D. None of the above
- E. make funds or economic resources available, indirectly, to, or for the benefit of, a designated person
Answer: D
NEW QUESTION # 62
The US and North Korea have been locked in a state of belligerency since June 1950. Throughout that period, American and North Korean troops have faced each other across the demilitarised zone, sometimes engaging in brief skirmishes.
The US imposed a blanket of near-total economic sanctions, which include:
- A. Sharing the same customs act
- B. Sanctions are only subject to property against DPRK
- C. International security and development cooperation act
- D. Trading of goods act
- E. Trading with the enemy act
Answer: C,E
NEW QUESTION # 63
How do you define an "Indicator" in Humanitarian indicators and data sources:
- A. A variable of data sources
- B. A variable that provides strength to a proposition
- C. Measurable variable and that which sheds light on another variable of interest
- D. Voting procedure for a sanction to be proposed
- E. Proposition provided by the UN
Answer: C
NEW QUESTION # 64
Under what objective does the Security Council has imposed sanctions to facilitate the return of refugees and displaced persons in the Former Republic of Yugoslavia (FRY)?
- A. Promoting good governance
- B. Ending a rebellion, invasion, or external interference
- C. Facilitating the exercise or protection of human rights
- D. Facilitating the establishment and consolidation of peace
- E. Bringing about disarmament or arms control
Answer: C
NEW QUESTION # 65
The EU Blocking Regulation prohibits an EU person or company from complying with:
- A. dual-use goods licensing requirements.
- B. country specific sanctions not listed in the Annex.
- C. sanctions legislation.
- D. US secondary sanctions.
Answer: D
Explanation:
The EU Blocking Regulation prevents EU persons and companies from complying with certain foreign extraterritorial sanctions, specifically those identified in its Annex. These are primarily US secondary sanctions. The Regulation is designed to protect EU entities from the extraterritorial application of non-EU sanctions. It does not prohibit compliance with EU sanctions or dual-use laws. Only the specific foreign sanctions laws listed in the Annex are prohibited for compliance.
Reference:
EU Blocking Regulation scope.
Restrictions on complying with foreign extraterritorial sanctions listed in the Annex.
Distinction between EU law compliance and non-EU secondary sanctions.
NEW QUESTION # 66
The Council noted that, in order to ensure that Iraq did not increase its capacity to re-arm, states were required to continue to prevent the sale, supply, or provision to Iraq.
Which of the following items is NOT included in this?
- A. nuclear weapons and activities such as nuclear testing
- B. personnel or training or technical support services relating to arms and related material, chemical and biological weapons, ballistic missiles with a range greater than 150km, and nuclear weapons
- C. arms and related material
- D. items relating to chemical and biological weapons, ballistic missiles with a range greater than 150km, and nuclear weapons
- E. technology relating to arms and related material, chemical and biological weapons, ballistic missiles with a range greater than 150km, and nuclear weapons
Answer: A
NEW QUESTION # 67
"Al-Falah Company", registered in Dubai, wants to open an account at a financial institution. Through due diligence, the compliance team finds out that "El-Fallah Investments", based in Iraq, is under UN sanctions for facilitating terrorism financing. The listed Chief Executive Officer (CEO) of the sanctioned entity is not the same as the CEO of the potential client. How should the compliance team proceed?
- A. The potential client should not be onboarded and the regulator must be notified.
- B. There is insufficient reason to escalate the case for further investigation and the client can be onboarded.
- C. There are enough similarities to pursue further investigation before a decision can be made.
- D. This is a near match, thus the client should only be onboarded depending on the financial institution's risk appetite.
Answer: C
Explanation:
Sanctions and Compliance Domains state that when entities share similar names, regions, or other characteristics with a sanctioned party - even when executive leadership differs - the institution must perform enhanced due diligence to rule out affiliation, ownership, or control links.
The similarity in names ("Al-Falah" vs. "El-Fallah"), geographic proximity, and the involvement of UN-sanctioned terrorism-related activity require deeper investigation. Compliance teams must confirm corporate records, ownership structure, purpose, and possible indirect connections before making a determination.
Automatic rejection is premature without evidence. Onboarding without further investigation is inappropriate.
Reference:
Name similarity and geographic proximity as sanctions escalation triggers.
Requirements for enhanced due diligence when possible indirect links exist.
NEW QUESTION # 68
Where is OFAC located?
- A. Iraq
- B. Washington DC
- C. United Kingdom
- D. India
- E. The Islamic Republic of Pakistan
Answer: B
NEW QUESTION # 69
A financial institution provides banking services to cryptocurrency exchanges. One of their clients is a cryptocurrency exchange that specializes in offering privacy coins and provision of a tumbler/mixer service. Which sanctions-related risk should be considered?
- A. A tumbler/mixer service mingles cryptocurrency making it difficult to perform effective sanctions screening.
- B. Privacy coins provide anonymity on the blockchain but can be screened for sanctions compliance by the exchange.
- C. The cryptocurrency exchange can rely on the financial institution to perform due diligence on their clients.
- D. Privacy coins provide enhanced anonymity features that negate the requirements for sanctions screening.
Answer: A
Explanation:
Sanctions and Compliance Domains emphasize that sanctions screening depends on traceable identifiers, transparent transaction histories, and clear counterparties. Privacy coins and mixers/tumblers significantly obscure blockchain transaction trails.
A tumbler or mixer intentionally blends cryptocurrency from multiple sources, making it extremely difficult to determine the origin of funds, the identities of transacting parties, or any links to sanctioned entities. This creates a high sanctions-related risk because sanctioned actors or jurisdictions may exploit these services to disguise involvement.
Privacy coins alone pose risk due to anonymity, but the mixer/tumbler function specifically disrupts sanctions screening capabilities. Financial institutions and exchanges cannot rely on upstream partners to conduct due diligence.
Reference from Sanctions and Compliance Domains:
Risks of anonymity-enhancing technologies (AETs) in sanctions compliance.
Screening limitations created by mixers/tumblers and privacy-preserving blockchain tools.
Guidance highlighting elevated sanctions risks in digital asset transactions lacking traceability.
NEW QUESTION # 70
What is the similarity between the the 1993 rule and 1983 Rule 11?
- A. Affirmative duty to investigate
- B. Frivolousness test
- C. Contents of the certificate
- D. Objective Test
- E. Required statements
Answer: A
NEW QUESTION # 71
Which of the following could affect the pursuit and implementation of incentive policies?
- A. Partisan struggle
- B. National Struggle
- C. Individual Struggle
- D. Factional struggle
- E. Institutional struggle
Answer: A,D,E
NEW QUESTION # 72
Which exogenous events sporadically derailed the changes in general of punishing Cuba?
- A. Cuban air force shooting down US aircraft
- B. Capture by Iranian-backed terrorists of US hostages
- C. Competition over Florida's electoral votes in the 1992 presidential election
- D. Democratic presidential nomination
- E. Burglar arrest at the Democratic National Committee office
Answer: A,C
NEW QUESTION # 73
Which industry client poses the highest sanctions risks to a financial institution that offers acquiring services?
- A. Pharmacy
- B. Digital currency provider
- C. Aircraft maintenance company
- D. Retail company
Answer: B
Explanation:
Digital currency providers pose a heightened sanctions risk due to:
* exposure to anonymity-enhancing technologies,
* increased risk of being used for sanctions evasion and illicit finance,
* difficulty tracing the ultimate beneficial owner or origin of funds, and
* vulnerabilities related to mixers, unhosted wallets, and cross-border platforms.
Pharmacies and retail companies generally present lower sanctions risk. Aircraft maintenance companies can pose some risk depending on jurisdictions served, but digital currency firms are consistently recognized as the highest-risk sector for sanctions exposure.
Reference:
Sanctions risk characteristics of virtual asset providers.
High-risk industry designation due to anonymous and cross-border value transfer.
NEW QUESTION # 74
A US financial institution finds a customer is listed under the Specially Designated Nationals List in the last Office of Foreign Assets Control (OFAC) update. The customer's accounts are immediately blocked. How quickly should the financial institution report this action to OFAC?
- A. 10 business days
- B. 14 business days
- C. 13 business days
- D. 11 business days
Answer: A
Explanation:
OFAC requires that reports of newly blocked property be submitted within 10 business days of the blocking action. The institution must provide full details of the blocked property and the sanctioned party. Any timeline other than 10 business days fails to meet OFAC's regulatory reporting requirements.
Reference:
OFAC reporting rule for blocked property within 10 business days.
NEW QUESTION # 75
A person designated by the Office of Foreign Assets Control (OFAC) as a Specially Designated National (SDN) sets up a company in a tax haven country to receive income from a consultancy business. Which is correct with respect to the company?
- A. It can transact freely in USD through a bank account held with a non-US Bank.
- B. It is not subject to OFAC sanctions
- C. It cannot transact through a US Bank, as it is owned by an SDN.
- D. It cannot be sanctioned by OFAC because it is set up in a tax haven country.
Answer: C
Explanation:
Under OFAC's 50 Percent Rule, any entity owned 50% or more by one or more SDNs is considered automatically blocked, even if it is not explicitly listed. The jurisdiction of incorporation (e.g., tax haven) does not exempt the entity from OFAC sanctions.
Because the SDN owns the company, the entity is also subject to OFAC prohibitions and cannot transact through the US financial system, including any USD-clearing banks, whether located inside or outside the United States.
Options B, C, and D are incorrect because OFAC sanctions apply regardless of where the company is registered and because USD transactions create a US nexus.
Reference:
OFAC 50 Percent Rule on ownership and blocking.
Prohibitions on US financial institutions processing transactions involving SDNs or SDN-owned entities.
NEW QUESTION # 76
Asset freezing legislation generally permits a person to make the following payments into a frozen account without the need for a license from OFSI, except:
- A. To credit a frozen account with payments from a third-person provided that the incoming funds are also frozen
- B. To make funds or economic resources available for the benefit of a designated person
- C. To make payments under agreement or obligations
- D. To operate with obligations that were concluded or arose before the date the person became sanctioned
- E. To make any payments due to a designated person under contracts
Answer: B
NEW QUESTION # 77
What caused the de-risking of banks for humanitarian sanctions?
- A. Insurance and safety
- B. Hurdle during online payments
- C. Civil not allowing imports to their country
- D. UNs disapproval
- E. United States disapproval
Answer: A,B
NEW QUESTION # 78
When effectiveness and externalities do not encourage the use of incentives what can happen?
- A. The trade-off between political externalities/effectiveness can create provocative dilemmas
- B. The relative effectiveness of incentives decreases
- C. The economic incentives will be preferred over economic threats
- D. This can affect the effectiveness of the economic statecraft
- E. It can punish or reward particular policies
Answer: A
NEW QUESTION # 79
All of the following are functions of the HM Treasury (Office of Financial Sanctions Implementation) except?
- A. UK's competent authority for implementing financial sanctions
- B. Negotiates all international sanctions
- C. Makes designations under UK domestic regimes
- D. Can impose monetary penalties
Answer: A,C,D
NEW QUESTION # 80
The fall of the Soviet Union shifted the policy of Washington. Shambaugh stated that there was a strong tendency among Chinese officials and scholars, in general, to view the US as:
- A. A violent and dominant force that is pushing its economic and military strength across the globe.
- B. A revisionist movement whose declared purpose is to uphold the authority of Chinese leaders.
- C. A friendly nation that casts the economic and military strength across the globe.
- D. A revisionist power whose stated aim is to challenge the plausibility of Chinese leaders and to transform the nature of Chinese politics.
Answer: A,D
NEW QUESTION # 81
What was the immediate goal of the 661 Iraqi international sanctions?
- A. Power Iraq with nuclear, chemical, and biological weapons.
- B. Establishment of a Compensation Commission to handle requests for reparations resulting from the Gulf War.
- C. Ensure that Iraq's withdrawal from Kuwait is stopped.
- D. None of the above
- E. Ensure the removal of Iraq from Kuwait.
Answer: E
NEW QUESTION # 82
In the late spring of 1998, the use or threat of sanctions by the US. Washington and its European partners announced additional steps of economic denial in a collective effort to discourage the escalation of which military force?
- A. Serbian military
- B. German military
- C. Syrian military
- D. Chinese military
- E. Japanese military
Answer: A
NEW QUESTION # 83
Why threatening to change the exchange pattern in an existing economic relationship is often insufficient to guarantee the power of negotiation between states?
- A. It may impact the raw material needed for manufacturing products.
- B. If an exchange is taking place between two rational economic actors, then the terms of exchange can be assumed to be Pareto optimal
- C. It will domestically impact the sender economy
- D. The sender can derive political leverage from the target's dependence on the gains from a trading relationship
- E. The sender must be willing to sacrifice some of its gains from trade
Answer: B,D,E
NEW QUESTION # 84
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To prepare for the ACAMS CGSS exam, candidates can take advantage of a range of study materials and training resources, including online courses, study guides, and practice exams. These resources are designed to help candidates develop a deep understanding of the topics covered on the exam and to prepare them for the rigors of the certification process.
ACAMS CGSS (Certified Global Sanctions Specialist) exam is a certification program designed to help professionals in the financial industry enhance their knowledge and skills in the area of global sanctions compliance. Certified Global Sanctions Specialist certification is recognized worldwide and is highly valued by employers in the financial industry.
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