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Free CSS Practice Questions

10 free, exam-style Certified Sanctions Specialist (CSS) practice questions with answers and explanations. No signup required. Work through them below, then take the full free CSS practice test to study every exam domain.

Question 1

A bank is onboarding a trading company incorporated in a third country. Due diligence reveals that two individuals on OFAC's SDN List each hold a 30 percent ownership interest in the company. The company itself does not appear on any OFAC list. Under OFAC's 50 Percent Rule, the bank should treat the company as:

  1. Not blocked, because the company itself does not appear anywhere on the OFAC SDN List
  2. Not blocked, because neither owner individually holds a majority interest
  3. Blocked, because blocked persons hold 50 percent or more of it in aggregate
  4. Blocked only if the two owners are shown to be acting in concert
Show answer & explanation

Correct answer: C - Blocked, because blocked persons hold 50 percent or more of it in aggregate

Question 2

A U.S. company's foreign subsidiary plans a transaction with a sanctioned party that the U.S. parent could not lawfully undertake directly. A U.S.-person employee at the parent approves the deal and helps arrange it for the subsidiary. The employee's conduct is BEST characterized as:

  1. Prohibited facilitation of a transaction by a U.S. person
  2. Permissible, because the foreign subsidiary is a separate legal entity
  3. A reportable but otherwise lawful extraterritorial transaction
  4. Permissible under the general license covering intra-group transactions
Show answer & explanation

Correct answer: A - Prohibited facilitation of a transaction by a U.S. person

Question 3

A U.S. bank receives a funds transfer that is prohibited under a sanctions program, but no blocked person holds any property interest in the funds. Under OFAC requirements, the bank should:

  1. Block the funds and hold them in an interest-bearing blocked account
  2. Reject the transaction and report it to OFAC
  3. Process the transaction but file a suspicious activity report
  4. Return the funds to the originator without filing any report
Show answer & explanation

Correct answer: B - Reject the transaction and report it to OFAC

Question 4

To reduce a heavy investigation workload, a bank raises the match threshold on its sanctions screening filter so that only very close name matches generate alerts. The MOST significant compliance risk created by this change is:

  1. An increase in false positives requiring manual investigation
  2. A noticeably higher rate of duplicate alerts generated for the same customer record
  3. Slower processing of legitimate customer transactions
  4. A greater chance that a true match is missed (a false negative)
Show answer & explanation

Correct answer: D - A greater chance that a true match is missed (a false negative)

Question 5

A multinational must identify which EU legal instrument makes a sanctions measure directly binding and applicable to private companies across all member states, without further national legislation. That instrument is:

  1. A Council Decision adopted under the Common Foreign and Security Policy
  2. A Directive issued by the European Commission for national transposition
  3. A Council Regulation adopted under Article 215 of the TFEU
  4. A Resolution passed by the European Parliament
Show answer & explanation

Correct answer: C - A Council Regulation adopted under Article 215 of the TFEU

Question 6

A blocked person holds a 40 percent ownership stake in a company and, through board appointments, exercises majority control over its decisions. No other blocked persons hold any interest. Under OFAC's 50 Percent Rule, the company is:

  1. Automatically blocked, because the blocked person exercises decisive managerial control over it
  2. Not automatically blocked; the rule turns on ownership, not control
  3. Blocked, because ownership combined with control exceeds the 50 percent threshold
  4. Outside OFAC's concern entirely, since the ownership stake is below 50 percent
Show answer & explanation

Correct answer: B - Not automatically blocked; the rule turns on ownership, not control

Question 7

During a transaction review, a compliance analyst notes that a tanker switched off its Automatic Identification System (AIS) for several days in open water near a sanctioned port, then resumed transmitting. This pattern is a recognized indicator of:

  1. A deceptive shipping practice indicative of potential sanctions evasion
  2. Routine maintenance of the vessel's onboard navigation equipment
  3. A standard measure taken to avoid piracy while transiting high-risk waters
  4. Compliance with international maritime data-privacy requirements
Show answer & explanation

Correct answer: A - A deceptive shipping practice indicative of potential sanctions evasion

Question 8

A company appears on OFAC's Sectoral Sanctions Identifications (SSI) List, and a U.S. financial institution holds funds belonging to it. Compared with a person on the SDN List, the SSI-listed company's property is:

  1. Equally blocked, because both lists are maintained by OFAC
  2. Subject to a full asset freeze pending OFAC review
  3. Blocked, but only for transaction amounts above a regulatory threshold
  4. Not blocked; only the specific sectoral restrictions apply
Show answer & explanation

Correct answer: D - Not blocked; only the specific sectoral restrictions apply

Question 9

A general license issued by OFAC is BEST described as:

  1. An individual authorization granted to one specifically named applicant for a single defined transaction
  2. A published authorization permitting a defined category of transactions without a separate application
  3. A statutory exemption that applies automatically to all persons
  4. A one-time waiver issued after a violation has occurred
Show answer & explanation

Correct answer: B - A published authorization permitting a defined category of transactions without a separate application

Question 10

A U.S. company inadvertently processes a transaction involving a sanctioned party, with no knowledge that the party was sanctioned. With respect to OFAC civil liability, the company:

  1. Cannot be penalized in any way, because it genuinely and demonstrably lacked knowledge of the violation
  2. Is liable only if OFAC proves that it acted willfully
  3. May still be liable, because OFAC civil enforcement applies a strict-liability standard
  4. Is automatically subject to criminal prosecution
Show answer & explanation

Correct answer: C - May still be liable, because OFAC civil enforcement applies a strict-liability standard

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