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ACFCS Financial Crime Specialist Sample Questions:

1. During an organizational overview of financial crime controls, Ms. Lee, the compliance analyst, discovers that certain high-risk customers have not undergone enhanced due diligence (EDD) as required by regulatory guidelines. What is the most appropriate action for Ms. Lee to take?

A) Document the findings and recommend the implementation of robust procedures for EDD.
B) Notify senior management and request immediate termination of the high-risk customer relationships.
C) Conduct a retrospective review of the high-risk customers' transactions to assess potential risks.
D) Ignore the issue as long as there have been no suspicious transactions involving the high-risk customers.

2. Company A a multinational manufacturing corporation, recently acquired a local company in Country Z that has a high level of state involvement in ihe economy and history of corruption Before purchasing the company. Company A hired a major international law firm to conduct a due diligence review and uncover any potential violations of global anti-corruption laws When the review came back free of issues Company A completed its acquisition.
Two years later executives from Company A were conducting their first anti-corruption compliance training with employees from the Country Z office During the training session Company A executives were alerted by Country Z-based employees that the distributors the company uses may be bribing government officials Company A had not conducted a review of distributors in Country Z, and when it began to look into the allegations it found widespread potential Foreign Corrupt Practices Act (FCPA) violations.
Which are two weaknesses in Company A's anti-corruption compliance program? Choose 2 answers

A) Company A should have conducted anti-corruption compliance training as soon as possible after acquiring the company in Country Z
B) The due diligence review should have been exclusively conducted by local counsel from within Country Z becausetheywould be better versed in the country's culture and laws
C) Company A did not include its distributors within Country Z when conducting its anti-corruption due diligence and training
D) Company A failed to reach out directly togovernmentagencies within Country Z to request information on any history of corrupt payments at the company it was acquiring

3. Person A has a savings account with Bank X. Five years later Person A was appointed chief minister of infrastructure lor Country Y a high-risk jurisdiction.

A) Because Country Y is a high-risk jurisdiction immediately file a SAR/STR
B) Establish permanent and improved monitoring of Person A's savings account
C) Initiate an audit of the original source of funds in Person A's account
D) Restrict activity in Person A's account since he is now a political figure in a high-risk country

4. A publicly traded corporation set up a shell company in an offshore jurisdiction for the purpose of making payments to government officials to win business The corporation funnels the proceeds through a London bank with a robust compliance program Once the scheme becomes public which is LEAST likely to occur?

A) The bank will be held liable for laundering Ihe proceeds of corruption
B) The corporation will suffer damage to its reputation and diminished share price
C) The corporation will be subject to sanctions by the offshore jurisdiction
D) The bank will be subject to investigation by U.K. authorities

5. Your firm has been retained aspairof a complex internal fraud case for a large corporation.Aspartof the investigation you are seeking to collect transaction records held in a subsidiary office located in another country.
The country has strict laws governing cross-border sharing of its citizens' personally identifiable information It does allow data sharing under sate harbor agreements with companies that meet certain data protection standards but your company does not currently have the criteria for such an agreement.
You are not sure il the records you are seeking would contain personal information subjecttothe country's data privacy laws but the matter is time-sensitive and reviewing these records is considered essential to move forward.
Which is Ihe BEST next step lo lake in your investigation?

A) Request that the transaction records be transmitted to your country immediately then delete any personally identifiable information during the review process
B) Initiate a review of your company's data protection standards lo identify any needed improvements and start the process to applyfora safe harbor agreement
C) Submit a request to law enforcement in the subsidiary's country to assist with searching and seizing the transaction records
D) Review the transaction records within the subsidiary s country and only transmit relevant non-personal data back to your country

Solutions: