A year ago when I registered for ACSS I had the same feeling when I started my ACAMS journey – “it is too much, too complex, this time I won’t make it”.
After a year, 297 ACSS pages, several Sanctions webinars, many hours of reading and some real Sanctions cases to deal with – the examination date came and everything proved to be worthy when I was handed with the “PASS” notification paper.
I also wrote an article – “The 5-Step Guide to Passing CAMS” – which you can find here.
In this article, I will tell you how I approached ACSS in order to be sure that I will pass it, as well as my impression on the exam and on the utility of this certification.
International Sanctions represent a very vast domain, with rapid-changing laws and regulations
If the AML-CFT laws change quite rarely (once at a few years), Sanctions Regulations and Orders can be issued or modified within days, depending on changes occurring in the international, political environment.
During my study for the ACSS examination, some very important changes actually happened in the area of International Sanctions, like Belarus EU sectoral sanctions.
Considering the above, I appreciated even more the effort and endeavor of ACSS to create a comprehensive, stand-alone material that would encompass such a vast and rapid-changing domain.
The ACSS manual is an A to Z guide for International Sanctions but in practice is just the foundation
The manual provides the pillars to understand International Sanctions. It starts with basic information in order to understand International Sanctions and the way they are enforced and continue with practical information on Sanction Evasion typologies, Sanctions Compliance Programs, the way Sanctions should be approached in different industries (besides banking – which I totally appreciated), case studies and a well-documented bibliography.
It provides you with the basis of being an International Sanctions Specialist.
However, it is not enough to actively work in this domain, exactly because it is a fast-changing one and the specific regulations are different for different countries and can change from one day to another. The ACSS manual provides you with all the necessary information in order to be able to evaluate a UN Council Resolution, an EU Regulation or a US Executive Order, but it cannot provide all the exact restrictions applicable at a certain date, as all the above mentioned laws can change even while publishing such a material.
In order be able to work practically in the Sanctions domain, you must remain informed and up to date, directly from the source (UN, EU, US) – newsletters, press releases and FAQ.
The exam is formed of 90% practical questions
Although the exam was in a standard multiple-choice format, it surprised me to see that the majority of the questions were presented in a case-study format.
Question by question I had to “assume” many roles – from a Business Manager in several industries, to Head of Compliance in a company from France, USA, Germany, Netherlands, etc. or to an employee from different departments – and to take decisions that would significantly influence the liability of the company I worked at.
Thus, all the theory from the manual was transposed in many case studies and I had to re-analyze the information received from a practical perspective.
A simple “learn by heart” approach is not enough. If you don’t understand the concepts described in the manual, you are doomed.
The exam is formed of 2 parts: 106 practical questions and one separate study-case with 3 questions. You have 3 hours allocated for both sections. The 2 sections are separated, meaning that you cannot pass to the case-study until you finish and close the section with 106 questions. Once you close the section with 106 questions, you cannot re-open it to review or change answers. You can only review answers until you close the session. So you have to be very attentive to finish reviewing the answers before closing the section, but also to be careful not to close the entire exam and thus miss the separate study-case (as it happened to a dear friend of mine – she passed the exam as she had a very good score at the 106 questions).
What did I gain from it?
Believe it or not, this was the first question I was asked by my non-Compliance friends and relatives when I told them from Cloud no. 9 that I had passed. “Why did you do it?”; “What did you gain from it?”.
At first I was blocked by the frankness of the question that I didn’t know what to answer. For me it was so obvious that I couldn’t even detail an answer. But, in the end, is a fair question.
Besides the signature mark 😊, what do you gain from such an effort? Is it worth it?
Yes, it is definitely worth it!
I now understand International Sanctions differently, I can evaluate practical situations more correctly, I understand how bank clients from different industries can be impacted by International Sanctions and how we should evaluate and rank them internally. I know where to look for further information when I need it.
Is it enough? No, it definitely isn’t!
Learning for the ACSS was difficult. Passing the exam was difficult. But considering the implications, the historical fines for Sanctions non-compliance and the fast-changing pace, remaining up-to-date seems even more difficult.
ACSS is just a foundation and the further daily “bricks” of information are mandatory. And for that, hats off to all our Sanctions Officers, as you are doing a very difficult job!
Have a wonderful New Year and free of AML / CFT / Sanctions events!
By Andreea Tampu, ACAMS, ACSS
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