CSS Sanctions Laws & Regulatory Frameworks 4

Question 1

Under OFAC regulations, what must happen to 'blocked' property belonging to a sanctioned party held by a US person?

Accepted Answer

It must be reported to the Treasury within 10 days and held in a segregated, interest-bearing account

Answer

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.

Question 2

Which of the following describes the 'non-derogation principle' in the context of overlapping UN and national/regional sanctions?

Accepted Answer

States may impose stricter sanctions than UN requirements but cannot fall below the UN minimum obligations

Answer

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.

Question 3

What is the role of the 'Designating Authority' in the EU sanctions framework?

Accepted Answer

The EU Council or a competent authority that determines which individuals/entities are listed on EU sanctions lists

Answer

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.

Question 4

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?

Accepted Answer

Block the transfer and report it to OFAC within 10 business days

Answer

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.

Question 5

The Global Magnitsky Act authorizes the US President to sanction foreign persons for which categories of conduct?

Accepted Answer

Serious human rights abusers and significant corrupt actors worldwide

Answer

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.

(CSS) Certified Sanctions Specialist Practice Test

(CSS) Certified Sanctions Specialist Practice Test

CSS Sanctions Laws & Regulatory Frameworks 4