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Hi, Can you please share details of scoring and minimum scoring requirements to pass Certified Sanctions Specialist Exam?

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Dear Mridul:

The Number of correct answers required to pass the CSS Exam: 76 questions.

The CSS examination consists of seven domains. Below you will find the test objectives for each of the domains as well as the overall percentage weight of each domain.

I.             Sanctions Regime Types, Goals, Prohibitions and Effects: 10-12% 

  • Articulate the definition and different 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 effectiveness of sanctions and unintended consequences of sanctions

II.    Sanctions Imposers and Targets: 10-12%

  • 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 different 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. 

III. Sanctions Evasion: Typologies and Schemes: 6-8% 

  • 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


IV. Essential Components of a Risk-Based Sanctions Compliance Program in Different Industry Settings: 28-30% 


a.    Management Commitment

  • Obtain senior management commitment to and support of an organization’s risk-based sanctions compliance program 

b.   Designing and Implementing a Sanctions Risk Assessment in Different Industry Settings


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

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

c.    Internal Controls: Policies and Procedures


  • Develop policies and procedures based on industry leading practices 
  • Analyze new government policies and regulatory and enforcement developments

d.   Designated Sanctions Officer and Staffing 

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


e.   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.


f.    Due Diligence


  • Conduct risk-based due diligence on customers and other parties in a financial institution setting 
  • Conduct risk-based due diligence in maritime shipping, commercial insurance, global commodities, or trade finance setting 
  • Conduct risk-based due diligence on customers and other parties in other sector settings 
  • Ensure that beneficial ownership of entities affiliated with sanctioned parties is reasonably determined 
  • Set up red flag indicators in a sanctions compliance program associated with sanctions evasion typologies 


g.    Testing and Auditing


  • Develop and report on operational and investigation metrics (e.g., subpoenas, blocked or rejected transactions by business partners) 
  • Test compliance controls to confirm they are working as expected and designed 
  • Implement a comprehensive, independent and objective regular audit function. 


V. Role of Technology and List Screening: 20-22%


  • Articulate general principles, concepts and fundamental pillars behind screening and the different ways that sanctions screening can take place
  • Develop, implement, maintain watch list screening tools 
  • Evaluate and hire list screening vendors 


VI. Other Operational Issues Contributing to an Effective and Efficient Sanctions Compliance Program : 14-16%


  • 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 offering additional protection in higher risk situations and dealing with contractual obligations when sanctions impact on a party’s 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.


VII. Enforcement and Conducting or Supporting Investigations into Sanctions Violations: 6-8% 


  • 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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