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ACAMS Certified Global Sanctions Specialist Sample Questions (Q90-Q95):
NEW QUESTION # 90
What is the similarity between the the 1993 rule and 1983 Rule 11?
- A. Required statements
- B. Frivolousness test
- C. Affirmative duty to investigate
- D. Objective Test
- E. Contents of the certificate
Answer: C
NEW QUESTION # 91
A person designated by the Office of Foreign Assets Control (OFAC) as a Specially Designated National (SDN) sets up a company in a tax haven country to receive income from a consultancy business. Which is correct with respect to the company?
- A. It can transact freely in USD through a bank account held with a non-US Bank.
- B. It cannot be sanctioned by OFAC because it is set up in a tax haven country.
- C. It is not subject to OFAC sanctions
- D. It cannot transact through a US Bank, as it is owned by an SDN.
Answer: D
Explanation:
Under OFAC's 50 Percent Rule, any entity owned 50% or more by one or more SDNs is considered automatically blocked, even if it is not explicitly listed. The jurisdiction of incorporation (e.g., tax haven) does not exempt the entity from OFAC sanctions.
Because the SDN owns the company, the entity is also subject to OFAC prohibitions and cannot transact through the US financial system, including any USD-clearing banks, whether located inside or outside the United States.
Options B, C, and D are incorrect because OFAC sanctions apply regardless of where the company is registered and because USD transactions create a US nexus.
Reference:
OFAC 50 Percent Rule on ownership and blocking.
Prohibitions on US financial institutions processing transactions involving SDNs or SDN-owned entities.
NEW QUESTION # 92
Why the First Circuit has imposed a Rule 11 sanction upon counsel in a "frivolous" habeas corpus proceeding?
- A. To district court for consideration of whether sanctions were appropriate
- B. Because sanctions are appropriate 'only in the most egregious circumstances and where the court has specifically found that penalties are necessary, that other remedies are insufficient and that its application of Rule 11 is tailored to the wrong found
- C. The petitioner sought the purely civil effect of preventing his deportation from happening.
- D. Petitioner was pursuing traditional habeas relief
- E. Petitioner was not pursuing traditional habeas relief
Answer: C,E
NEW QUESTION # 93
The attorney should confer directly with the client to verify the accuracy of the claims. In McGhee v. Sanilac County, 934 F.2d 89, 93 (6th Cir. 1991), under what circumstances did the appellate court reversed decision not to sanction?
- A. Upon attorney who discussed general content of amended complaint with clients prior to filing but did not inform clients of exact wording of new allegations, which proved to be false.
- B. Where attorney certified that he informed both husband and wife as to alternatives under the bankruptcy code and he had in fact only informed the wife.
- C. Where forwarding attorney had not advised them of an earlier adverse ruling.
- D. Where the attorney could not have been reasonably obtained by local counsel
- E. Where attorney neglected to ask the client whether allegedly defamatory statements were actually false
Answer: E
NEW QUESTION # 94
How can a state, even during peaceful relations, bring pressure on another state without actual war?
- A. Through Round Table Conference
- B. Through Article 12
- C. Through necessary determinations
- D. By using any of the above options
- E. Through Pacific Blockade
Answer: E
NEW QUESTION # 95
......
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