ACFCS CFCS Exam : Financial Crime Specialist

Phillips Importers LLC. is a shell company owned by Jon Phillips Mr. Phillips is very active in his local church He has convinced a large number of individuals from his church to invest in the Phillips Fund, which guarantees 10% returns.He lakes the money he collects and puts itina bank account for Phillips Importers LLC. He uses that money to market the Phillips Fund to new investors, print statements, pay dividends to his investors and pay some of his personal expenses.
Which types of fraud isMr.Phillips committing? Choose 2 answers

• A. Pyramid scheme
• B. Affinity fraud
• C. Market manipulation
• D. Ponzi scheme

A law enforcement agent is investigating the owner of a small grocery store thought to be involved in a financial crime scheme II is believed that the store owner is moving illicit proceeds, but it is not clear how it might be happening.
The agent is conducting surveillance on the grocery store and makes the following observations.
* Individuals occasionally enter the store and ask to speak with the owner, who meets with them and takes notes in a notebook he keeps on his person
* Individuals sometimes arrive at the store with small packages or bags and leave without groceries
* The owner periodically visits another store in the neighborhood that acts as an agent for a large international money services business The agent has subpoenaed the bank account and transaction records for the grocery store Transaction patterns do not seem out of the ordinary given the type of business and the area and no suspicious transaction reports have been filed on the account. The store is a sole proprietorship and the owner is not listed as owning or controlling any other business entities.
Based on this information what is the MOST LIKELY conclusion of Ihe law enforcement agent?

• A. The store owner is operating as an unlicensed money remitter
• B. The store owner is involved in a tax fraud scheme
• C. The store owner is running an affinity fraud scheme
• D. The store owner is conducting a terrorist financing operation

You are part of a law enforcement learn reviewing remittances from global money service businesses (MSBs) over a several year period including a time of severe economic recession During this time period there was a regulatory change that drastically lowered the transaction amount al which ihe MSBs were required lo record identity documentation (e.g., driver's license passport) (or any wire transfers crossing international boundaries.
Which result suggests criminal actors have previously been using the system to transfer funds and avoid the reporting requirement?

• A. There was an increase in Suspicious Transaction Reports (SARs/STRs) filed to the Financial Intelligence Unit (FIU)
• B. The aggregate amount of money transferred from one country to another decreased sharply immediately prior to and increased sharply after the new reporting requirements were enacted
• C. The aggregate amount of money transferred from one country to another reduced sharply immediately prior to and after the new reporting requirements were enacted
• D. There was an increase in the number of cross-border transmissions with an increased average value

Which actions have led to penalties or violations of sanctions regimes overseen by the Office of Foreign Assets Control (OFAC)? Choose 2 answers

• A. Stripping wire transfer information to conceal customer information
• B. Conducting transactions with high-risk individuals
• C. Failing to search customers against the sanctions list
• D. Conducting transactions with entities that have been removed from the sanctions list

You were recently hired as a new sanction's analyst for a large international bank in your introductory training you were told the bank generally prefers to avoid doing business with jurisdictions on U.S. sanctions lists, but has supported transactions under "specific' and "general licenses".
In your day-to-day job you find a certain business line seems to be conducting transactions with companies in sanctioned countries and these transactions are flagged by your sanction's filters more than others When you researched the companies you found the transactions were not covered under a general or specific license When you raised this issue with the division's business line manager, he said it "was a mistake".
A week later, you saw a transaction to a company with nearly the same name except shortened and slightly altered. The transaction amount is the same but there was no mention of the sanctioned jurisdiction. The business line manager assured you it was a different company m non-sanctioned country Which is the MOST appropriate next step for you to take?

• A. Update your sanctions filter parameters lo note that the new company with the similar name has been internally white-listed
• B. inform your superiors that due to conflicting information both companies should be the subject of a Suspicious Activity Report (SAR)
• C. inform your superiors that some business lines may be stripping transaction details and dealing with entities or regions on U.S. sanctions
• D. Close the case because the original alerts were false positives The country is not on a U.S. sanctions list