Sanctions Laws & Regulatory Frameworks Flashcards
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Read the first 7 Sanctions Laws & Regulatory Frameworks flashcards as text
Under OFAC regulations, what must happen to 'blocked' property belonging to a sanctioned party held by a US person?
Answer: It must be reported to the Treasury within 10 days and held in a segregated, interest-bearing account
US persons must report blocked property to OFAC within 10 business days and hold it in a blocked, interest-bearing account segregated from other assets.
Which of the following describes the 'non-derogation principle' in the context of overlapping UN and national/regional sanctions?
Answer: States may impose stricter sanctions than UN requirements but cannot fall below the UN minimum obligations
The non-derogation principle means UN sanctions set the floor — states must implement at minimum the UN measures — but may adopt stricter autonomous measures beyond those requirements.
What is the role of the 'Designating Authority' in the EU sanctions framework?
Answer: The EU Council or a competent authority that determines which individuals/entities are listed on EU sanctions lists
In the EU framework, the Council of the EU is the primary designating authority, acting on proposals from member states or the High Representative to add parties to EU sanctions lists.
A US bank receives a wire transfer that passes through its systems destined for a non-US bank. The originator is on the SDN List. Under OFAC regulations, what must the US bank do?
Answer: Block the transfer and report it to OFAC within 10 business days
When a US bank processes a transfer involving an SDN, it must block the funds and report the blocked transaction to OFAC within 10 business days.
The Global Magnitsky Act authorizes the US President to sanction foreign persons for which categories of conduct?
Answer: Serious human rights abusers and significant corrupt actors worldwide
The Global Magnitsky Human Rights Accountability Act (2016) authorizes sanctions globally against serious human rights abusers and significant corrupt actors, expanding the original Russia-focused Magnitsky Act.
Which document does OFAC use to explain its enforcement priorities and factors considered when determining civil monetary penalties?
Answer: Economic Sanctions Enforcement Guidelines (31 C.F.R. Part 501, Appendix A)
OFAC's Economic Sanctions Enforcement Guidelines, codified at 31 C.F.R. Part 501 Appendix A, detail the factors OFAC considers in determining penalty amounts including aggravating and mitigating factors.
What is 'deceptive shipping practices' as a sanctions evasion method, and which US agency primarily targets it?
Answer: Manipulating vessel tracking systems (AIS spoofing/disabling) to conceal ship locations; targeted by OFAC and the Coast Guard
Deceptive shipping practices include AIS manipulation, flag-hopping, and ship-to-ship transfers to evade detection; OFAC, working with DHS and the Coast Guard, issues advisories targeting these methods.