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

3 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

1 months ago

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

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Denna

1 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

1 months ago

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

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Nelida

2 months ago

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

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Glenn

3 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

2 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

2 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

2 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

3 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

2 months ago

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

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Shasta

2 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

2 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

4 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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