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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?

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?

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?

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?

Answer: E


NEW QUESTION # 94
How can a state, even during peaceful relations, bring pressure on another state without actual war?

Answer: E


NEW QUESTION # 95
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