CSS Enforcement Actions & Reporting Obligations 2

Question 1

Under OFAC regulations, what is the maximum civil penalty per violation for a willful sanctions violation as of recent enforcement guidance?

Accepted Answer

$1,000,000 or twice the transaction value

Answer

OFAC can impose civil penalties up to $1,000,000 or twice the value of the underlying transaction for willful violations, whichever is greater.

Question 2

A U.S. bank discovers it processed a wire transfer to a blocked entity three years ago. What is the standard OFAC reporting deadline once the violation is identified?

Accepted Answer

30 calendar days

Answer

OFAC requires that blocked or rejected transactions be reported within 10 business days of the blocking or rejection, but initial discovery reports for past violations are typically due within 10 business days as well — however, blocking reports have a 10-business-day rule while annual reports follow a separate schedule.

Question 3

Which OFAC enforcement factor results in the greatest reduction of a base penalty amount in a settlement negotiation?

Accepted Answer

Voluntary self-disclosure of the violation

Answer

Voluntary self-disclosure is the single most significant mitigating factor under OFAC's Economic Sanctions Enforcement Guidelines, typically reducing the base penalty by 50%.

Question 4

What does OFAC's 'egregious case' designation mean for civil penalty calculations?

Accepted Answer

The base penalty is calculated at the top of the applicable penalty schedule

Answer

For egregious cases, OFAC uses the top of the applicable base penalty schedule as the starting point for calculation, rather than the midpoint used in non-egregious cases.

Question 5

Under FinCEN's SAR regulations, what is the filing deadline for a suspicious activity report involving a known or suspected sanctions violation?

Accepted Answer

30 calendar days from detection

Answer

Financial institutions must file a SAR within 30 calendar days of initially detecting a suspicious activity, or 60 days if no suspect is identified at the time of detection.

(CSS) Certified Sanctions Specialist Practice Test

(CSS) Certified Sanctions Specialist Practice Test

CSS Enforcement Actions & Reporting Obligations 2