CSS CSS Sanctions Program Types & Target Identification 2

Question 1

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

Accepted Answer

50 percent or more

Answer

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.

Question 2

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

Accepted Answer

Material support basis

Answer

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

Question 3

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

Accepted Answer

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

Answer

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.

Question 4

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

Accepted Answer

WMD Proliferators Sanctions Regulations (31 CFR Part 544)

Answer

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.

Question 5

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

Accepted Answer

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

Answer

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.

(CSS) Certified Sanctions Specialist Practice Test

(CSS) Certified Sanctions Specialist Practice Test

CSS CSS Sanctions Program Types & Target Identification 2