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ACFCS Financial Crime Specialist Sample Questions:

1. How are trade price manipulation schemes used to launder criminal proceeds?

A) By transferring funds offshore through invoicing schemes for non-existent good and services
B) By serving as a balancing mechanismtosettle payments between unregistered hawalas and other informal value transfer systems
C) By transferring value between related criminal enterprises through the fraudulent misrepresentation of the value of exported commodities
D) By obscuring the money trail through offshore bond swaps and fraudulent letters of credit

2. You are an investigator pursuing a suspected fraudster whom you believe is leading a multi-million dollar Ponzi scheme targeting the elderly in your country You believe you are close to gathering the evidence needed to recover some of the victims losses However you are missing some transaction records from a financial institution that would connect the suspect to accounts holding the proceeds of the fraud.
These records can only be released to law enforcement or government regulators. You have a friend in the local police department who is willing to contact the institution and request the records under the pretenses they are needed for an unrelated police investigation.
Given these circumstances would it be ethical for you to ask your friend to obtain the records?

A) This action is unethical because you do not have proof that Ihe suspect has committed the fraud and are only acting on your belief
B) This action is ethical because you are acting in the best interests of your clients, the fraud victims who need this information to recover some of Their losses
C) This action is epical because the records are being turned over to a law enforcement official and you the investigator, are not directly misrepresenting yourself
D) This action is unethical because your avenue for obtaining Ihe records was inappropriate, even if you did not directly misrepresent yourself

3. Company A is a New Jersey-based company, that trades in the metals industry and has been in business for less than two years. To augment their financing, they approach several banks to obtain loans to be repaid in
180 days. The collateral for the loans is the receivables. When the banks ask Company A for documentation to support the receivables, they are presented with documentation that suggests the receivables are coming from customers in various industries none of which have anything to do with metals.
Which is a red flag of illegal incoming revenue to an entity?

A) The loans are very short-term and should not be used to augment their financing
B) The receivables transactions have no business or apparent lawful purpose related to the metals industry
C) it is very unusual for a company to secure a loan based on receivables from other companies
D) A relatively young company approaching several banks for a loan is very unusual

4. You are the chief compliance officer for a non-U S Bank that maintains some accounts in the name of U S residents Your country has signed a FATCA Model 1 inter-governmental agreement.
In developing your FATCA compliance program which should be incorporated into your program?

A) Once evidence indicates a relationship with a U S resident, an exemption to file form must be obtained
B) IRS reporting must include all account balances and securities held in the name of a US resident
C) Customer due diligence for FATCA should leverage your existing AML program
D) Customer due diligence for FATCA should be based on existing IRS requirements (or Qualified Intermediaries

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

Solutions: