Acams CGSS Exam Dumps

Sanctions evasion indicators in trade documentation include:

* Multiple amendments designed to obscure the parties involved -- a classic red flag indicating concealment of the real counterparty.

* Falsified or tampered shipping documents -- used to hide sanctioned routes, ports, or vessels.

* Conflicting end-user documentation -- a major warning sign of diversion or concealment of sanctioned recipients.

Cash withdrawals (E) and online payment instructions (F) are AML indicators, but not directly sanctions evasion indicators. Docking at non-sanctioned countries (D) is not suspicious unless used as part of concealment, which is not indicated here.

Trade-based sanctions evasion red flags (altered documents, falsification, inconsistent end-user information).

Diversion and concealment indicators in trade compliance.

Sanctions and Compliance Domains provide that a financial institution must not execute a transaction when significant unresolved discrepancies exist, especially in high-risk transshipment regions. When:

* documentation does not match payment details, and

* the customer refuses to provide required information,

the institution cannot proceed. Without clarity, the transaction may involve diversion, routed shipments, or indirect dealings with sanctioned entities.

Rejection is appropriate because blocking only applies when a confirmed sanctions match exists. Reprimanding customers, forcing subpoenas, or engaging mutual legal assistance procedures are not required or appropriate steps in sanctions transaction handling.

Reference from Sanctions and Compliance Domains:

Requirements to reject a transaction when discrepancies cannot be resolved.

Need for customer cooperation in sanctions investigations.

Standards for handling high-risk transshipment-related alerts.

Sanctions and Compliance Domains state that screening must be applied to all relevant business activities and relationships that can expose an organization to sanctions risk. This includes customers, vendors, intermediaries, distributors, beneficial owners, and any party involved in transactions, supply chains, or service delivery.

Limiting screening only to customers is inconsistent with sanctions compliance expectations. Excluding vendors, intermediaries, or beneficial owners can expose an organization to significant sanctions violations due to indirect dealings with sanctioned parties. Comprehensive coverage of all business activities is the standard approach in an effective sanctions compliance program.

Reference from Sanctions and Compliance Domains:

Requirements for comprehensive sanctions screening across all relevant business relationships.

Inclusion of customers, intermediaries, vendors, distributors, and beneficial owners.

Risk-based approach requiring full coverage of business activities to prevent indirect sanctions exposure.

Sanctions evasion commonly occurs through:

* Trade finance --- manipulating bills of lading, transshipment, falsified documents.

* Correspondent banking --- indirect access to the financial system through other banks.

* Shell companies --- concealment of ownership, diversion of goods, and masking sanctioned parties.

Corporate, online, and retail banking may have risks but are not primary evasion channels highlighted in sanctions-evasion typologies.

Sanctions evasion indicators involving trade, correspondent networks, and shell structures.

OFAC advisories on high-risk payment channels.

Comprehensive sanctions prohibit nearly all exports, imports, services, financial transactions, and business dealings with a specific jurisdiction. These sanctions apply broadly to the entire territory and often include embargoes, trade restrictions, and full financial prohibitions.

Sectoral sanctions apply only to certain industries. Targeted sanctions apply to specific individuals or entities. Thematic sanctions focus on conduct (e.g., cybercrime, human rights abuses).

Definition of comprehensive sanctions and their prohibition scope.

Distinction from targeted, sectoral, and thematic sanctions.