Acams Exam CAMS Topic 2 Question 79 Discussion

Actual exam question for Acams's CAMS exam

Question #: 79
Topic #: 2

[All CAMS Questions]

A compliance officer of a financial institution is reviewing a payment for sanctions compliance between two parties in Europe and Asia. The payment is in Euros and involves the provision of services to a company located in a jurisdiction subject to Office of Foreign Assets Control secondary sanctions. Which factor is most important in determining the compliance officer's response?

AAsset freezes only prohibit US companies from engaging in certain activities with counterparts from a sanctioned jurisdiction.

BA one-off commercial transaction conducted between parties in Europe and Asia is not subject to secondary sanctions.

CThe threat of US sanctions against foreign individuals and entities continues to exist despite the absence of a US nexus.

DSecondary sanctions only target specific sectors of the economy such as the banking and finance sectors.

Show Suggested Answer

Suggested Answer: B

by Isaac at Jul 11, 2024, 02:55 PM

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Catrice

13 days ago

I'm going with C. Better safe than sorry when it comes to sanctions, even if the parties are in Europe and Asia.

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Glenn

19 days ago

Haha, the compliance officer better be on their A-game! This question is no joke - secondary sanctions can be a real minefield.

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Veronica

29 days ago

Option B is tempting, but I'm not sure a one-off transaction is enough to avoid secondary sanctions, especially given the jurisdiction involved.

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Chana

1 months ago

I think option C is the correct answer. Secondary sanctions can still apply even without a direct US nexus, so the compliance officer needs to be cautious.

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