Free ACAMS CAMS Actual Exam Questions s - Question 14 Discussion
between two parties in Europe and Asia. The payment is in Euros and involves the provision of
services to a company located in a jurisdiction subject to Office of Foreign Assets Control secondary
sanctions. Which factor is most important in determining the compliance officer's response?
C imo, since secondary sanctions target foreign parties regardless of US involvement.
Agree that C highlights the ongoing risk without a US link, but what about the role of the payment currency? Does using Euros instead of USD reduce exposure under OFAC’s secondary sanctions?
C imo. The key is that secondary sanctions don’t need a US nexus to apply, so even if the payment’s in Euros and involves Europe and Asia, the compliance risk remains. A and D seem off because they either limit the scope to US companies or certain sectors, which isn’t the case with secondary sanctions broadly. B is tricky but usually one-off transactions don’t automatically exempt you from sanctions risk. So, the presence of any indirect US ties or the sanctioned jurisdiction itself still matters most here.
C, since secondary sanctions apply without requiring a US connection.
C makes the most sense. Secondary sanctions are designed to pressure foreign entities regardless of a direct US connection, so the compliance officer must consider that risk seriously here.
C
Secondary sanctions can hit anyone, even without a US connection, so that's the biggest risk here. The other options either limit the scope wrongly or ignore the broad reach of these sanctions.
C Secondary sanctions can apply even without a direct US link, so that risk stays real. Options A and B downplay the scope, and D is too narrow since secondary sanctions aren’t just sector-specific.
Option C seems most relevant here. Even if there's no direct US involvement, secondary sanctions can still apply to foreign companies dealing with sanctioned jurisdictions. The key is that the risk of US sanctions remains for these foreign entities, so the compliance officer needs to consider that seriously. The other options either downplay the reach of secondary sanctions or focus too narrowly on the type of transaction or sectors involved. Feels like the question is testing awareness of how broad US secondary sanctions can be, especially in cross-border payments involving sanctioned areas.