CGSS flashcards
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32 cards. Read the term and the definition here. The deck at the top of this page is optional.
- UN Charter Article 41
- Legal basis authorizing the UN Security Council to impose measures not involving armed force, including economic sanctions, to maintain or restore international peace and security.
- 50 Percent Rule
- OFAC rule that an entity owned 50% or more, directly or indirectly, in the aggregate by one or more blocked persons is itself blocked, even if unlisted.
- Primary sanctions
- Restrictions that apply to persons subject to the issuing jurisdiction, such as nationals, residents, entities, and transactions through its territory.
- Secondary sanctions
- Measures threatening penalties against non-US persons for specified conduct outside US jurisdiction, designed to deter dealings with sanctioned targets.
- Comprehensive embargo
- Broad prohibitions on most trade, financial, and other dealings with an entire country or territory, as opposed to targeted measures against specific persons.
- EU Article 215 TFEU
- Treaty article enabling the EU to adopt regulations implementing CFSP restrictive measures that interrupt or reduce economic relations with third countries or persons.
- SDN List
- OFAC's Specially Designated Nationals and Blocked Persons List of individuals and entities whose property US persons must block and with whom dealings are prohibited.
- SSI List
- OFAC's Sectoral Sanctions Identifications list imposing narrower restrictions, such as limits on new debt or equity, rather than full blocking.
- OFSI
- UK Office of Financial Sanctions Implementation, which administers and enforces UK financial sanctions and considers license applications.
- UN 1267 Committee
- Security Council committee administering the ISIL/Al-Qaida sanctions regime, maintaining a consolidated asset-freeze list binding on member states.
- CAATSA
- US law authorizing secondary sanctions on significant transactions with Russia, Iran, and North Korea, including defense and energy sectors.
- Five pillars
- OFAC compliance framework elements: management commitment, risk assessment, internal controls, testing and auditing, and training.
- Risk assessment
- Documented evaluation of sanctions exposure across customers, products, geographies, channels, and transactions, used to calibrate controls proportionately.
- Board oversight
- Senior management and board responsibility for approving the sanctions program, appointing a sanctions officer, and receiving regular compliance reporting.
- Independent testing
- Risk-based review by internal audit or external parties assessing whether sanctions controls are designed and operating effectively.
- Escalation procedure
- Documented process for referring potential sanctions matches or violations to compliance, legal, and senior management for decision and recordkeeping.
- Fuzzy matching
- Screening technique that identifies near matches to list names, allowing for spelling, transliteration, and name-order variations but producing false positives.
- False positive
- A screening alert that, after review of secondary identifiers, does not match a designated person and can be documented and closed.
- Blocked property report
- Filing to OFAC within 10 business days after blocking property, reporting the blocked person, assets, and circumstances.
- Rejected transaction
- A transaction stopped because it would violate sanctions; OFAC requires reporting within 10 business days.
- Payment screening
- Filtering of wire and message traffic against sanctions lists before execution to prevent prohibited payments.
- Suspicious Activity Report
- Filing with FinCEN or a national FIU describing potentially illicit transactions, including sanctions-evasion indicators.
- Transshipment
- Routing goods through an intermediate country to disguise their final destination, often used to evade country-based sanctions.
- Shell company
- An entity with no substantive operations, often used to conceal beneficial ownership or move funds and goods on behalf of sanctioned parties.
- AIS manipulation
- Disabling or falsifying vessel tracking signals to hide location, port calls, or ship-to-ship transfers linked to sanctions evasion.
- Trade-based evasion
- Concealing sanctioned dealings through misdescribed goods, false invoicing, or undervaluation in trade documentation.
- Hawala
- Informal value-transfer system relying on trust and settlement between brokers, used to move funds outside formal banking channels.
- Strict liability
- US sanctions liability that does not require intent; a prohibited transaction by a US person is a violation even if unintentional.
- Voluntary self-disclosure
- Reporting one's own apparent sanctions violation to the regulator before investigation, a mitigating factor that can reduce penalties.
- Price cap
- Policy allowing services for Russian oil only if sold at or below a set price, enforced through attestations and documentation in the supply chain.
- Crypto mixer
- Service that obscures the origin of crypto assets, a sanctions-evasion risk and itself a target of designations.
- Ransomware payment
- Payment to a ransomware actor; OFAC warns such payments may violate sanctions if the recipient is designated, requiring risk-based due diligence.