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Study guide · Updated October 2026

CGSS Exam Study Guide (2026)

Everything the CGSS Certification Exam (Certified Global Sanctions Specialist) tests, topic by topic: what each section covers, the facts that come up most, and how to study it. Pair it with the free 15-question practice test.

The exam at a glance

Questions100 multiple-choice and multiple-select questions
Time175 minutes
Passing scoreScaled score of 75
FormatClosed book, computer-based
Certifying bodyACAMS (Association of Certified Anti-Money Laundering Specialists)
Test providerPearson VUE (test center or online proctored)

Mind map: the whole exam on one screen

CGSS
Sanctions Basics and Types
Comprehensive vs targeted sanctionsSectoral sanctionsSecondary sanctionsBlocking (asset freeze)
Major Sanctions Regimes: UN, US, EU and UK
OFAC's 50 Percent RuleEU ownership and control testUK financial sanctions enforcerUK sanctions legal basis
Licenses, Exemptions and Authorizations
General licenseSpecific licenseWind-down licenseOFAC recordkeeping period
Building a Sanctions Compliance Program
7 key facts
Screening, Alerts and Reporting
7 key facts
Trade, Maritime and Export Control Risks
7 key facts
Detecting and Investigating Sanctions Evasion
7 key facts

1. Sanctions Basics and Types

This topic covers what sanctions are for, the main types (comprehensive, targeted, sectoral, secondary) and the measures they use, such as asset freezes, trade restrictions and travel bans.

Key facts

  • Sanctions are foreign policy and security tools used to change behavior, constrain targets or signal disapproval.
  • Comprehensive sanctions restrict almost all dealings with a country or region; targeted sanctions hit named people, entities, vessels or aircraft.
  • Sectoral sanctions restrict specific activities with companies in a sector (for example new debt or equity), not all dealings.
  • Secondary sanctions threaten non-US persons with penalties for significant dealings with sanctioned targets, even without a US nexus.
  • An asset freeze (blocking) means funds and economic resources can't be used, moved or made available to the target.
  • Trade sanctions and export controls restrict goods, technology and services, including dual-use items.
  • Counter-terrorism and non-proliferation sanctions implement UN Security Council resolutions and FATF Recommendations 6 and 7.

Flashcards

Comprehensive vs targeted sanctionsComprehensive: almost all dealings with a country or region. Targeted: named persons, entities, vessels or aircraft.
Sectoral sanctionsRestrictions on specific types of dealings with companies in a sector, rather than a full freeze.
Secondary sanctionsPenalties on non-US persons for significant dealings with sanctioned targets, even without a US nexus.
Blocking (asset freeze)Property can't be transferred, paid, withdrawn or otherwise dealt in, and must be reported.

Exam tip: If the scenario restricts only new debt or equity for a named company, that's sectoral, not a full block.

2. Major Sanctions Regimes: UN, US, EU and UK

Know who issues sanctions in each major jurisdiction, how they're published, and the key differences, especially ownership and control rules and who must comply.

Key facts

  • UN Security Council sanctions under Chapter VII bind all member states, which implement them in national law.
  • OFAC (US Treasury) administers US sanctions. The SDN List is the main list; US persons must comply wherever they are.
  • OFAC's 50 Percent Rule blocks entities owned 50% or more, in aggregate, by blocked persons.
  • EU sanctions are adopted by the Council (CFSP decision plus regulation) and enforced by member states' competent authorities.
  • The EU and UK treat entities owned more than 50% or controlled by a designated person as subject to the freeze.
  • The UK's OFSI (HM Treasury) enforces financial sanctions; UK sanctions are made under the Sanctions and Anti-Money Laundering Act 2018.
  • The US BIS (Commerce Department) administers export controls through the Export Administration Regulations and the Entity List.

Flashcards

OFAC's 50 Percent RuleEntities owned 50% or more, directly or indirectly, individually or in aggregate, by blocked persons are blocked.
EU ownership and control testMore than 50% ownership, or control assessed case by case.
UK financial sanctions enforcerOFSI (Office of Financial Sanctions Implementation), part of HM Treasury.
UK sanctions legal basisThe Sanctions and Anti-Money Laundering Act 2018 (SAMLA).

Exam tip: Note the subtle threshold difference: OFAC is 50% or more; the EU and UK are more than 50%, plus control.

3. Licenses, Exemptions and Authorizations

Sanctions programs allow some activity under general or specific licenses. Questions test when a license is needed, who can rely on it and what records to keep.

Key facts

  • A general license authorizes a type of transaction for everyone who meets its conditions, without applying.
  • A specific license is issued on application to a named person for a particular transaction.
  • Humanitarian exemptions and licenses cover items such as food, medicine and aid, but conditions must be met.
  • Firms relying on a license should document which license applies and keep evidence that conditions were met.
  • Wind-down general licenses give a limited time to end dealings after a new designation.
  • Licenses don't override other regimes: a US license doesn't authorize activity under EU or UK law.
  • OFAC's recordkeeping period was extended from 5 to 10 years (effective March 2025), in line with the longer statute of limitations.

Flashcards

General licensePre-authorized category of transactions anyone may rely on if conditions are met.
Specific licenseAuthorization issued on application to a specific person for a specific transaction.
Wind-down licenseA time-limited authorization to end existing dealings with a newly sanctioned party.
OFAC recordkeeping period10 years (extended from 5 years, effective March 2025).

Exam tip: If a question mixes jurisdictions, check each regime separately. A license in one doesn't fix a breach in another.

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4. Building a Sanctions Compliance Program

Half the CGSS exam is about the program. Learn OFAC's five components, how the risk assessment drives controls, and the roles of governance, training and testing.

Key facts

  • OFAC's Framework for Compliance Commitments (2019) names five components: management commitment, risk assessment, internal controls, testing and auditing, and training.
  • The sanctions risk assessment looks at customers, products, geographies, counterparties, supply chains and delivery channels.
5 more key facts and 5 flashcards for this topic are in the member study notes.

Flashcards

OFAC's five components of sanctions complianceManagement commitment, risk assessment, internal controls, testing and auditing, training.

Exam tip: OFAC's framework is the backbone of many program questions. If one of the five components is an answer option, it's often the right one.

5. Screening, Alerts and Reporting

This topic covers customer and payment screening, list management, fuzzy matching, alert review, blocking versus rejecting, and reporting deadlines.

Key facts

  • Customer screening checks names at onboarding and whenever lists or customer data change; payment screening checks transactions before release.
  • Fuzzy matching catches spelling variations, transliterations, aliases and typos; thresholds balance misses against false positives.
5 more key facts and 5 flashcards for this topic are in the member study notes.

Flashcards

Deadline to report blocked property to OFACWithin 10 business days.

Exam tip: Reject when the transaction is prohibited but there's no blocked person's property interest; block when a blocked person has an interest.

6. Trade, Maritime and Export Control Risks

Many sanctions breaches involve trade. Learn trade finance controls, dual-use goods, maritime red flags and the due diligence expected on goods, vessels and end users.

Key facts

  • Dual-use goods have both civilian and military applications and are controlled under export control regimes.
  • Trade finance staff should screen all parties (buyer, seller, banks, shipping companies, agents), vessels and ports in a transaction.
5 more key facts and 5 flashcards for this topic are in the member study notes.

Flashcards

Dual-use goodsItems with both civilian and military uses, controlled by export regimes.

Exam tip: In a trade scenario, look for the party you haven't screened yet (agent, vessel, port, freight forwarder). That's usually the gap.

7. Detecting and Investigating Sanctions Evasion

This topic (about 30% of the exam) covers how sanctioned parties hide, the red flags that reveal them, and how to investigate, freeze and report.

Key facts

  • Stripping removes or changes payment message information to avoid screening.
  • Front companies, shell companies and nominees hide the involvement of sanctioned persons.
5 more key facts and 5 flashcards for this topic are in the member study notes.

Flashcards

Wire strippingRemoving or altering payment message data so screening won't catch a sanctioned party.

Exam tip: When ownership moves just below 50% to a relative or associate, assume control hasn't changed until proven otherwise.

How to pass

  • Half the exam is about running a sanctions program: screening, alert handling, escalation, reporting and testing. Spend half your time there.
  • Know the differences between the UN, US (OFAC), EU and UK (OFSI) regimes, especially ownership and control rules.
  • Sanctions compliance is strict liability in the US: a violation can be penalized even without intent. Expect questions on this.
  • 100 questions in 175 minutes is about 1 minute 45 seconds each. Don't get stuck on one scenario.

Frequently asked questions

How long should I study for the CGSS exam?

Most working candidates need 4 to 8 weeks at 45 to 60 minutes a day. Book your exam once your Readiness Score has stayed at 80 or higher for about a week.

Can I take the CGSS exam online?

Yes. ACAMS exams are delivered by Pearson VUE at test centers or online with a remote proctor. Format: closed book, computer-based. Check the current Candidate Handbook from ACAMS for the rules.

What score do I need to pass the CGSS exam?

Scaled score of 75. The exam has 100 multiple-choice and multiple-select questions and a time limit of 175 minutes.

What are the most tested topics?

The outline covers sanctions basics and types, major sanctions regimes: un, us, eu and uk, licenses, exemptions and authorizations, building a sanctions compliance program, screening, alerts and reporting, trade, maritime and export control risks, detecting and investigating sanctions evasion. Use the free practice test to see which ones you need most.

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Summarized from ACAMS' official candidate information and the standards and regulations cited, checked October 2026. Confirm current requirements with ACAMS (Association of Certified Anti-Money Laundering Specialists).

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