SANCTIONS GOVERNANCE AND ENFORCEMENT – 25%
1.1 How sanctions are created, changed, and
enforced (e.g., global laws and regulations, legal
processes, assumptions and errors)

1.2 Key concepts of sanctions (e.g., definitions, UN
Security Council, OFAC, EU, UK-HMT, AUSTRAC
sanctions; multilateral v. unilateral sanctions;
restrictive measures)

1.3 Different types of sanctions (e.g., individuals,
countries, goods, vessels, sectoral sanctions,
terrorism-related sanctions)

1.4 Geographic scope of sanctions (e.g., the
IEEPA, extraterritorial reach, blocking statutes,
the effect on trade restrictions, national and
autonomous sanctions)

1.5 Beneficial control, ownership, and the 50% rule

1.6 License types and the scope of permitted
activities (e.g., authorities for issuing licenses,
assumptions and errors related to licenses,
license application processes, operational
challenges)

1.7 Principles of governance, risk-based approach,
and how they apply to sanctions screening (e.g.,
risk categories, regulator expectations)

SANCTIONS EVASION TECHNIQUES — 17.5%
2.1 Types of attempts that are made by illicit actors
to evade sanctions, including evasion techniques
related to payments and transactions

2.2 Trade-related evasion techniques (e.g., how
targets try to conceal the end-use of goods or
the identity of the end-user, export controls)

2.3 Methods that targets use to hide their identity
(e.g., shell companies, LLCs, restructuring,
ownership schemes).

SANCTIONS DUE DILIGENCE — 20%
3.1 Sanctions due diligence key concepts to
effectively mitigate sanctions risks (e.g.,
approach for assessing sanctions risks,
geographic scope, risk assessment formula,
transaction-level due diligence)

3.2 How to apply sanctions due diligence to different lines of business (e.g., luxury goods industry, retail banking, commercial banking, insurance)

3.3 Beneficial ownership calculation (e.g., compare
the 25% rule for AML to 50% rule for Sanctions,
EU guidance on beneficial ownership)

3.4 Key sanctions risk areas, including customers, the nature of their business, products, and jurisdiction (e.g., dual-use goods, differences between the EU and OFAC concerning due diligence and beneficial ownership)

3.5 Financial services and products as they relate to
sanctions risks

SANCTIONS SCREENING — 20%
4.1 Sanctions monitoring procedures and important
controls (e.g., similarities and differences
between AML monitoring and controls and
sanctions monitoring and controls, interdiction
software)

4.2 Screening key concepts, including Automated
Screening Tools (ASTs), interdiction systems,
algorithms, and regulatory expectations (e.g.,
inequalities and exclusion lists, filtering and
weighting of potential matches)

4.3 Customer and third-party name screening (e.g.,
common naming conventions, transliteration,
fuzzy logic, Romanization)

4.4 Payment screening process (e.g., common
methods for managing AST alerts, relevant fields
in a SWIFT payment message)

4.5 Sanctions technology (e.g., screening software,
matching algorithms, machine learning, artificial
intelligence)

4.6 Sanctions-related software features (e.g., match
proximity thresholds, validation)

4.7 Data management and analysis (e.g., list
management, predictive analytics, data quality.

SANCTIONS INVESTIGATIONS AND ASSET FREEZING — 17.5%
5.1 How to conduct investigations, keep records, and file reports

5.2 Sources of information to use in an investigation
(e.g., primary and secondary sources)

5.3 How to freeze assets, notify targets, and make
reports (e.g., institutional requirements for
managing frozen assets, identifying a target’s
assets