CGSS study plan
CGSS · Give each week a clear focus.
8 weeks · About 6 hours per week
Sanctions Compliance Program Design and Governance
Map the core elements of a sanctions compliance program (policy, procedures, controls, training, audit, remediation) and rank them by exam weight
Draft a written risk-assessment methodology that scores customer, product, channel, geography, and transaction risk
Define governance roles: board and senior management oversight, sanctions compliance officer authority, and escalation paths
Distinguish first-line, second-line, and third-line responsibilities in a sanctions control environment
Your checkpoint
A one-page sanctions program framework diagram plus a 300-word risk-assessment methodology memo with a scoring rubric you can apply to a sample customer
Sanctions Compliance Program Design and Governance & Sanctions Fundamentals and Legal Framework
Build a policy-to-control traceability table linking each written requirement to a named control and control owner
Design a training program that differentiates role-based content for front office, operations, and screening analysts
Construct a testing and audit calendar covering independent review frequency and sample-selection logic
Identify the legal hierarchy of sanctions authorities (statutes, executive orders, regulations, general licenses) and where program obligations originate
Your checkpoint
A completed traceability matrix of at least 12 requirements mapped to controls, owners, and test methods, plus a 10-question role-based training outline
Sanctions Fundamentals and Legal Framework
Explain the jurisdictional reach of primary and secondary sanctions and apply it to three hypothetical fact patterns
Differentiate asset freezes from trade restrictions and prohibitions on dealing in blocked property
Classify conduct as prohibited, authorized by general license, or requiring a specific license
Interpret key defined terms (blocked person, 50 percent rule concept, facilitation, dealing) and apply them in short scenario answers
Outline recordkeeping, reporting, and voluntary self-disclosure obligations with their triggers
Your checkpoint
A one-page legal framework reference sheet (authorities, definitions, licensing logic) plus written answers to five scenario questions scored against your own answer key
Sanctions Programs and Regulatory Regimes
Compare the structure, scope, and listing mechanics of at least four major sanctions programs by jurisdiction and target type
Diagram the listing and designation process, including how designations propagate to owned or controlled entities
Identify sectoral versus comprehensive restrictions and the compliance implications of each
Map at least three national or supranational regimes and note where their requirements diverge or overlap
Your checkpoint
A comparison matrix of at least four sanctions programs across scope, listing authority, licensing posture, and key prohibitions
Sanctions Programs and Regulatory Regimes & Sanctions Screening, Monitoring and Investigation
Translate each program's prohibitions into concrete screening list requirements and data fields
Specify matching logic: exact versus fuzzy matching, threshold tuning, secondary identifiers, and transliteration handling
Define list management controls including update frequency, version control, and back-screening after list changes
Design the four screening moments (onboarding, payment, counterparty/trade, periodic rescreen) and state the decision rule at each
Your checkpoint
A screening requirements specification covering list sources, matching parameters, thresholds, and disposition paths for each of the four screening moments
Sanctions Screening, Monitoring and Investigation
Write an alert triage procedure that separates true matches, false positives, and indeterminate results with defined SLA timelines
Draft an investigation checklist covering ownership and control tracing, vessel or shipment review, and adverse media corroboration
Construct a monitoring scenario set from red flags such as third-country payments, unusual routing, and dual-use goods indicators
Explain alert disposition documentation standards needed to withstand examiner review
Your checkpoint
A full investigation playbook with a triage decision tree, a 15-item evidence checklist, and two documented mock case files (one escalation, one closure)
Sanctions Evasion, Enforcement and Emerging Issues
Identify common evasion typologies including ownership obfuscation, transshipment, invoice manipulation, and use of intermediaries
Diagnose enforcement patterns: strict-liability tendencies, penalty aggravators and mitigators, and the value of self-disclosure
Evaluate emerging risk areas such as new payment rails, virtual assets, and shifting designation regimes
Recommend control enhancements that address each typology you identified
Your checkpoint
An evasion typology-to-control mapping table of at least 10 typologies, each with a detection indicator and a specific control enhancement
Sanctions Fundamentals and Legal Framework & Sanctions Programs and Regulatory Regimes & Sanctions Compliance Program Design and Governance & Sanctions Screening, Monitoring and Investigation & Sanctions Evasion, Enforcement and Emerging Issues
Synthesize all five domains into an integrated case study that moves from risk assessment through screening, investigation, and remediation
Re-test weak objectives identified in earlier milestones and close gaps
Practice timed, scenario-based questions under exam conditions and review every missed item for the underlying rule
Your checkpoint
A scored 40-question timed practice set with a written error log identifying each missed objective and the corrective study action taken
Milestones
Week 2: Explain the program framework and risk methodology from memory in 10 minutes and pass a self-check on legal hierarchy of sanctions authorities without notes
Week 4: Score at least 80 percent on a 20-question self-test covering domains 1 and 2, with no recurring miss on the same concept
Week 6: Complete two mock investigations end-to-end within time limits and defend each disposition against a written examiner-style challenge
Week 8: Score at least 85 percent on the timed 40-question mixed practice set and show an error log with zero unresolved objectives