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ACFCS Financial Crime Specialist Sample Questions:

1. Your client is the family of a man who is deceased. The family remembers stones that their father (the deceased) had a Cayman Islands company where he held his investments. They have located a file containing an old Cayman Islands bank statement in the name of Company A Limited and in care of a post office address. They want to know what information they can find out about the company and the account.
How can they determine if the company still exists?

A) Visit the post office and ask for access to the PO Box
B) Conduct an internet search for the company's name as company information is public
C) Check with the Corporate Registry as this information is public
D) Contact the bank and ask the status of the company

2. An offshore energy company is attempling to make payment to Iran for a bulk oil purchase The payment is routed through the offshore bank's New Y affiliate bank where the funds are converted to USD to be forwarded to Iranian Oil LTD, Tehran, Iran.
Which forward payment scheme is MOST likely to be used by banks to defeat the U.S. Office of Foreign Assets Control (OFAC) Sanctions?

A) Redirection - sending funds to an Iranian oil shell company in a non-sanctioned country and then wiring them to Iranian Oil LTD Tehran
B) Stripping - removing the name and destination from the SWIFT messaging to mask the client's identity and location
C) Alternate Delivery Service (ADS) - referring to an automated clearing house service to forward payment to a service provider in a non-sanctioned country for final payment to Iranian Oil LTD
D) Intermediated Delivery Service (IDS) - forwarding funds to a non-sanctioned affiliate bank not in the US lo be forwarded to a correspondent bank account inside Iran

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

4. Ms. Garcia, the Chief Compliance Officer of a multinational bank, is reviewing the institution's sanctions compliance program. She wants to ensure that appropriate measures are in place to monitor and control transactions involving high-risk jurisdictions. Which of the following strategies would be most effective for Ms. Garcia to achieve this objective?

A) Implementing transaction monitoring systems that flag transactions involving high-risk jurisdictions for manual review.
B) Increasing transaction processing speed to minimize delays for clients from low-risk jurisdictions.
C) Conducting enhanced due diligence on all clients regardless of their jurisdiction.
D) Restricting all transactions with counterparties from high-risk jurisdictions to minimize exposure.

5. During a routine audit, a financial institution discovers that its sanctions screening software has not been updated to include the latest changes to the OFAC SDN list. What is the most appropriate action for the institution to take?

A) Notify OFAC of the software issue and seek guidance on interim measures.
B) Immediately suspend all transactions until the screening software is updated.
C) Proceed with transactions and update the screening software during the next scheduled maintenance.
D) Conduct manual screening of transactions against the latest version of the SDN list until the software is updated.

Solutions: