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ACFCS Financial Crime Specialist Sample Questions:

1. During an organizational overview of financial crime controls, Ms. Patel, the compliance analyst, discovers that certain customer due diligence procedures are inconsistently applied across different branches of the organization. What should Ms. Patel recommend to address this issue?

A) Implement additional layers of bureaucracy to ensure uniformity.
B) Disregard the inconsistencies as they may not significantly impact compliance.
C) Conduct a comprehensive review of existing customer due diligence procedures.
D) Assign responsibility for customer due diligence to individual branch managers.

2. Mr. X is a business consultant who specializes in helping European companies expand their operations into Latin America. You are part of a law enforcement unit investigating Mr. X who is under suspicion of assisting his clients to conceal bribe payments made to government officials in Latin American countries.
Mr. X is knowntocontrol a numberofdifferent companies andtheirrelated subsidiaries within severalLamAmerican countries. You are tracing (fundsthat originated from an account held by one of Mr.X's companies in the UK in an effort to establish that he is involved in the corruption and money laundering scheme.
Which would provide the BEST indicatorThatMr.X is helping to launder funds connected to bribery?

A) Funds transferred into the account from a nondescript business with little information available about it
B) Funds whose source can be traced to a corporate account in a country located in the European Union
C) Funds that are being used in the operation of a business in ahigh-riskjurisdiction
D) Funds transferred to business associates of Mr.X located in the European Union

3. You were recently hired as a new sanction's analyst for a large international bank in your introductory training you were told the bank generally prefers to avoid doing business with jurisdictions on U.S. sanctions lists, but has supported transactions under "specific' and "general licenses".
In your day-to-day job you find a certain business line seems to be conducting transactions with companies in sanctioned countries and these transactions are flagged by your sanction's filters more than others When you researched the companies you found the transactions were not covered under a general or specific license When you raised this issue with the division's business line manager, he said it "was a mistake".
A week later, you saw a transaction to a company with nearly the same name except shortened and slightly altered. The transaction amount is the same but there was no mention of the sanctioned jurisdiction. The business line manager assured you it was a different company m non-sanctioned country Which is the MOST appropriate next step for you to take?

A) Update your sanctions filter parameters lo note that the new company with the similar name has been internally white-listed
B) inform your superiors that due to conflicting information both companies should be the subject of a Suspicious Activity Report (SAR)
C) Close the case because the original alerts were false positives The country is not on a U.S. sanctions list
D) inform your superiors that some business lines may be stripping transaction details and dealing with entities or regions on U.S. sanctions

4. During an organizational overview of financial crime controls, Mr. Thompson, the compliance manager, identifies a lack of adequate training for frontline staff on recognizing and reporting suspicious activities.
What is the most effective way for Mr. Thompson to address this issue?

A) Assign responsibility for training to individual branch managers.
B) Hire additional compliance staff to oversee frontline operations.
C) Develop and implement an ongoing training program tailored to the specific needs of frontline staff.
D) Conduct a one-time training session for all frontline staff members.

5. You are a law enforcement agent investigating an associate of Country X's former prime minister who is suspected of helping high-level government officials facilitate a scheme to misappropriate hundreds of millions of dollars in public funds. During your investigations, you uncovered a network of legal entities that you believe have been used to transfer and conceal the proceeds of this corruption scheme.
Through public record searches requests to law enforcement in other jurisdictions and subpoenas to financial institutions you have outlined the following arrangement.
* The associate contacted a relationship manager at a small private bank based in Country X to open a private bank account
* The associate's attorney created an offshore investment company Tropico, Ltd that holds the private banking account
* The associates attorney then appointed three shelf companies formed in Panama as Tropico's directors
* A fourth shelf company formed in the Cayman Islands was named as the primary shareholder You are now trying to determine the true owners behind the funds and assets concealed through this corporate structure Wh.ch is the MOST effect.ve next steptoidentify these individuals?

A) Obtain articles of incorporation for the three shelf companies formed in Panama and listed as Tropics directors
B) Obtain transaction records from the private bank to determine who transferred funds into the account after it was established
C) Obtain articles of incorporation for the shelf company formed in the Cayman Islands that was listed as primary shareholder
D) Obtain a subpoena that requires the relationship manager to provide testimony on the ownership structure of the legal entities

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