Acams CAMS Exam - Topic 2 Question 79 Discussion
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?
B) A one-off commercial transaction conducted between parties in Europe and Asia is not subject to secondary sanctions.
A) Asset freezes only prohibit US companies from engaging in certain activities with counterparts from a sanctioned jurisdiction.
C) The threat of US sanctions against foreign individuals and entities continues to exist despite the absence of a US nexus.
D) Secondary sanctions only target specific sectors of the economy such as the banking and finance sectors.
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