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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.

Question 1

A screening system generates an alert matching a customer's name to an SDN entry. The names are identical, but the date of birth and nationality differ. The analyst should:

  1. Dismiss immediately as the secondary identifiers do not match
  2. Investigate further using all available identifiers to determine if it's a true match
  3. Block the account immediately regardless of other identifiers
  4. Request OFAC confirmation before taking any action
Show answer & explanation

Correct answer: B - Investigate further using all available identifiers to determine if it's a true match

Question 2

A global bank operates in the US, EU, and UK. It identifies a customer designated on the UK sanctions list but NOT on the OFAC SDN List or EU Consolidated List. The customer maintains accounts in all three jurisdictions. How should the bank respond?

  1. Freeze only the UK accounts and report to UK authorities while maintaining normal operations for US and EU accounts without additional review
  2. Freeze the UK accounts, conduct enhanced due diligence on all accounts, and assess whether any UK nexus exists for the US and EU accounts
  3. Immediately close all accounts globally and file suspicious activity reports in all three jurisdictions regardless of local requirements
  4. Continue normal operations in all jurisdictions while filing a defensive report only with UK authorities since other jurisdictions lack designation
Show answer & explanation

Correct answer: B - Freeze the UK accounts, conduct enhanced due diligence on all accounts, and assess whether any UK nexus exists for the US and EU accounts

Question 3

A compliance officer discovers that a customer's beneficial owner is a trust with a designated person as the settlor and beneficiary, but with an independent trustee controlling the assets. Under the OFAC 50% Rule:

  1. The trust assets are not blocked because the trustee controls them
  2. The trust assets are likely blocked due to the designated person's beneficial interest
  3. Trusts are exempt from the 50% Rule
  4. Only the trust income is blocked, not the principal
Show answer & explanation

Correct answer: B - The trust assets are likely blocked due to the designated person's beneficial interest

Question 4

A European electronics manufacturer receives an order from a Turkish company for high-technology components that are controlled under export regulations. The Turkish company requests that the goods be shipped to a port in Turkey known as a transshipment hub. Enhanced due diligence reveals that the Turkish company's beneficial owner has business connections to Iran. The manufacturer should:

  1. Ship the goods because Turkey is not sanctioned
  2. Refuse the order and investigate potential Iran connection
  3. Ship the goods but require an end-user certificate
  4. Only be concerned if the goods are on the SDN List
Show answer & explanation

Correct answer: B - Refuse the order and investigate potential Iran connection

Question 5

A bank discovers that a sanctions screening alert was incorrectly dispositioned as a false positive six months ago, and the customer is actually an SDN. During the six months, 15 transactions were processed. The bank's due diligence failure is:

  1. Minimal because the screening system initially identified the customer correctly and the error was in human judgment
  2. Significant, as it represents a breakdown in internal controls at the alert handling stage, potentially resulting in 15 sanctions violations
  3. Limited to procedural deficiencies since the bank maintained proper documentation of the alert disposition decision
  4. Moderate because the bank can demonstrate good faith reliance on its established screening procedures and staff training
Show answer & explanation

Correct answer: B - Significant, as it represents a breakdown in internal controls at the alert handling stage, potentially resulting in 15 sanctions violations

Question 6

A compliance team identifies that an SDN's spouse holds 35% of a company, and the SDN holds 20% directly. The spouse is NOT designated. Under OFAC's 50% Rule:

  1. The company is blocked because combined family ownership is 55%
  2. Only the SDN's 20% is relevant; spouse ownership is not aggregated unless the spouse is also designated
  3. Family members' ownership is always aggregated under the 50% Rule
  4. The company is automatically blocked because the SDN has any ownership stake
Show answer & explanation

Correct answer: B - Only the SDN's 20% is relevant; spouse ownership is not aggregated unless the spouse is also designated

Question 7

An investigation reveals the following structure: SDN-A is the 100% owner of a Trust in the Cayman Islands. The Trustee holds 49% of Company-X registered in the BVI. Company-X holds 100% of Company-Y in Dubai. Company-Y maintains a bank account at a European bank. The European bank should:

  1. Continue the banking relationship as Company-Y is several layers removed from the SDN
  2. Trace the beneficial ownership chain to determine SDN-A controls Company-Y and block the account
  3. Only freeze the trust assets, not Company-Y's account
  4. Wait for the SDN to be formally linked to Company-Y in OFAC guidance
Show answer & explanation

Correct answer: B - Trace the beneficial ownership chain to determine SDN-A controls Company-Y and block the account

Question 8

An entity named 'Bank Melli Iran' appears on the OFAC SDN List. A customer's payment references 'BMI Tehran.' A screening system relying only on name matching would:

  1. Detect this match easily
  2. Potentially miss this match due to abbreviation differences
  3. Always detect abbreviations automatically
  4. Flag all three-letter acronyms as matches
Show answer & explanation

Correct answer: B - Potentially miss this match due to abbreviation differences

Question 9

A compliance officer discovers that the bank inadvertently processed 50 transactions involving a blocked person over 6 months due to a screening system failure. The BEST course of action is:

  1. Correct the system error and move on without reporting
  2. File a Voluntary Self-Disclosure with OFAC and implement corrective actions
  3. Report only the most recent transaction to OFAC
  4. Wait to see if OFAC discovers the violations on its own
Show answer & explanation

Correct answer: B - File a Voluntary Self-Disclosure with OFAC and implement corrective actions

Question 10

A sanctions investigation reveals that a customer was designated on the SDN List 6 months ago, but the bank's screening system failed to detect the match due to a data quality issue. The bank has processed 50 transactions for the customer since the designation. The bank should:

  1. Fix the data issue and monitor going forward
  2. Block remaining property, conduct lookback review, file required reports, and consider Voluntary Self-Disclosure
  3. Only block the most recent transaction
  4. Report only transactions above the filing threshold
Show answer & explanation

Correct answer: B - Block remaining property, conduct lookback review, file required reports, and consider Voluntary Self-Disclosure

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