Exam CGSS Topic 1 Question 91 Discussion

Actual exam question for ACAMS's CGSS exam
Question #: 91
Topic #: 1

The legal counsel of a Canadian-based entity is drafting a contract in connection to selling goods to a legal entity client incorporated in Iran that operates in the financial sector of the Iranian economy. Which item should be addressed in the contract?

A. Parties must commit to issue or receive all payments related to the contract via cross-border wire payments denominated in US B. Parties must commit to comply with EU operators' obligations outlined under the EU's blocking statute. C. Parties must commit to avoid mentioning or including any reference to Iran in financial transactions related to the contract. D. Parties must commit that the transaction will be conducted in compliance with Canadian sanctions related to Iran.

Suggested Answer: D Vote an answer

Canadian sanctions law requires that Canadian persons ensure all commercial dealings comply with Canadian sanctions regulations, including those concerning Iran. Contracts involving sanctioned countries must incorporate compliance clauses reflecting applicable Canadian law.
The EU Blocking Statute does not apply to Canadian entities. Avoiding references to Iran is ineffective and does not eliminate sanctions exposure. USD payments may introduce US sanctions exposure and are not advisable in this context.
Reference:
Canadian sanctions obligations under SEMA and related Iran regulations.
Requirement for legal compliance clauses in contracts involving sanctioned jurisdictions.

by Les at Dec 28, 2025, 02:56 AM

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