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Exam CGSS Topic 1 Question 96 Discussion

Actual exam question for ACAMS's CGSS exam
Question #: 96
Topic #: 1
Independent testing related to sanctions screening should be conducted by which group with adequate technology expertise?

Suggested Answer: A Vote an answer

Sanctions and Compliance Domains state that independent testing and auditing must be conducted by a group separate from the sanctions operations and screening management teams. Internal audit is typically the independent function with sufficient technology and control expertise to assess system performance, threshold calibration, governance, and rule sets.
Teams involved in day-to-day operations (investigations, list management, risk assessment) cannot test their own work due to conflicts of interest.
Reference:
OFAC and industry expectations for independent testing.
Internal audit as the designated independent review function.

by Ward at Dec 14, 2025, 07:28 AM

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