The Office of Foreign Assets Control has designated which types of high-risk persons or entities in the digital asset ecosystem? (Select Three.)
OFAC has designated:
* Hackers and cyber actors involved in cryptocurrency theft.
* Cryptocurrency exchanges facilitating illicit transactions or supporting sanctioned jurisdictions.
* Mixers (tumblers) known to anonymize blockchain transactions and facilitate laundering and sanctions evasion.
Software developers (D) are generally not designated unless directly linked to illicit activity. Credit unions and central banks are not typical OFAC digital-asset designations.
OFAC digital asset designations (e.g., mixers, DPRK cyber actors).
Sanctions risk indicators in the virtual currency sector.
The US Treasury adopts a mechanism of secondary sanctions to enforce compliance with its regulations. Which statement best describes the concept of secondary sanctions?
The concept of secondary sanctions refers to sanctions imposed by the United States on non-US persons or entities that engage in certain activities involving sanctioned jurisdictions, individuals, or sectors. These sanctions apply even though the affected parties are not ordinarily subject to US jurisdiction.
Secondary sanctions are used to discourage foreign actors from engaging in conduct that undermines US sanctions objectives. They do not reflect repeated sanctions, nor are they tied to correspondent banking. They impose consequences irrespective of geographical or jurisdictional boundaries, provided the activity meets defined US sanctionable criteria.
Reference from Sanctions and Compliance Domains:
US Treasury framework defining secondary sanctions and applicability to non-US persons.
Distinction between primary and secondary sanctions.
A sanctions analyst receives a letter of credit (LC) request that shows the carrier is a possible match under the Specially Designated Nationals and Blocked Persons List. Which action should the analyst take?
Sanctions and Compliance Domains state that when a potential sanctions match occurs, the first step is to conduct a proper investigation to determine whether the alert is a true match or false positive. This includes obtaining additional identifiers such as addresses, IMO numbers, registration numbers, or corporate details.
Immediate rejection or reporting is only appropriate after confirming a true match. Premature rejection without verification violates due diligence expectations. Closing the customer account is not justified without confirmed sanctions involvement.
Investigation procedures for potential sanctions matches.
Requirements to gather additional identifiers before determining match status.
According to the Wolfsberg Guidance, the most important factor a financial institution should take into consideration for developing an in-house sanctions screening system is:
The Wolfsberg Guidance on Sanctions Screening emphasizes data quality as the most important factor when developing or maintaining a screening system. High-quality, accurate, complete, and consistently structured data is essential to ensure proper matching, reduce false positives, and avoid missed true matches.
Even with strong IT capabilities or defined risk appetite, a screening system will fail if the underlying data is incomplete or inaccurate.
Wolfsberg Guidance: primacy of data quality in sanctions screening.
Importance of accurate customer and transaction data for effective matching.
ABC Industries is a legal entity owned by Entity X (30%), Entity Y (25%), and Entity Z (45%). Entity X is a Specially Designated National (SDN) under OFAC sanctions, and Entity Y is owned (80%) by an OFAC SDN. Is ABC Industries a blocked entity under OFAC sanctions?
OFAC's 50 Percent Rule requires aggregation of ownership by SDNs and entities owned 50% or more by SDNs.
Ownership breakdown:
* Entity X (SDN) 30%
* Entity Y (owned 80% by an SDN) treated as an SDN contributes 25%
* Total SDN-derived ownership = 30% + 25% = 55%
Since aggregate SDN ownership exceeds 50%, ABC Industries is automatically considered a blocked entity, even though Entity Z is not sanctioned.
Options B and C are incorrect because explicit listing is not required---ownership triggers blocking. Option A is incorrect because one SDN at 30% alone is insufficient, but combined ownership is.
OFAC 50 Percent Rule (aggregation principle).
Treatment of entities majority-owned by SDNs as SDNs for ownership calculations.
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