CSS Cheat Sheet 2026

The 30 highest-yield CSS facts, distilled from real exam questions. Print it, save it as a PDF, or study it here — free, no sign-up.

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 document would be MOST useful when conducting due diligence on a foreign financial institution's sanctions exposure? → A Wolfsberg Questionnaire completed by the institution
3. Under OFAC regulations, what is the maximum civil penalty per violation for a willful sanctions violation as of recent enforcement guidance? → $1,000,000 or twice the transaction value
4. Which OFAC enforcement factor results in the greatest reduction of a base penalty amount in a settlement negotiation? → Voluntary self-disclosure of the violation
5. What does OFAC's 'egregious case' designation mean for civil penalty calculations? → The base penalty is calculated at the top of the applicable penalty schedule
6. Which OFAC sanctions program primarily targets the government of Venezuela and related parties? → Venezuela Sanctions Regulations (31 CFR Part 591)
7. Which designation criterion does OFAC use when targeting persons who provide material support to sanctioned parties? → Material support basis
8. Which U.S. regulatory expectation requires financial institutions to implement a risk-based sanctions compliance program? → OFAC's Framework for OFAC Compliance Commitments (2019)
9. When a U.S. financial institution rejects (rather than blocks) a transaction involving a sanctions concern, what filing is required and to whom? → A rejected transaction report to OFAC within 10 business days
10. What is a potential outcome of non-compliance with sanctions reporting? → Increased profits
11. How do automated screening systems benefit sanctions compliance? → By increasing profits
12. A sanctions risk assessment for a money services business (MSB) should prioritize which of the following customer risk factors? → Customer's geographic reach into high-risk jurisdictions
13. Which OFAC process allows a designated party to formally request removal from the SDN List? → Administrative Reconsideration or Delisting Request
14. When screening a corporate customer, which additional step is required beyond screening the entity name itself? → Screen all beneficial owners, directors, and key principals against sanctions lists
15. What is the purpose of conducting a risk assessment in compliance? → To analyze company growth
16. What is the purpose of OFAC's 'No Action Letter' process? → To allow parties to obtain informal guidance on whether a transaction is permissible
17. Which of the following is generally NOT exempt from OFAC sanctions without a license? → Commercial sale of luxury goods to a comprehensively sanctioned country
18. Under OFAC's Compliance Commitments Framework, which element focuses on ensuring senior management understands and supports sanctions compliance? → Management Commitment
19. Which of the following is a common screening tool used for sanctions compliance? → OFAC SDN list and other sanctions lists
20. Which of the following best describes 'disgorgement' as used in OFAC civil settlements? → Recovery of profits gained through sanctionable conduct
21. 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
22. What is the primary purpose of sanctions laws? → To restrict trade and transactions in response to violations
23. A compliance team is reviewing a high-value transaction involving a free trade zone (FTZ). What is the PRIMARY sanctions concern associated with FTZs? → Reduced regulatory oversight that can facilitate sanctions evasion through transshipment
24. Which sanctions program specifically targets narcotics traffickers and was authorized by the Kingpin Act? → Foreign Narcotics Kingpin Sanctions program
25. An organization uses a sanctions screening system with a 'threshold score' of 85%. What does this mean operationally? → Matches scoring at or above 85% similarity will generate an alert for human review
26. Which document in a trade finance transaction is most useful for identifying the ultimate origin of goods in a sanctions context? → Certificate of Origin
27. Which EU legal instrument is the primary vehicle for implementing EU autonomous sanctions (i.e., not derived from UN Security Council resolutions)? → EU Regulation
28. Which OFAC requirement mandates that blocked funds must be reported within a specific timeframe? → Blocked funds must be reported to OFAC within 10 business days of the blocking
29. Which of the following can be a consequence of violating sanctions? → Improved market share
30. A deferred prosecution agreement (DPA) negotiated between a company and the DOJ for sanctions violations typically requires which ongoing obligation? → Appointment of an independent compliance monitor for the DPA term