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CSS Sanctions Program Types & Target Identification Flashcards

6 cards from real CSS practice questions. Tap to flip, then mark Knew It or Still Learning — missed cards come back until you master them.

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  1. Under the '50 Percent Rule,' OFAC considers an entity to be blocked if sanctioned persons collectively own what minimum ownership stake?

    Answer: 50 percent or more

    OFAC's 50 Percent Rule states that any entity owned 50% or more (in aggregate) by one or more SDNs is itself considered blocked, even if not explicitly listed.

  2. Which designation criterion does OFAC use when targeting persons who provide material support to sanctioned parties?

    Answer: Material support basis

    OFAC can designate persons who provide material support, goods, or services to or in support of already-designated SDNs under various sanctions program authorities.

  3. What does the term 'blocked property' mean in the context of U.S. sanctions law?

    Answer: Property in which a sanctioned person has an interest that must be frozen and cannot be dealt in

    Blocked property is not seized but frozen in place — U.S. persons must hold it in a blocked account and may not transfer, pay, or deal in it without an OFAC license.

  4. Which OFAC program imposes sanctions related to weapons of mass destruction (WMD) proliferators?

    Answer: WMD Proliferators Sanctions Regulations (31 CFR Part 544)

    OFAC administers the WMD Proliferators Sanctions Regulations (31 CFR Part 544) to target individuals and entities involved in the proliferation of WMD and their delivery systems.

  5. A 'front company' in the context of sanctions evasion is best described as:

    Answer: An entity that appears to conduct normal business but is actually controlled by or acting for a sanctioned party

    Front companies obscure the involvement of sanctioned parties by presenting a legitimate business facade while actually facilitating access to the financial system for blocked persons.

  6. Which sanctions list maintained by the U.S. Department of Commerce's BIS restricts export privileges rather than blocking assets?

    Answer: Entity List

    The Bureau of Industry and Security (BIS) Entity List restricts the export, reexport, and transfer of items to listed parties without a license, focusing on export controls rather than asset blocking.