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ACFCS Financial Crime Specialist Sample Questions:

1. 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) Submit a request to law enforcement in the subsidiary's country to assist with searching and seizing the transaction records
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) Review the transaction records within the subsidiary s country and only transmit relevant non-personal data back to your country
D) Request that the transaction records be transmitted to your country immediately then delete any personally identifiable information during the review process

2. Mr. Smith, the compliance manager of ABC Bank, is tasked with conducting a risk assessment of the institution's correspondent banking relationships. Which of the following factors should Mr. Smith consider when assessing the risks associated with correspondent banking?

A) The size of transactions conducted by correspondent banks.
B) The number of transactions processed through correspondent accounts.
C) The geographical location of correspondent banks' headquarters.
D) The total assets of ABC Bank.

3. You are the head of fraud risk management for a company that provides telecommunications services to business customers Recently an employee in the customer service department has approached you with concerns about a rise in customer complaints concerning overbilling.
In the past three months an increasing number of clients have complained they have been charged for unspecified "administrative fees beyond their contracted rates. You inquire with your company s operations department about these administrative fees but they are not aware of any changes to services or policies that would have led to new fees for customers After conducting an audit of customer billings you discover that the issue is widespread and you suspect it may be part of an internal fraud scheme on the part of one or more employees.
You initiate an internal investigation of company employees. Which employee should you investigate FIRST?

A) An employee who has recently been disciplined lor chronic absenteeism and was placed on a performance improvement plan
B) An employee who led the periodic audit of customer billing last year but has since been promoted to a different role within your company's internal audit unit
C) An employee who is one of the leading sales learn members and is known for upselling existing customers on larger more profitable contracts
D) An employee who has oversight over accounts payable and is responsible for reviewing customer inquiries related to billing

4. InvestPlus was a securities trading firm that purportedly specialized in high-risk high-reward investment opportunities in developing countries. InvestPlus was losing money on many of its products and began to take funds from new clients to repay earlier investors. The scheme was eventually revealed and InvestPlus collapsed leaving behind numerous defrauded investors InvestPlus is now bankrupt.
A group of investors who lost money has hired your law firm to recover assets InvestPlus had complex holdings and investments in many different countries worldwide Without access to the company s financial records it has been difficult to trace them. The owners of InvestPlus reaped substantial profits but led lavish lifestyles and are thought to have burned through most of their assets.
Which is the BEST way your firm could pursue recovery of damages?

A) File mutual legal assistance treaty requests in the jurisdictions where InvestPlus is thought to have assets
B) Request a summons for the owners of InvestPlus to provide testimony on their financial status
C) Investigate whether third parties have facilitated the scheme and, if so, pursue legal action against them
D) Contact other defrauded investors to see if they have further information on the location of recoverable assets

5. 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) 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
C) 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
D) Company A did not include its distributors within Country Z when conducting its anti-corruption due diligence and training

Solutions: