CSS Secondary Sanctions & Extraterritorial Reach 2

Question 1

The Global Magnitsky Human Rights Accountability Act authorizes U.S. sanctions against foreign persons for which of the following?

Accepted Answer

Significant corruption or gross violations of internationally recognized human rights

Answer

The Global Magnitsky Act authorizes the President to impose sanctions against foreign individuals responsible for significant corruption or serious human rights abuses, regardless of country.

Question 2

Which statute serves as the primary legal authority for presidential imposition of secondary sanctions through executive orders?

Accepted Answer

The International Emergency Economic Powers Act (IEEPA)

Answer

IEEPA grants the President broad authority to regulate or prohibit economic transactions during declared national emergencies involving foreign threats, and is the primary basis for most modern secondary sanctions programs.

Question 3

'De-risking' by foreign financial institutions in response to secondary sanctions concerns typically involves which behavior?

Accepted Answer

Terminating relationships with entire jurisdictions or customer segments to avoid any sanctions exposure

Answer

De-risking refers to foreign banks exiting entire markets or customer categories rather than managing individual risks, often driven by secondary sanctions pressure and compliance cost concerns.

Question 4

Under the Comprehensive Iran Sanctions, Accountability, and Divestiture Act (CISADA), which activity by a foreign bank can result in loss of its U.S. correspondent account?

Accepted Answer

Knowingly facilitating significant financial transactions on behalf of the IRGC or designated Iranian parties

Answer

CISADA authorizes OFAC to prohibit or restrict a foreign bank's U.S. correspondent accounts if it knowingly facilitates significant financial transactions for the IRGC or other designated Iranian parties.

Question 5

Which of the following is NOT typically a factor OFAC considers when determining whether a transaction is 'significant' for secondary sanctions purposes?

Accepted Answer

The nationality of the individual employees processing the transaction

Answer

OFAC's 'significant transaction' analysis focuses on transaction size, nature, and national security impact — the nationality of compliance employees is not a determining factor.

(CSS) Certified Sanctions Specialist Practice Test

(CSS) Certified Sanctions Specialist Practice Test

CSS Secondary Sanctions & Extraterritorial Reach 2