ACFCS CFCS : Financial Crime Specialist

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 has oversight over accounts payable and is responsible for reviewing customer inquiries related to billing
• D. An employee who is one of the leading sales learn members and is known for upselling existing customers on larger more profitable contracts

The automated transaction monitoring system at a bank that is headquartered in Japan has generated a case for a customer located in the U S whose activity was more than 50% above its expected activity Hall of the transactional activities are with countries in Asia.
An investigation into this case by the compliance department should include which three steps? Choose 3 answers

• A. A request lor information from the bank's relationship manager
• B. A calltothe customer to determine the nature of the business with Asian countries
• C. A review of the customer's Know Your Customer (KYC) file
• D. An Internet search of the parties in the transactions

In the context of compliance programs and controls, what is the primary objective of conducting a risk assessment within a financial institution?

• A. To generate revenue through risk management activities.
• B. To allocate resources for regulatory compliance efforts.
• C. To assess the financial institution's exposure to various types of risks.
• D. To identify potential areas of non-compliance with internal policies.

During a review of its compliance program, XYZ Bank discovers that it has processed transactions involving individuals and entities on the Office of Foreign Assets Control (OFAC) Specially Designated Nationals (SDN) list. What is the most appropriate action for XYZ Bank to take?

• A. Immediately report the findings to OFAC and await further instructions.
• B. Conduct a retrospective review of transactions to assess the extent of potential violations.
• C. Suspend all transactions until the individuals and entities are removed from the SDN list.
• D. Implement enhanced due diligence procedures for transactions involving high-risk countries.

A small but very successful construction company is expanding rapidly Having quickly gone from just a few employees to a larger staff the company's managers have become concerned about the possibility for internalTheftand fraud, and are implementing compliance measures.
The company promotes one of its current HR employees to be the new head of compliance It institutes a new whistleblower policy in which all employees are required to report suspicious behavior or transactions directly to their immediate supervisor who will escalate as necessary.
The company also institutes a gifts and entertainment policy that restricts promotional expenses for the company's sales staff and any managersthatinteract with clients and vendors Finally the company starts a selective review process for all invoices above a certain threshold subjecting them to senior management review.
Based on this scenario which is the MOST significant weakness in the company's efforts to detect and prevent internal financial crime?

• A. The gifts and entertainment policy - The policy is not comprehensive enough and should include all company employees not only sales staff and management
• B. Thewhistleblowerpolicy - Reporting should never go through the company's business lines it should lake place anonymously
• C. The promotion of a current employee as head of compliance - Compliance officers should always be hired externally to minimize the chances of internal fraud
• D. The Policy ofinvoice review - All invoices should be subject to senior management approval not only those above a certain level