[2026年02月]更新のCGSS試験問題集、CGSS練習テスト問題 [Q42-Q64]

[2026年02月]更新のCGSS試験問題集、CGSS練習テスト問題

検証済みCGSS問題集PDF資料 [2026]

ACAMS CGSS（認定グローバル制裁スペシャリスト）認定試験は、グローバル制裁の分野に特化した専門家を目指す人向けに設計されています。この認定はグローバルに認められており、個人の制裁遵守に関する知識と理解を検証します。CGSS認定試験は、金融犯罪に対する取り組みに専念する国際的な主要組織である認定反マネーロンダリングスペシャリスト協会（ACAMS）によって実施されています。

ACAMS CGSS 認定試験は、制裁コンプライアンスの分野の専門家が専門知識を認定し、キャリアを推進するための貴重な機会です。これは、この重要なコンプライアンス分野で卓越性への取り組みを示す厳格で尊敬される資格です。

 

質問 # 42
A bank has a zero-tolerance policy for conducting activity with sanctioned entities or countries. The bank is asked to act as an intermediary to process a remittance. An analyst blocks the remittance because its destination is a sanctioned country. Which is the appropriate step for the analyst to take?

• A. Process the wire and file a suspicious activity report to the regulator.
• B. Escalate the wire for consideration and processing.
• C. Reject and return the remittance and notify the sending bank of the return for compliance reasons.
• D. Process the wire because it falls under a license/exemption to sanctions for the provision.

正解：C

解説：
When a bank has a zero-tolerance stance regarding sanctioned jurisdictions and no applicable license or exemption exists, the appropriate response is to reject and return the remittance, informing the sending bank that the transaction cannot be processed for sanctions compliance reasons.
Escalation for consideration is inconsistent with a zero-tolerance policy. Filing a SAR does not authorize processing a prohibited payment. Processing on the assumption of a license without one presents regulatory violations.
Reference:
Requirement to reject prohibited transactions absent authorization.
Policy alignment with sanctions prohibitions and geographic restrictions.

質問 # 43
A sanctions analyst reviews payment requests from a sanctioned country. After investigation, it appears that the request represents a medicine export from a pharmaceutical company to a sanctioned country. Which step should the analyst take next?

• A. Demand a specific license.
• B. Check for applicable general licenses or exemptions.
• C. Review the counterparty.
• D. Reject the payment.

正解：B

解説：
In sanctions compliance frameworks applied globally by bodies such as OFAC, the EU, the UN, the UK, Canada, and Australia, transactions involving humanitarian goods, including medicine and medical supplies, are treated under specific regulatory categories. These frameworks include humanitarian exemptions, general licenses, and permitted transactions for medical or health-related items. The standard compliance expectation requires an analyst to determine whether the activity is already authorized before taking restrictive action.
The Sanctions and Compliance Domains specify that when a transaction involves potential humanitarian goods, the analyst must confirm whether a general license or exemption applies. General licenses commonly authorize exports of medicines, medical devices, and humanitarian materials to sanctioned jurisdictions. The rule requires verification of these authorizations prior to escalation, rejection, or requesting a specific license.
If a general license exists for the type of goods or activity, the transaction may proceed in accordance with regulatory conditions. Only when no exemption or general license applies should a specific license be sought. Therefore, the correct immediate step for the analyst is to check applicable general licenses or exemptions related to medical exports.
Reference from Sanctions and Compliance Domains:
Regulatory requirements relating to humanitarian exemptions under sanctions programs.
General license structures for medical and humanitarian goods in sanctions regimes.
Compliance procedures directing analysts to verify authorizations or exemptions before rejecting or escalating transactions.
Standard sequencing: determine applicability of general licenses or exemptions prior to requesting a specific license.

質問 # 44
Which of the following steps is/are not involved in building a causal model?

• A. Be clear about the problem statement before starting.
• B. Construct the causal pathwaysas* linking cause and effect.
• C. Identify potential causes.
• D. Differentiate variables that may belong in causal chains.
• E. Identify likely effects.

正解：D、E

質問 # 45
The roles of the HM Treasury (Office of Financial Sanctions Implementation) includes the following except?

• A. Can impose monetary penalties
• B. UK's competent authority for implementing financial sanctions
• C. Enforces breaches of trade sanctions
• D. Makes designations under UK domestic regimes
• E. Investigates breaches of financial sanctions

正解：C、E

質問 # 46
All of the following are functions of the HM Treasury (Office of Financial Sanctions Implementation) except?

• A. Can impose monetary penalties
• B. Negotiates all international sanctions
• C. Makes designations under UK domestic regimes
• D. UK's competent authority for implementing financial sanctions

正解：A、C、D

質問 # 47
The EU-Iran Instrument in Support of Trade Exchange (INSTEX), which allowed EU purchases of Iranian oil after 2018, is an example of:

• A. sanctions evasion.
• B. a blocking statute.
• C. a special purpose vehicle.
• D. a general license.

正解：C

解説：
INSTEX was established by EU member states as an operational mechanism designed to facilitate limited and compliant trade with Iran after the re-imposition of U.S. secondary sanctions in 2018. According to the Sanctions and Compliance Domains, INSTEX is categorized as a special purpose vehicle, created specifically to permit trade transactions without reliance on traditional cross-border payment routes exposed to U.S. sanctions risk.
Special purpose vehicles are defined within sanctions frameworks as structured entities created to conduct or support specific categories of trade or payments where direct financial transfers are restricted or exposed to sanctions risk. INSTEX was designed to match European exporters and importers with Iranian counterparts through a barter-style internal clearing arrangement, avoiding external USD payment flows.
It is not a general license, nor is it a blocking statute. It also does not constitute sanctions evasion because it was formally established, publicly announced, and structured within EU legal parameters. Its purpose was to ensure compliance while maintaining limited humanitarian and permitted trade channels.
Reference from Sanctions and Compliance Domains:
Definitions and characteristics of special purpose vehicles in sanctions environments.
Description of EU mechanisms facilitating compliant trade with sanctioned jurisdictions.
Distinction between SPVs, blocking statutes, and licensing frameworks.
Regulatory context regarding INSTEX as an EU-created structured trade mechanism.

質問 # 48
Which unit function has been identified as critical to managing sanctions risks?

• A. Third-party due diligence firms
• B. Human resources
• C. Audit and testing
• D. Credit risk management

正解：C

質問 # 49
Transliteration is defined as the:

• A. ways in which an individual's name is given to, or used by, the individual.
• B. conversion of text from one script into another.
• C. process of matching an internal record against a sanctioned list record.
• D. process of taking a non-Latin writing system and converting it into Latin script.

正解：B

解説：
Transliteration is defined as converting writing from one script into another while preserving pronunciation as closely as possible. In sanctions screening, transliteration is important because sanctioned parties may appear in multiple scripts (e.g., Cyrillic, Arabic, Mandarin) and the automated screening system must recognize these variations.
While option B focuses specifically on converting non-Latin scripts into Latin, sanctions screening requires a broader definition that applies to any script-to-script conversion relevant to matching names globally. Thus, the correct definition is the general conversion of text from one script into another.
Reference from Sanctions and Compliance Domains:
Definition of transliteration in sanctions screening and name-matching methodologies.
Need for script conversion to support accurate detection of sanctioned parties across language systems.

質問 # 50
In the period between the 1983 amendment and the adoption of the current Rule 11 in 1993, which of the following propositions had support in the face of widespread criticism in the legal community:

• A. Rule 11 has too rarely been enforced through nonmonetary sanctions, and with cost-shifting having become the normative sanction
• B. Rule 11 has occasionally created problems for a party which seeks to assert novel legal contentions
• C. Rule 11, in conjunction with other rules, has tended to impact plaintiffs more frequently and severely than defendants
• D. Rule 11 provides little incentive, and perhaps a disincentive, for a party to abandon positions after determining they are no longer supportable in fact or law

正解：A、B、C、D

質問 # 51
Which of the following are UK government departments and agencies involved in sanctions:

• A. HM Treasury
• B. Department for International Trade
• C. HM Revenue & Customs (HMRC)
• D. Foreign & Commonwealth Office

正解：A、B、C、D

質問 # 52
Aviation sanctions are intended to ban flights to and from a destination or to obstruct a destination's ability to use flights within its own sphere of influence as part of the security council's sanctions schemes which factors controlled by a country are prohibited as part of its penalty schemes?

• A. Provision of transfer of assets through it
• B. Provision of technical assistance of the aircraft
• C. Provision of manufacture or maintenance of aircraft
• D. Provision of guidance and training of the aircraft
• E. None of the above-mentioned statements

正解：B、C、D

質問 # 53
ABC Industries is a legal entity owned by Entity X (30%), Entity Y (25%), and Entity Z (45%). Entity X is a Specially Designated National (SDN) under OFAC sanctions, and Entity Y is owned (80%) by an OFAC SDN. Is ABC Industries a blocked entity under OFAC sanctions?

• A. Yes; ABC Industries is a blocked entity due to aggregate ownership (50%) by two OFAC SDNs.
• B. No; ABC Industries is not a blocked entity since aggregate OFAC SDNs' ownership is below 50%.
• C. Yes; ABC Industries is a blocked entity due to ownership by one OFAC SDN.
• D. No; ABC Industries is not a blocked entity since it is not listed as an OFAC SDN.

正解：A

解説：
OFAC's 50 Percent Rule requires aggregation of ownership by SDNs and entities owned 50% or more by SDNs.
Ownership breakdown:
* Entity X (SDN) → 30%
* Entity Y (owned 80% by an SDN) → treated as an SDN → contributes 25%
* Total SDN-derived ownership = 30% + 25% = 55%
Since aggregate SDN ownership exceeds 50%, ABC Industries is automatically considered a blocked entity, even though Entity Z is not sanctioned.
Options B and C are incorrect because explicit listing is not required-ownership triggers blocking. Option A is incorrect because one SDN at 30% alone is insufficient, but combined ownership is.
Reference:
OFAC 50 Percent Rule (aggregation principle).
Treatment of entities majority-owned by SDNs as SDNs for ownership calculations.

質問 # 54
Which directs the Office of Foreign Assets Control to list non-US persons as Specially Designated Nationals?

• A. Executive Orders issued by the US President
• B. UN Security Council Resolutions
• C. Sectoral Sanctions Identifications issued by the US Treasury Department
• D. Financial Action Task Force Recommendations

正解：A

解説：
OFAC designations-including designating non-US persons-are authorized through Executive Orders (EOs) issued by the President under statutory authority such as IEEPA or the Trading With the Enemy Act. Executive Orders define which categories of persons or entities may be designated and direct OFAC to act.
Sectoral Sanctions Identifications relate to sectoral sanctions, not full SDN designation. FATF recommendations are global AML standards, not OFAC authorities. UN resolutions may influence US sanctions but are not the legal authority directing SDN listings.
Reference:
Executive Orders as legal authority for OFAC SDN designations.
Relationship between US statutory authority and OFAC implementation.

質問 # 55
According to OFSI, what from the listed below can be defined as as fundsas?

• A. Interest, dividends or other income on or value accruing from or generated by assets
• B. Deposits with financial institutions or other entities
• C. Cash, cheques, claims on money, drafts, money orders
• D. Letters of credit
• E. Materials and equipment

正解：A、B、C、D

質問 # 56
EU Restrictive Measures apply: (Select Two.)

• A. on a vessel under the jurisdiction of an EU Member State.
• B. to a company incorporated under the law of a non-EU country, that is 45% owned by a national of an EU Member State.
• C. to a company outside the territory of the EU, which is incorporated or constituted under the law of an EU Member State.
• D. within a non-EU country, which has a double taxation convention with all EU Member States.
• E. within a non-EU country which is part of the Customs Union agreement with the EU.

正解：A、C

解説：
EU Restrictive Measures apply to all persons and entities within the territory of the EU, including airspace and territorial waters, and to any vessel or aircraft under the jurisdiction of an EU Member State. This establishes that sanctions obligations extend to vessels registered under EU jurisdictions regardless of location.
EU sanctions also apply to all legal persons, entities, and bodies incorporated or constituted under the law of an EU Member State, even when those entities operate entirely outside EU territory. Legal incorporation under EU law creates an ongoing obligation to comply with EU sanctions.
EU ownership by itself does not trigger sanctions applicability, so a non-EU company that is 45% owned by an EU national does not fall under EU Restrictive Measures. Additionally, arrangements such as double-taxation conventions or participation in customs union agreements do not extend the territorial or legal applicability of EU sanctions to non-EU jurisdictions.
Reference from Sanctions and Compliance Domains:
Territorial applicability of EU sanctions, including vessels and aircraft under Member State jurisdiction.
Applicability to companies incorporated under EU Member State law regardless of geographic operations.
Legal and territorial definitions outlining the scope of EU Restrictive Measures.

質問 # 57
In the late spring of 1998, the use or threat of sanctions by the US. Washington and its European partners announced additional steps of economic denial in a collective effort to discourage the escalation of which military force?

• A. Japanese military
• B. Serbian military
• C. Chinese military
• D. Syrian military
• E. German military

正解：B

質問 # 58
If, in a roll-call, the members of the league council unanimously agreed with the subcommittee's conclusions on war and convent breach, where could the matter further proceed?

• A. To the armed forced
• B. To the office of President
• C. To the Convent
• D. To the Security Council
• E. To the league assembly

正解：E

質問 # 59
Your obligation to report to OFSI is in addition to any other non-financial sanctions reporting obligations you may have and that includes the following except?

• A. Report under the OFSI Data Protection Act 1998
• B. Report under section 19 of the Terrorism Act 2000.
• C. Reporting required by your regulator
• D. Submitting Suspicious Activity Reports (SARs) to the National Crime Agency (NCA) under the Proceeds of Crime Act 2002.
• E. Sunbmisson of designations made under ATCSA 2001

正解：A、E

質問 # 60
What do we learn from the Vulnerability Analysis?

• A. Different types of sanctions
• B. Women are at greater risk of malnutrition
• C. Loss count
• D. Discrimination between ethnic groups
• E. Young children are at greater risk because they require nutrients for their natural growth

正解：B、E

質問 # 61
The Office of Foreign Assets Control has designated which types of high-risk persons or entities in the digital asset ecosystem? (Select Three.)

• A. Persons hacking and stealing cryptocurrency
• B. Credit unions
• C. Central banks
• D. Cryptocurrency exchanges
• E. Software developers
• F. Mixers

正解：A、D、F

解説：
OFAC has designated:
* Hackers and cyber actors involved in cryptocurrency theft.
* Cryptocurrency exchanges facilitating illicit transactions or supporting sanctioned jurisdictions.
* Mixers (tumblers) known to anonymize blockchain transactions and facilitate laundering and sanctions evasion.
Software developers (D) are generally not designated unless directly linked to illicit activity. Credit unions and central banks are not typical OFAC digital-asset designations.
Reference:
OFAC digital asset designations (e.g., mixers, DPRK cyber actors).
Sanctions risk indicators in the virtual currency sector.

質問 # 62
Which of the following statements is/are true for Proximal and distal causes?

• A. Prior events leading to the proximal cause, removed in the sequence of causal events are referred to as distal causes
• B. The process of causation can't be examined to define the order and relations among relevant variables.
• C. The steps from distal and proximal causes to an input of interest are referred to as a chain of causation.
• D. A proximal cause is an event that immediately precedes the outcome of interest.
• E. Causal pathways are defined by detailing steps, tracing backward from the outcome, or forward from an initial event.

正解：A、D、E

質問 # 63
Which acts were born of a sense of frustration and necessity in Congress?

• A. CDA of 1992
• B. Militia Act of 1991
• C. Helms-Burton Act of 1996
• D. Unfunded Mandates Reform Act of 1995
• E. National Banking Act of 1963

正解：A、C

質問 # 64
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CGSS認定試験はグローバルに認められ、金融業界の雇用主から高い評価を受けています。CGSS認定を持つことは、専門性へのコミットメントや制裁コンプライアンスの最新動向について常に学び続ける決意を示すことを意味します。CGSS認定を持ったプロフェッショナルを雇用する雇用主は、制裁規制に準拠するために必要な知識とスキルを持った個人を雇用していることを確信することができます。

 

最新のCGSS実際の無料試験問題は更新された103問あります：https://www.goshiken.com/ACAMS/CGSS-mondaishu.html

無料CGSS試験ブレーン問題集認定ガイド問題と解答：https://drive.google.com/open?id=1PN4Pb_u9QMyqRqo4yFwIPyeSgTOkqKq5