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CSS001 exam Format | CSS001 Course Contents | CSS001 Course Outline | CSS001 exam Syllabus | CSS001 exam Objectives

Exam Code: CSS001

Exam Name: ACSS Certified Sanctions Specialist (CSS)

Number of Questions: 106

Time Allotted: 3 hours

Question Format: Multiple choice

Passing Marks/Score: Not publicly disclosed by ACSS.

Delivery: Proctored exam at testing centers across the globe



- SANCTIONS REGIME TYPES, GOALS, PROHIBITIONS AND EFFECTS

- Articulate the definition and dierent types of economic/financial/trade sanctions regimes in order to be able to implement a sanctions compliance program.

- Describe the history and reasons why sanctions exist.

- Identify and describe the common prohibitions (facilitations), and common exemptions contained within sanctions regimes.

- Understand how to measure eectiveness of sanctions and unintended consequences of sanctions.



- SANCTIONS IMPOSERS AND TARGETS

- Understand the UN Security Council Sanctions architecture and mandate.

- Know how to read a UN Security Council Resolutions imposing a new sanctions regime.

- Understand the UN Security Council sanctions designation criteria for targets and the delisting process.

- Understand the EU sanctions/restrictive measures architecture and mandate.

- Know the dierent EU Sanctions Regimes.

- Articulate the main US agencies involved in sanctions, the roles they play in its enforcement, and its extraterritorial reach

- Identify and assess key other (UK, Australia, Japan, Canada) unilateral sanctions imposers and their regimes.



- SANCTIONS EVASION: TYPOLOGIES AND SCHEMES

- Articulate typologies and schemes set up to evade sanctions in the financial industry.

- Articulate typologies and schemes set up to evade sanctions in other industries such as maritime shipping, commercial insurance and others.



- ESSENTIAL COMPONENTS OF A RISKBASED SANCTIONS COMPLIANCE PROGRAM IN DIFFERENT INDUSTRY SETTINGS

- Management Commitment

- Obtain senior management commitment to and support of an organizations risk-based sanctions compliance program.

- Designing and Implementing a Sanctions Risk Assessment in Dierent Industry Settings

- Identify customer/product/geography related sanctions risks inherent within the applicable industry.

- Conduct and maintain a sanctions risk exam for clients and customers, products and services, supply chain, intermediaries, counter-parties, transactions and geographic locations.

- Internal Controls: Policies and Procedures

- Develop policies and procedures based on industry leading practices.

- Analyze new government policies and regulatory and enforcement developments.

- Designated Sanctions Ocer and Stang

- Hire and oversee appropriate personnel with the right level of professional skills.

- Communication and Training

- Conduct training and develop awareness for stakeholders.

- Advise organization stakeholders.

- Supervise line-level personnel to ensure application of procedures using operational instructions and guidelines.



- ROLE OF TECHNOLOGY AND LIST SCREENING

- Articulate general principles, concepts and fundamental pillars behind screening and the dierent ways that sanctions screening can take place

- Develop, implement, maintain watch list screening tools

- Evaluate and hire list screening vendors



- OTHER OPERATIONAL ISSUES CONTRIBUTING TO AN EFFECTIVE AND EFFICIENT SANCTIONS COMPLIANCE PROGRAM

- Assist with resolution of standard and complex cases

- Obtain, manage or review licenses that authorize particular transactions that may otherwise be prohibited by the sanctions

- Reference how to use contractual clauses and warranties, drafting contractual clauses oering additional protection in higher risk situations and dealing with contractual obligations when sanctions impact on a partys ability to perform.

- Know the options and risks of outsourcing certain sanctions compliance tasks to freight forwarders and other business partners or third-party agents in order to streamline operations

- Reference how the sanctions program interacts and intersects with other related compliance areas (e.g. trade controls, anti-money laundering, anti-bribery & corruption)

- Critically evaluate the forces in business environment that cause sanctions compliance dilemmas.



- ENFORCEMENT AND CONDUCTING OR SUPPORTING INVESTIGATIONS INTO SANCTIONS VIOLATIONS

- Articulate law enforcement agencies role in investigating sanctions violations and know how they coordinate in order to investigate potential sanctions violations or support the investigation process.

- Engage with government agencies.

- Understand the various government stakeholders in the sanctions regimes applicable to your company

- Internally investigate potential/historical violations of sanctions related laws or policies utilizing modern techniques including document review, data analysis, interviews, and external resources where necessary.

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