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ACFCS Financial Crime Specialist Sample Questions:

1. During a risk assessment of its trade finance operations, XYZ Bank identifies a high volume of transactions involving shell companies with obscure ownership structures. What is the most appropriate action for XYZ Bank to take in response to this finding?

A) Immediately terminate all trade finance operations involving shell companies.
B) Conduct enhanced due diligence on transactions involving shell companies.
C) Seek approval from senior management to continue trade finance operations.
D) Ignore the issue as long as the transactions are compliant with regulatory requirements.

2. You are a compliance officer for a bank that provides services to a third-party payment processor. The processor facilitates credit card payments for online and physical retail stores located within your own country.
You conducted enhanced due diligence on the client when the account was originally opened two years ago.
Since then, periodic reviews have noted no changes in the client s operations ownership structure or other information.
Recently regulators in your country have issued penalties against other banks that had insufficient AML controls and monitoring on accounts held by payment processors Concerned, your legal department has asked you to review the client's risk status.
Which is the primary reason for your conclusion that the customer relationship is higher risk?

A) The account relationship manager is reluctant to provide additional supporting documentation
B) The payment processor conducts credit card transactions
C) The retail stores served by the processor are not covered by AML regulations
D) The bank does not have visibility into the activities of the processor's customers

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

4. A bank holds accounts for several different gatekeeper clients such as attorneys accountants and company formation agents II is conducting a periodic review of these accounts and updating their risk ratings.
Which two accounts should the bank consider to be at highest risk? Choose 2 answers

A) A company formation agent that establishes private investment companies primarily for clients in Africa and Asia
B) An attorney whose practice specializes in cases involving maritime law in the international shipping industry
C) An accountant at a private accounting firm whose clients are large multinational agricultural corporations
D) A notary in Latin America who specializes in assisting clients from other countries with high-end real estate transactions

5. A financial institution operates in multiple jurisdictions and encounters challenges in ensuring consistent compliance with OFAC sanctions across its global operations. What would be the most effective approach for the institution to enhance cross-border sanctions compliance?

A) Outsourcing sanctions compliance responsibilities to third-party service providers specialized in global compliance solutions.
B) Implementing jurisdiction-specific sanctions compliance policies tailored to the regulatory requirements of each country.
C) Conducting regular risk assessments to identify jurisdiction-specific sanctions risks and adjust compliance measures accordingly.
D) Establishing a centralized sanctions compliance team responsible for overseeing compliance efforts in all jurisdictions.

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