The Certified Global Sanctions Specialist (CGSS) Certification Set One

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Topics Covered

Sanctions Framework and Compliance

  1. Sanctions Creation and Enforcement

    • 1.1 Sanctions Processes: Understanding how sanctions are established, modified, and enforced, including global laws, legal processes, and common errors.
  2. Sanctions Concepts

    • 1.2 Sanctions Overview: Key concepts of sanctions, including definitions, and the roles of entities like the UN Security Council, OFAC, EU, UK-HMT, and AUSTRAC; distinctions between multilateral and unilateral sanctions; and the nature of restrictive measures.
  3. Types of Sanctions

    • 1.3 Sanction Categories: Different types of sanctions, such as those targeting individuals, countries, goods, vessels, sectors, and terrorism-related activities.
  4. Geographic Scope of Sanctions

    • 1.4 Sanctions Scope: Geographic impact of sanctions, including the IEEPA, extraterritorial reach, blocking statutes, and effects on trade restrictions, as well as national and autonomous sanctions.
  5. Beneficial Control and Ownership

    • 1.5 Control and Ownership: Understanding beneficial control, ownership, and the 50% rule in the context of sanctions.
  6. License Types and Scope

    • 1.6 Sanctions Licenses: Types of licenses and their scope, including issuing authorities, common errors, application processes, and operational challenges.
  7. Governance and Risk Management

    • 1.7 Sanctions Governance: Principles of governance and risk-based approaches as they apply to sanctions screening, including risk categories and regulatory expectations.

Sanctions Evasion Techniques

  1. Evasion Techniques by Illicit Actors

    • 2.1 General Evasion Tactics: Common methods used by illicit actors to evade sanctions, including techniques related to payments and transactions.
  2. Trade-Related Evasion

    • 2.2 Trade Concealment: Techniques used to obscure the end-use of goods or the identity of end-users, such as manipulating export controls and concealing trade purposes.
  3. Identity Concealment Methods

    • 2.3 Hiding Identity: Methods used by targets to conceal their identity, including the use of shell companies, LLCs, restructuring, and complex ownership schemes.

Sanctions Due Diligence and Risk Management

  1. Sanctions Due Diligence

    • 3.1 Key Concepts: Essential elements of sanctions due diligence for mitigating risks, including risk assessment approaches, geographic considerations, and transaction-level due diligence.
  2. Application Across Business Lines

    • 3.2 Business-Specific Due Diligence: Implementing sanctions due diligence across various sectors, such as luxury goods, retail banking, commercial banking, and insurance.
  3. Beneficial Ownership

    • 3.3 Ownership Calculation: Comparing the 25% rule for AML with the 50% rule for sanctions, and understanding EU guidelines on beneficial ownership.
  4. Sanctions Risk Areas

    • 3.4 Risk Areas: Identifying key sanctions risk areas, including customer profiles, business nature, products, and jurisdictions. Addressing differences in due diligence requirements between the EU and OFAC.
  5. Financial Products and Services

    • 3.5 Sanctions Risks: Understanding how different financial services and products relate to sanctions risks.

Sanctions Monitoring and Screening

  1. Monitoring Procedures

    • 4.1 Sanctions Monitoring: Procedures and key controls for sanctions monitoring, including comparisons with AML controls, and the use of interdiction software.
  2. Screening Key Concepts

    • 4.2 Screening Tools: Understanding Automated Screening Tools (ASTs), interdiction systems, algorithms, and regulatory expectations, including handling inequalities and exclusion lists.
  3. Name Screening

    • 4.3 Customer and Third-Party Screening: Techniques for screening names, including common naming conventions, transliteration, fuzzy logic, and Romanization.
  4. Payment Screening

    • 4.4 Process: Managing AST alerts in payment screening and identifying relevant fields in SWIFT payment messages.
  5. Sanctions Technology

    • 4.5 Technological Tools: Utilizing sanctions screening software, matching algorithms, machine learning, and artificial intelligence.
  6. Software Features

    • 4.6 Sanctions Software: Features such as match proximity thresholds and validation within sanctions-related software.
  7. Data Management and Analysis

    • 4.7 Data Practices: Effective data management and analysis, including list management, predictive analytics, and ensuring data quality.

Investigations and Reporting

  1. Conducting Investigations

    • 5.1 Investigation Procedures: Methods for conducting investigations, maintaining records, and filing reports effectively.
  2. Information Sources

    • 5.2 Sources of Information: Utilizing primary and secondary sources in an investigation.
  3. Asset Management

    • 5.3 Freezing and Reporting: Procedures for freezing assets, notifying targets, and reporting, including institutional requirements for managing frozen assets and identifying target assets.

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