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Exam Code: CSS001
Exam Name: ACSS Certified Sanctions Specialist (CSS)
Number of Questions: 106
Time Allotted: 3 hours
Question Format: Multiple choice
Passing Marks/Score: Not publicly disclosed by ACSS.
Delivery: Proctored test at testing centers across the globe

- SANCTIONS REGIME TYPES, GOALS, PROHIBITIONS AND EFFECTS
- Articulate the definition and dierent types of economic/financial/trade sanctions regimes in order to be able to implement a sanctions compliance program.
- Describe the history and reasons why sanctions exist.
- Identify and describe the common prohibitions (facilitations), and common exemptions contained within sanctions regimes.
- Understand how to measure eectiveness of sanctions and unintended consequences of sanctions.

- SANCTIONS IMPOSERS AND TARGETS
- Understand the UN Security Council Sanctions architecture and mandate.
- Know how to read a UN Security Council Resolutions imposing a new sanctions regime.
- Understand the UN Security Council sanctions designation criteria for targets and the delisting process.
- Understand the EU sanctions/restrictive measures architecture and mandate.
- Know the dierent EU Sanctions Regimes.
- Articulate the main US agencies involved in sanctions, the roles they play in its enforcement, and its extraterritorial reach
- Identify and assess key other (UK, Australia, Japan, Canada) unilateral sanctions imposers and their regimes.

- SANCTIONS EVASION: TYPOLOGIES AND SCHEMES
- Articulate typologies and schemes set up to evade sanctions in the financial industry.
- Articulate typologies and schemes set up to evade sanctions in other industries such as maritime shipping, commercial insurance and others.

- ESSENTIAL COMPONENTS OF A RISKBASED SANCTIONS COMPLIANCE PROGRAM IN DIFFERENT INDUSTRY SETTINGS
- Management Commitment
- Obtain senior management commitment to and support of an organizations risk-based sanctions compliance program.
- Designing and Implementing a Sanctions Risk Assessment in Dierent Industry Settings
- Identify customer/product/geography related sanctions risks inherent within the applicable industry.
- Conduct and maintain a sanctions risk test for clients and customers, products and services, supply chain, intermediaries, counter-parties, transactions and geographic locations.
- Internal Controls: Policies and Procedures
- Develop policies and procedures based on industry leading practices.
- Analyze new government policies and regulatory and enforcement developments.
- Designated Sanctions Ocer and Stang
- Hire and oversee appropriate personnel with the right level of professional skills.
- Communication and Training
- Conduct training and develop awareness for stakeholders.
- Advise organization stakeholders.
- Supervise line-level personnel to ensure application of procedures using operational instructions and guidelines.

- ROLE OF TECHNOLOGY AND LIST SCREENING
- Articulate general principles, concepts and fundamental pillars behind screening and the dierent ways that sanctions screening can take place
- Develop, implement, maintain watch list screening tools
- Evaluate and hire list screening vendors

- OTHER OPERATIONAL ISSUES CONTRIBUTING TO AN EFFECTIVE AND EFFICIENT SANCTIONS COMPLIANCE PROGRAM
- Assist with resolution of standard and complex cases
- Obtain, manage or review licenses that authorize particular transactions that may otherwise be prohibited by the sanctions
- Reference how to use contractual clauses and warranties, drafting contractual clauses oering additional protection in higher risk situations and dealing with contractual obligations when sanctions impact on a partys ability to perform.
- Know the options and risks of outsourcing certain sanctions compliance tasks to freight forwarders and other business partners or third-party agents in order to streamline operations
- Reference how the sanctions program interacts and intersects with other related compliance areas (e.g. trade controls, anti-money laundering, anti-bribery & corruption)
- Critically evaluate the forces in business environment that cause sanctions compliance dilemmas.

- ENFORCEMENT AND CONDUCTING OR SUPPORTING INVESTIGATIONS INTO SANCTIONS VIOLATIONS
- Articulate law enforcement agencies role in investigating sanctions violations and know how they coordinate in order to investigate potential sanctions violations or support the investigation process.
- Engage with government agencies.
- Understand the various government stakeholders in the sanctions regimes applicable to your company
- Internally investigate potential/historical violations of sanctions related laws or policies utilizing modern techniques including document review, data analysis, interviews, and external resources where necessary.