Acams CAMS Exam - Topic 2 Question 79 Discussion

Actual exam question for Acams's CAMS exam

Question #: 79
Topic #: 2

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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Providencia

5 months ago

C makes the most sense, even without a US link.

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Sylvia

5 months ago

A is misleading; it’s more complicated than that.

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Lorita

5 months ago

Wait, are we really saying secondary sanctions don't apply?

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Alona

6 months ago

I disagree, B seems more relevant for this scenario.

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Sherron

6 months ago

C is definitely the key factor here.

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Levi

6 months ago

I feel like the focus should be on the potential threat of US sanctions, but I’m not confident about how that plays out in this context.

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Jackie

6 months ago

If I remember correctly, the key factor is whether the transaction could still expose the institution to US sanctions, even if it's just a one-off deal.

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Laurene

7 months ago

I think I came across a practice question that mentioned how secondary sanctions can affect foreign entities, but I can't recall the specifics.

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Florencia

7 months ago

I remember studying that secondary sanctions can still apply even without a direct US connection, but I'm not entirely sure how that impacts this scenario.

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Bok

7 months ago

Based on what I know about sanctions compliance, I would say Option C is the correct answer. The threat of US sanctions can extend beyond just US companies.

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Amie

7 months ago

I'm not totally sure about this, but I think the compliance officer needs to carefully evaluate the risk of potential secondary sanctions, regardless of the parties' locations.

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Thersa

7 months ago

I'm a bit confused by the details here. Does the fact that the payment is in Euros and the parties are in Europe and Asia mean it's not subject to US sanctions?

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Kasandra

7 months ago

This question seems tricky, but I think the key is understanding the concept of secondary sanctions and how they can apply even without a US nexus.

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Leslie

7 months ago

Option C seems like the most important factor to consider. Secondary sanctions can still apply even if there's no direct US involvement in the transaction.

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Jani

7 months ago

Okay, I've got this. The key is to identify which of the options would be considered a discretionary cost that the health plan has control over, rather than a committed cost.

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Penney

7 months ago

Hmm, I'm a little confused on the difference between corrective and preventive measures. I'll have to think this through carefully.

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Catrice

11 months 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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France

10 months ago

D: Yeah, it's better to be safe than sorry when dealing with potential sanctions violations.

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Denna

10 months ago

C: It's always important to err on the side of caution when it comes to sanctions, so I would go with that too.

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Xochitl

10 months ago

B: I agree, the location of the company can have a big impact on sanctions compliance.

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Nelida

10 months ago

A: I think the most important factor is the jurisdiction of the company receiving the services.

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Glenn

12 months 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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Queen

10 months ago

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

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Alex

11 months ago

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

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Sherron

11 months ago

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

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Veronica

12 months 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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Wendell

11 months ago

C: I agree. We should be cautious and consider all factors before making a decision.

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Shasta

11 months ago

B: That's a good point. The jurisdiction involved could make a difference in how we approach this.

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Reena

11 months ago

A: I think we need to consider the threat of US sanctions against foreign individuals and entities, even without a US nexus.

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Chana

1 year 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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