[2026年03月11日] 完全版最新の問題集でPDFで最新CGSS試験問題と解答 [Q21-Q40]

[2026年03月11日] 完全版最新の問題集でPDFで最新CGSS試験問題と解答

無料で使えるCGSS試験問題集で100%合格できる試験簡単に合格させるGoShiken

ACAMS CGSS試験は、制裁コンプライアンスの専門家として認められているグローバルな標準として認識されています。金融機関、政府機関、および制裁規制の対象となる他の組織で働く個人のニーズに対応するよう設計されています。試験は、制裁の歴史と進化、異なる種類の制裁規制、および制裁コンプライアンスに関連する課題や機会など、幅広いトピックをカバーしています。

 

質問 # 21
In the event of a sanctions violation, the inclusion of a sanctions clause in a trade contract can:

• A. act as a specific license allowing the contract to be fulfilled.
• B. define which sanctioned elements are prohibited in the execution of the contract.
• C. identify the liability for any fines related to sanctioned entities.
• D. enforce the contract if sanctions are imposed on any of the parties.

正解：B

解説：
Sanctions and Compliance Domains state that sanctions clauses in trade contracts are used to:
* clarify prohibited activities,
* define obligations of the parties in case sanctions become applicable, and
* ensure business partners understand compliance expectations.
A sanctions clause cannot enforce a contract when sanctions apply (B), cannot assign liability for regulatory fines (C) beyond legal requirements, and cannot operate as a license (D). Only regulators (e.g., OFAC, EU authorities) can authorize activities by issuing licenses.
Reference:
Trade contract sanctions clauses and their function.
Legal requirements surrounding sanctions clauses and regulatory authority.

質問 # 22
An EU and US-based retail company sells various goods globally. What product may pose export sanctions violations for the company?

• A. Art reproductions
• B. Cigars
• C. Textbooks
• D. Toys

正解：B

解説：
Cigars, particularly those originating from Cuba or other embargoed jurisdictions, fall under both EU and US export sanctions restrictions. Under US OFAC regulations, Cuban-origin goods-including cigars-are strictly prohibited from import, export, resale, or re-export by US persons. EU sanctions may also restrict trade with embargoed or designated jurisdictions.
Textbooks, toys, and art reproductions generally do not fall under export prohibitions unless tied to dual-use concerns or specific jurisdictions, which is not indicated here. Cigars present the most direct and well-established sanctions risk.
Reference:
US OFAC Cuban Assets Control Regulations on Cuban-origin goods.
EU and US export controls covering embargoed jurisdictions and prohibited commodities.

質問 # 23
The fall of the Soviet Union shifted the policy of Washington. Shambaugh stated that there was a strong tendency among Chinese officials and scholars, in general, to view the US as:

• A. A friendly nation that casts the economic and military strength across the globe.
• B. A revisionist movement whose declared purpose is to uphold the authority of Chinese leaders.
• C. A revisionist power whose stated aim is to challenge the plausibility of Chinese leaders and to transform the nature of Chinese politics.
• D. A violent and dominant force that is pushing its economic and military strength across the globe.

正解：C、D

質問 # 24
A bank is processing a trade finance transaction and has a legal obligation to complete the transaction. After completing its sanctions review, the bank determines there are multiple red flags indicative of counterfeiting. Which are the appropriate next steps for handling the transaction?

• A. Block the transaction, place the funds in an interest-bearing account, and file a report on the transaction.
• B. Reject the transaction and file a report on the transaction with the appropriate regulator.
• C. File a suspicious activity report and notify the customer of the red flags identified during the review.
• D. Process the transaction and refer the transaction for further investigation by the bank's financial intelligence unit.

正解：B

解説：
Sanctions and Compliance Domains specify that when a transaction shows significant sanctions or illicit-trade red flags, a bank must avoid executing the transaction if it risks breaching sanctions restrictions. If the bank identifies discrepancies, counterfeiting indicators, or potential sanctions violations, the transaction must be rejected unless a blocking requirement applies.
Blocking applies only when a sanctioned party or property interest is identified. In this scenario, because there are red flags but no confirmed designated person, the appropriate action is to reject the transaction and file the relevant report with the competent authority.
Banks should not process the transaction and investigate later, nor should they disclose red-flag details to customers. Reporting requirements prohibit tipping-off in such regulatory contexts.
Reference from Sanctions and Compliance Domains:
Guidance on rejection versus blocking in trade finance risks.
Reporting obligations when red flags indicate possible sanctions exposure.
Prohibition on providing details of internal investigations to customers.

質問 # 25
Under what objective does the Security Council has imposed sanctions to facilitate the return of refugees and displaced persons in the Former Republic of Yugoslavia (FRY)?

• A. Promoting good governance
• B. Bringing about disarmament or arms control
• C. Ending a rebellion, invasion, or external interference
• D. Facilitating the establishment and consolidation of peace
• E. Facilitating the exercise or protection of human rights

正解：E

質問 # 26
"Al-Falah Company", registered in Dubai, wants to open an account at a financial institution. Through due diligence, the compliance team finds out that "El-Fallah Investments", based in Iraq, is under UN sanctions for facilitating terrorism financing. The listed Chief Executive Officer (CEO) of the sanctioned entity is not the same as the CEO of the potential client. How should the compliance team proceed?

• A. There is insufficient reason to escalate the case for further investigation and the client can be onboarded.
• B. The potential client should not be onboarded and the regulator must be notified.
• C. There are enough similarities to pursue further investigation before a decision can be made.
• D. This is a near match, thus the client should only be onboarded depending on the financial institution's risk appetite.

正解：C

解説：
Sanctions and Compliance Domains state that when entities share similar names, regions, or other characteristics with a sanctioned party - even when executive leadership differs - the institution must perform enhanced due diligence to rule out affiliation, ownership, or control links.
The similarity in names ("Al-Falah" vs. "El-Fallah"), geographic proximity, and the involvement of UN-sanctioned terrorism-related activity require deeper investigation. Compliance teams must confirm corporate records, ownership structure, purpose, and possible indirect connections before making a determination.
Automatic rejection is premature without evidence. Onboarding without further investigation is inappropriate.
Reference:
Name similarity and geographic proximity as sanctions escalation triggers.
Requirements for enhanced due diligence when possible indirect links exist.

質問 # 27
Which is accurate guidance that can be applied in a situation where a customer's funds have been blocked or frozen?

• A. The customer may be notified and can be directed to the appropriate government authority.
• B. The customer cannot be notified but can be directed to the appropriate governmental authority.
• C. The customer cannot be notified because it is prohibited under sanctions regulations.
• D. The customer may be notified but the reason cannot be provided.

正解：A

解説：
Sanctions and Compliance Domains state that institutions may notify the customer that their funds have been blocked or frozen, provided the notification does not reveal internal compliance processes or compromise legal obligations.
The customer may also be directed to the competent authority (such as OFAC or a national sanctions regulator) to seek guidance or licensing relief.
There is no blanket prohibition against notifying the customer; however, the institution must provide factual notification without offering legal advice or operational details.
Reference:
Guidance on customer communication after blocking actions.
Requirements to refer customers to competent authorities for inquiries or license requests.

質問 # 28
According to the Office of Foreign Assets Control (OFAC), USD can be used in transactions with Cuba when the transaction involves:

• A. US companies.
• B. both Cuba and other countries as well.
• C. certain circumstances allowed by OFAC.
• D. specific companies.

正解：C

解説：
OFAC regulations permit the use of USD for Cuba-related transactions only when explicitly authorized under specific exceptions or general licenses. These include certain remittances, humanitarian transactions, and authorized travel-related transactions.
General USD use with Cuba is otherwise prohibited unless OFAC has expressly allowed it through a license or regulatory exemption.
Reference:
OFAC Cuba Sanctions Regulations.
Licensed and authorized activities involving USD clearing.

質問 # 29
Which information should be considered while investigating a potential sanctions violation? (Select Two.)

• A. The customer's IP addresses
• B. The customer's transactions of 10,000 USD or EUR or higher
• C. The customer's dual residence in a sanctioned country and a non-sanctioned country
• D. The customer's incoming and outgoing wire transfers involving non-sanctioned countries
• E. The customer's salary

正解：A、C

解説：
Sanctions and Compliance Domains emphasize the importance of identity, residency, location indicators, and digital footprints when assessing potential sanctions violations.
Dual residency in a sanctioned country may trigger sanctions exposure because residency can determine jurisdictional reach. Likewise, IP addresses reveal the customer's actual geographic location during transactions and are critical in identifying hidden connections to sanctioned jurisdictions.
Transaction size thresholds, routine salary information, or transfers within non-sanctioned countries do not directly indicate sanctions violations.
Reference:
Analysis of geographic indicators such as residency and IP information.
Importance of location-based data in determining sanctions exposure.

質問 # 30
A relevant institutions must inform OFSI without delay whenever it credits a frozen account with which of the following?

• A. Funds dealing with breaches of licensing conditions
• B. Funds transferred to an account by a third party
• C. Payments due under prior contracts
• D. Payments made without the prior consent of the legal person or designated person
• E. Payments made under judicial decisions rendered in an EU member state

正解：B、C、E

質問 # 31
A sanctions officer is reviewing a report showing increased activity at an international branch with a large population of expatriates from a newly sanctioned jurisdiction. Which are red flags for identifying clients with increased sanctions or AML risk? (Select Two.)

• A. Privately held companies conducting international wire transfers through institutions distinct from company registration
• B. Regulated entities with a clear web presence with a verifiable business background
• C. Established accounts that send or receive funds from non-sanctioned institutions or institutions active on SWIFT
• D. Publicly traded corporate vehicles
• E. New accounts that are experiencing a sudden rise in value being transferred to the institution from higher risk countries without clear business rationale

正解：A、E

解説：
Red flags for sanctions and AML risk include:
* Privately held companies using institutions outside their jurisdiction of registration, a known structuring and sanctions-evasion indicator.
* Sudden rises in value from high-risk countries without business justification, a classic AML and sanctions red flag indicating possible sanctions circumvention, layering, or illicit value transfer.
Publicly traded entities and regulated firms generally present lower risk due to transparency. Routine SWIFT activity alone is not a red flag.
Reference:
AML/sanctions red-flag indicators related to wire transfers and unexplained value movement.
Risk characteristics of opaque private companies and cross-border financial behavior.

質問 # 32
From a US sanctions perspective, which is true of the high-value art market?

• A. Transactions are exempt from Office of Foreign Assets Control regulations under the Berman Amendment to the International Emergency Economic Powers Act and Trading with the Enemy Act.
• B. The Office of Foreign Assets Control has not published guidance on art-related transactions.
• C. Regulations require full customer due diligence only if the value of the art exceeds USD 50,000.
• D. It is known for low transparency and a high degree of confidentiality among buyers.

正解：D

解説：
Sanctions and Compliance Domains highlight that the high-value art market is characterized by anonymity, confidentiality, private sales, intermediaries, and limited transparency. These conditions create vulnerabilities for sanctions evasion and illicit finance, including the possibility that sanctioned individuals may use art transactions to move value discreetly.
The Berman Amendment does not exempt high-value art transactions from OFAC regulations where value transfer is involved. OFAC has published guidance clearly stating that art transactions remain subject to sanctions rules. There is no value threshold such as USD 50,000 that determines compliance responsibilities.
Reference:
OFAC statements on risks in the high-value art market.
Identified vulnerabilities due to anonymity and lack of transparency.

質問 # 33
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. Reporting required by your regulator
• B. Report under section 19 of the Terrorism Act 2000.
• C. Report under the OFSI Data Protection Act 1998
• 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：C、E

質問 # 34
North Korea's campaign to become a nuclear power first became apparent in March 1993, when it announced that it was withdrawing from a treaty.
Which of the following treaty is this?

• A. Treaty on the Prohibition of Nuclear Weapons
• B. Ballistic Missile Launch Notification Agreement
• C. Intermediate-Range Nuclear Forces Treaty - INF
• D. Strategic Arms Limitation Treaty I (Interim Agreement)
• E. Nuclear Non-Proliferation Treaty (NPT)

正解：E

質問 # 35
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 Security Council
• B. To the Convent
• C. To the league assembly
• D. To the office of President
• E. To the armed forced

正解：C

質問 # 36
Asset freezing legislation generally permits a person to make the following payments into a frozen account without the need for a licence from OFSI, so long as those funds are frozen after being paid in which of the following?

• A. Any payments due to a designated person under contracts
• B. Any agreement or obligations that were concluded or arose before the date the person became sanctioned
• C. Any trademarks and patents created within the account
• D. Any interest on the account
• E. Any earnings on the account

正解：D

質問 # 37
What is the reason why non-members including the Republic of Korea, have taken steps to implement various sanctions regimes?

• A. Because they want to lessen aggression between countries.
• B. Because they are mandated by the Security Council.
• C. In order to promote and advocate peace.
• D. In order to help maintain or restore international peace and security.
• E. Because they felt more than a moral obligation to apply sanctions.

正解：A

質問 # 38
To whom does the person who jointly own an asset with the designated person can sell his share under existing licensing grounds?

• A. A third party who has agreed to hold it for the benefit of the designated person.
• B. The share cannot be sold.
• C. To the OFSI.
• D. The designated person.
• E. The designated person's family member.

正解：A、D

質問 # 39
An EU and US-based retail company sells various goods globally. What product may pose export sanctions violations for the company?

• A. Art reproductions
• B. Cigars
• C. Textbooks
• D. Toys

正解：B

解説：
Cigars, particularly those originating from Cuba or other embargoed jurisdictions, fall under both EU and US export sanctions restrictions. Under US OFAC regulations, Cuban-origin goods-including cigars-are strictly prohibited from import, export, resale, or re-export by US persons. EU sanctions may also restrict trade with embargoed or designated jurisdictions.
Textbooks, toys, and art reproductions generally do not fall under export prohibitions unless tied to dual-use concerns or specific jurisdictions, which is not indicated here. Cigars present the most direct and well-established sanctions risk.
Reference:
US OFAC Cuban Assets Control Regulations on Cuban-origin goods.
EU and US export controls covering embargoed jurisdictions and prohibited commodities.

質問 # 40
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CGSS認定試験は、グローバルな制裁コンプライアンスの知識をテストするために設計された包括的な一連の多肢選択問題で構成されています。試験は、制裁の起源と目的、規制環境、制裁コンプライアンスの実践的な応用など、様々なトピックをカバーしています。試験はコンピュータベースであり、世界中のACAMSテストセンターで受験することができます。合格点を取得する必要があります。

CGSS認定試験は、コンプライアンスオフィサー、リスクマネージャー、AMLプロフェッショナルなど、金融セクターで働くプロフェッショナルの知識をテストするために設計されています。この試験は、制裁コンプライアンスに関連する様々なトピックをカバーしており、制裁の法的枠組み、制裁スクリーニング、リスクマネジメントなどが含まれます。この試験に合格した候補者は、複雑で絶え間なく変化するグローバル制裁の世界における深い理解を証明します。

 

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