CSS Cheat Sheet 2026

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1. Which of the following is NOT typically a factor OFAC considers when determining whether a transaction is 'significant' for secondary sanctions purposes? → The nationality of the individual employees processing the transaction
2. Which OFAC sanctions program primarily targets the government of Venezuela and related parties? → Venezuela Sanctions Regulations (31 CFR Part 591)
3. Which designation criterion does OFAC use when targeting persons who provide material support to sanctioned parties? → Material support basis
4. Which U.S. regulatory expectation requires financial institutions to implement a risk-based sanctions compliance program? → OFAC's Framework for OFAC Compliance Commitments (2019)
5. What is a potential outcome of non-compliance with sanctions reporting? → Increased profits
6. How do automated screening systems benefit sanctions compliance? → By increasing profits
7. Which OFAC process allows a designated party to formally request removal from the SDN List? → Administrative Reconsideration or Delisting Request
8. What is the purpose of conducting a risk assessment in compliance? → To analyze company growth
9. Which of the following is generally NOT exempt from OFAC sanctions without a license? → Commercial sale of luxury goods to a comprehensively sanctioned country
10. Under OFAC's Compliance Commitments Framework, which element focuses on ensuring senior management understands and supports sanctions compliance? → Management Commitment
11. Which of the following is a common screening tool used for sanctions compliance? → OFAC SDN list and other sanctions lists
12. What is the purpose of OFAC's Non-SDN Consolidated Sanctions List (Non-SDN CSL)? → It lists entities subject to enhanced due diligence but not full asset blocking
13. What is the primary purpose of sanctions laws? → To restrict trade and transactions in response to violations
14. Which sanctions program specifically targets narcotics traffickers and was authorized by the Kingpin Act? → Foreign Narcotics Kingpin Sanctions program
15. Which document in a trade finance transaction is most useful for identifying the ultimate origin of goods in a sanctions context? → Certificate of Origin
16. Which of the following can be a consequence of violating sanctions? → Improved market share
17. Which technology tool is increasingly used by financial institutions to detect vessel-based sanctions evasion through analysis of maritime data? → Satellite-based AIS monitoring and vessel behavior analytics platforms
18. What is the first step in conducting due diligence for new business partners? → Requesting financial reports
19. What is the difference between economic sanctions and military sanctions? → Economic sanctions restrict trade and military sanctions restrict military actions
20. Which OFAC guidance document is most relevant for banks providing trade finance services involving potential sanctions exposure? → OFAC's Frequently Asked Questions (FAQs) on trade finance and letters of credit
21. When a specific OFAC license is obtained, the licensee's obligations include: → Complying with all conditions and recordkeeping requirements specified in the license
22. Under the '50 Percent Rule,' OFAC considers an entity to be blocked if sanctioned persons collectively own what minimum ownership stake? → 50 percent or more
23. What is the primary enforcement mechanism OFAC uses to implement secondary sanctions against foreign financial institutions? → Prohibiting or restricting the foreign institution's access to U.S. correspondent accounts
24. What is the purpose of reporting obligations in sanctions compliance? → To manage financial transactions
25. Why is verifying the ultimate beneficial owner (UBO) important in sanctions compliance? → To increase shareholder value
26. What is the role of enforcement actions in sanctions compliance? → To improve office efficiency
27. Under CAATSA Section 231, a foreign person may face sanctions if they knowingly engage in a 'significant transaction' with which sector? → Russia's defense or intelligence sectors
28. A financial institution's 'blocking report' submitted to OFAC must include which key information? → Identity of the account holder, nature and value of blocked property, and date of blocking
29. How often should sanctions lists be updated in compliance systems? → Only when a violation occurs
30. Which entity is responsible for enforcing sanctions on financial institutions? → The U.S. Department of Treasury and EU