Practice Test Geeks(RCMS) Registered Compliance Management Specialist Certification Practice Test
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Sanctions & Trade Compliance Flashcards

7 cards from real RCMS practice questions. Tap to flip, then mark Knew It or Still Learning — missed cards come back until you master them.

Read the first 7 Sanctions & Trade Compliance flashcards as text

  1. Which OFAC enforcement action involves a monetary penalty issued without a formal administrative hearing when the party does not contest the findings?

    Answer: Agreed settlement (settlement agreement)

    A settlement agreement allows OFAC and the violating party to resolve a potential civil monetary penalty without admitting or denying the findings, avoiding a formal hearing.

  2. Under the Export Administration Regulations, what is the 'de minimis' rule used to determine?

    Answer: Whether a foreign-produced item incorporating U.S.-origin content is subject to the EAR

    The de minimis rule determines whether a foreign-produced item containing U.S.-controlled content (by value or function) triggers EAR jurisdiction for re-export.

  3. A financial institution receives a wire transfer with the payment message 'Ref: services rendered / [blank originator field].' What sanctions red flag does this present?

    Answer: Stripping or omission of originator information to obscure identity

    Omitting or stripping originator information from wire transfers is a classic method used to evade sanctions screening systems.

  4. Iran sanctions under IFCA (Iran Freedom and Counter-Proliferation Act) target which sector that is distinct from traditional oil and finance sanctions?

    Answer: Shipping, shipbuilding, and port operations

    IFCA expanded Iran sanctions to cover the shipping, shipbuilding, and port operations sectors, targeting Iran's ability to transport and export sanctioned goods.

  5. What is the primary purpose of a 'Specially Designated Global Terrorist' (SDGT) designation under Executive Order 13224?

    Answer: To block the property and prohibit transactions with persons who support terrorism

    E.O. 13224 authorizes OFAC to block the property of and prohibit transactions with SDGTs — persons determined to commit, threaten, or support acts of terrorism.

  6. A U.S. company's foreign subsidiary (not a U.S. person) enters into a contract with a Cuban state-owned entity. Under current OFAC rules, is this generally permitted?

    Answer: No, because OFAC's Cuban Assets Control Regulations apply to entities owned or controlled by U.S. persons

    OFAC's Cuban Assets Control Regulations (CACR) extend to entities owned or controlled by U.S. persons, making foreign subsidiary transactions with Cuba generally prohibited without a license.

  7. In trade compliance, what does 'transshipment risk' refer to?

    Answer: The risk that goods are re-routed through a third country to reach a prohibited end destination

    Transshipment risk refers to the diversion of controlled goods through intermediary countries to circumvent sanctions or export controls on the ultimate destination.