CSS Secondary Sanctions & Extraterritorial Reach 3

Question 1

Which Executive Order most broadly authorizes secondary sanctions related to Russia's harmful foreign activities post-2021?

Accepted Answer

E.O. 14024

Answer

Executive Order 14024, issued in April 2021, provides the broadest authority for secondary sanctions targeting those who operate in specified Russian economic sectors or support Russian government activities.

Question 2

How do 'blocking' (primary) sanctions differ from secondary sanctions in terms of their immediate legal effect?

Accepted Answer

Blocking sanctions freeze assets and prohibit U.S. person transactions; secondary sanctions extend prohibitions to non-U.S. persons dealing with sanctioned parties

Answer

Blocking sanctions immediately freeze assets and prohibit all U.S. person transactions with the designated party, while secondary sanctions deter non-U.S. persons from engaging with those parties by threatening their own access to U.S. markets.

Question 3

A European bank processes a payment for a Russian energy company on the SSI (Sectoral Sanctions Identifications) List. Under U.S. secondary sanctions, which outcome is most likely?

Accepted Answer

OFAC may investigate and potentially restrict the bank's access to U.S. correspondent banking

Answer

Under secondary sanctions, OFAC can investigate and potentially restrict a foreign bank's U.S. correspondent accounts if it finds the transaction was significant and in violation of applicable sanctions authorities.

Question 4

The Sectoral Sanctions Identifications (SSI) List differs from the SDN List in which key way?

Accepted Answer

SSI listings impose targeted prohibitions on specific types of transactions rather than blocking all dealings with the listed entity

Answer

SSI-listed entities face sector-specific transaction prohibitions — such as restrictions on new debt over a defined maturity — rather than the comprehensive asset-blocking that applies to SDN-listed parties.

Question 5

When OFAC evaluates whether to impose secondary sanctions on a non-U.S. person who transacted with an Iranian entity, which statement best describes OFAC's enforcement posture?

Accepted Answer

Secondary sanctions are largely discretionary — OFAC evaluates significance and policy factors before imposing consequences

Answer

Secondary sanctions are predominantly discretionary; OFAC typically evaluates the significance of the transaction and broader policy considerations before imposing sanctions on a non-U.S. person.

(CSS) Certified Sanctions Specialist Practice Test

(CSS) Certified Sanctions Specialist Practice Test

CSS Secondary Sanctions & Extraterritorial Reach 3