Exam CGSS Topic 5 Question 90 Discussion

Actual exam question for ACAMS's CGSS exam
Question #: 90
Topic #: 5

Which measures should be incorporated into a comprehensive sanctions framework by a financial institution (FI)? (Select Two.)

A. The FI's management information reports should be available to everyone. B. The FI should not consider a broader set of controls for reviewing at a later stage. C. The FI should gather the required information on a best-efforts basis. D. The FI should ensure comprehensive training for people involved in the alert clearing process. E. The FI must have a robust screening control program with a clear strategy in place.

Suggested Answer: D,E Vote an answer

A comprehensive sanctions framework requires well-designed operational controls, including thorough training for staff responsible for alert review and sanctions decision-making. Sanctions and Compliance Domains specify that personnel involved in alert clearing must receive appropriate training to ensure awareness of regulatory expectations, sanctions typologies, and escalation procedures.
Additionally, the framework must include robust screening controls supported by documented strategy, governance, list-management processes, alert management rules, and ongoing testing. These elements form core requirements of sanctions compliance programs.
Management information reports are restricted to need-to-know distribution, and reliance on "best-efforts" is not compliant. Institutions must implement structured, risk-based controls, not minimal-effort approaches.
Reference:
Requirements for sanctions training and staff competency.
Necessity of a robust sanctions screening program with strategic oversight.
Internal governance and control expectations in sanctions frameworks.

by Egbert at Mar 31, 2026, 11:42 AM

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