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Free CGSS Practice Questions

10 free, exam-style Certified Global Sanctions Specialist (CGSS) practice questions with answers and explanations. No signup required. Work through them below, then take the full free CGSS practice test to study every exam domain.

The CGSS exam has 100 questions and runs 2 hours 55 minutes.

These 10 free CGSS questions are organized by exam domain, so you can see how each part of the Certified Global Sanctions Specialist blueprint is tested. Reveal the answer and explanation under each question.

Domain 1: Sanctions Compliance

Question 1

A regional bank is expanding from domestic retail banking into trade finance, maritime insurance, and virtual-asset clients. Under OFAC's compliance framework, what is the BEST program response?

  1. Refresh the risk assessment and align controls, testing, training, and oversight to the new risk profile
  2. Keep the existing program unchanged because SDN List screening remains the only sanctions control that matters
  3. Move sanctions review to the business lines and involve compliance only after a confirmed violation occurs
  4. Lower screening sensitivity to protect straight-through processing while adding a year-end policy memo
Show answer & explanation

Correct answer: A - Refresh the risk assessment and align controls, testing, training, and oversight to the new risk profile

Question 2

SDN-A owns 80% of Company-B, and Company-B owns 70% of Company-C. Under OFAC's current 50 Percent Rule methodology, how should Company-C be treated?

  1. Only Company-B is blocked because SDN-A has no direct registered shareholding in Company-C
  2. Company-C is blocked because blocked Company-B directly owns 50% or more of Company-C
  3. Company-C is not blocked because indirect ownership is tested only by multiplying all tiers
  4. Company-C is blocked only after OFAC separately publishes Company-C on the SDN List
Show answer & explanation

Correct answer: B - Company-C is blocked because blocked Company-B directly owns 50% or more of Company-C

Question 3

An EU bank with a US branch faces a transaction that may be prohibited by US Iran secondary sanctions but also raises EU Blocking Regulation concerns. What is the strongest first response?

  1. Prioritize US rules globally and disregard the EU Blocking Regulation whenever the regimes conflict
  2. Treat the US measures as irrelevant because secondary sanctions never affect non-US banking groups
  3. Escalate for counsel, map each jurisdictional nexus, and consider ring-fencing or authorization
  4. Process non-dollar payments and review only transactions that settle through a US correspondent
Show answer & explanation

Correct answer: C - Escalate for counsel, map each jurisdictional nexus, and consider ring-fencing or authorization

Question 4

A manufacturer has a general authorization for certain medical-device exports to Iran, but the intended hospital buyer is on the OFAC SDN List. What should the manufacturer do?

  1. Ship the devices because medical items are exempt from sanctions screening requirements
  2. Proceed if the payment avoids US dollars and the goods have no obvious dual-use features
  3. Use the general authorization and file a post-shipment notice after delivery is complete
  4. Stop unless the authorization covers that SDN or OFAC issues a specific license
Show answer & explanation

Correct answer: D - Stop unless the authorization covers that SDN or OFAC issues a specific license

Question 5

A UAE bank sends a US-dollar payment to a Turkish bank through a New York correspondent. The beneficiary is on the OFAC SDN List. What should the US correspondent do?

  1. Block the payment because the US clearing leg creates OFAC jurisdiction over blocked property
  2. Process it because the originator and beneficiary are foreign and the payment began outside the US
  3. Rely on the originating bank's sanctions certificate and keep the payment moving without review
  4. Reject it only if the beneficiary is also listed by the United Nations or the European Union
Show answer & explanation

Correct answer: A - Block the payment because the US clearing leg creates OFAC jurisdiction over blocked property

Domain 2: Sanctions Screening

Question 6

A tanker carrying petroleum from a high-risk region shows a three-day AIS gap near a known ship-to-ship transfer area, then resumes under a new name and flag. What should a sanctions analyst do?

  1. Treat the name change as sufficient evidence that the voyage is now unrelated to prior risk
  2. Escalate the case and review AIS history, ownership, cargo documents, and STS-transfer indicators
  3. Clear the transaction if the vessel's current flag state is not subject to comprehensive sanctions
  4. Hold the payment only if the vessel appears by name on the SDN List at the time of screening
Show answer & explanation

Correct answer: B - Escalate the case and review AIS history, ownership, cargo documents, and STS-transfer indicators

Question 7

A letter-of-credit file describes the goods as 'machine spare parts,' but the packing list identifies electronic control units for industrial centrifuges and a transshipment hub. What is the BEST response?

  1. Rely on the invoice description because the invoice is the primary payment document
  2. Process the credit after obtaining a general statement that the goods are non-military
  3. Escalate for dual-use, end-use, route, and sanctions review before honoring the credit
  4. Treat the mismatch as a normal logistics issue unless the applicant is already listed
Show answer & explanation

Correct answer: C - Escalate for dual-use, end-use, route, and sanctions review before honoring the credit

Question 8

Immediately after a shareholder is added to a sanctions list, a company restructures so the listed person's direct holding falls from 55% to 49%, with shares moved to a spouse and nominee director. What is the strongest interpretation?

  1. Clear the company because the listed person's recorded holding is now below the 50% threshold
  2. Remove the company from review unless the same shareholder is still the legal majority owner
  3. Accept the transfers as valid if they appear in the local registry and are dated after listing
  4. Treat the timing and nominee structure as evasion red flags requiring ownership/control review
Show answer & explanation

Correct answer: D - Treat the timing and nominee structure as evasion red flags requiring ownership/control review

Question 9

A virtual-asset exchange sees a customer log in through a VPN associated with a sanctioned jurisdiction, then attempt a transfer to a wallet clustered with a listed digital-currency address. What should happen?

  1. Escalate, use blockchain analytics and geolocation, and restrict or block if nexus is confirmed
  2. Clear the transfer because only bank accounts and fiat payment messages can be blocked
  3. Process the transfer if that exact wallet address is not printed on the SDN List
  4. Ask the customer to disable the VPN and release the transfer after a short cooling-off period
Show answer & explanation

Correct answer: A - Escalate, use blockchain analytics and geolocation, and restrict or block if nexus is confirmed

Domain 3: Economic and Financial Sanctions Frameworks and Governance

Question 10

A sanctions risk assessment for a mid-sized bank is being redesigned. Which data set is most important to include?

  1. Only the number of sanctions alerts closed during the previous quarter, since alert volume drives risk scoring
  2. Customers, counterparties, products, services, geographies, transactions, and delivery channels
  3. Only the AML risk rating, because sanctions exposure is fully captured by the AML model
  4. The compliance team's staffing level, without customer, product, or geography analysis
Show answer & explanation

Correct answer: B - Customers, counterparties, products, services, geographies, transactions, and delivery channels

The rest of the CGSS blueprint

The CGSS exam also covers these domains. Drill them in the full free practice test:

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