Exam CGSS Topic 2 Question 48 Discussion

Actual exam question for ACAMS's CGSS exam
Question #: 48
Topic #: 2

Which statement best describes the difference between the requirements for calculating beneficial ownership for sanctions due diligence (SDD) and calculating beneficial ownership for AML in the US?

A. AML requirements identify a beneficial owner as a person who owns more than 50% of a legal entity, whereas the Office of Foreign Assets Control applies the 25% Rule to legal entity ownership for SDD. B. AML requirements identify a beneficial owner as a person who owns more than 25% of a legal entity, whereas the Office of Foreign Assets Control applies the 50% Rule to legal entity ownership for SDD. C. AML requirements identify a beneficial owner as a person who owns more than 51% of a legal entity, whereas the Office of Foreign Assets Control applies the 25% Rule to legal entity ownership for SDD. D. AML requirements identify a beneficial owner as a person who owns more than 20% of a legal entity, whereas the Office of Foreign Assets Control applies a higher threshold to legal entity ownership for SDD.

Suggested Answer: B Vote an answer

US AML requirements (such as the Customer Due Diligence Rule) define a beneficial owner as an individual who owns 25% or more of a legal entity. OFAC, however, applies the 50% Rule for sanctions due diligence: an entity is considered owned by a sanctioned person if the designated person holds, individually or collectively, 50% or more of the entity.
The AML 25% standard is not used for determining whether an entity is treated as sanctioned; instead, OFAC's ownership threshold is fixed at 50%. The correct distinction is the difference between AML's 25% threshold and OFAC's 50% Rule.
Reference from Sanctions and Compliance Domains:
Beneficial ownership thresholds under US AML customer due diligence rules.
OFAC's 50% Rule for sanctions ownership determinations.

by Isidore at Mar 28, 2026, 10:16 AM

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