CGSS study materials
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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.