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ACFCS CFCS Exam Syllabus Topics:
| Section | Objectives |
|---|---|
| Topic 1: Compliance Programs & Regulatory Frameworks | - Risk assessment and management - US, EU, UK and international regulations - Compliance program design & governance |
| Topic 2: Fraud Schemes & Prevention | - Detection techniques and controls - Financial statement fraud - Internal and external fraud |
| Topic 3: Sanctions Compliance | - OFAC, UN, EU and national sanctions regimes - Screening and due diligence - License and exception procedures |
| Topic 4: Terrorist Financing & Proliferation Financing | - International counter-measures - Financing mechanisms - Detection and prevention |
| Topic 5: Cybercrime & Emerging Threats | - Cyber-enabled financial crime - Cryptocurrency and digital asset risks - Ransomware and account takeovers |
| Topic 6: Bribery & Corruption | - FCPA, UK Bribery Act and global laws - Third-party risk management - Anti-corruption compliance programs |
| Topic 7: Asset Recovery & Investigations | - Asset tracing and recovery - Evidence collection and reporting - Cross-border cooperation - Investigation methodologies |
| Topic 8: Anti-Money Laundering (AML) | - Customer due diligence & KYC - Trade-based money laundering - Money laundering stages and methods - Global AML standards (FATF 40 Recommendations) |
| Topic 9: Ethics & Professional Standards | - Confidentiality and conflict of interest - Professional conduct and integrity |
| Topic 10: Tax Evasion & Related Offenses | - Tax evasion schemes - Offshore structures and disclosure rules |
ACFCS Financial Crime Specialist Sample Questions:
1. 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 is one of the leading sales learn members and is known for upselling existing customers on larger more profitable contracts
B) An employee who has oversight over accounts payable and is responsible for reviewing customer inquiries related to billing
C) An employee who has recently been disciplined lor chronic absenteeism and was placed on a performance improvement plan
D) 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
2. You are a law enforcement agent investigating an associate of Country X's former prime minister who is suspected of helping high-level government officials facilitate a scheme to misappropriate hundreds of millions of dollars in public funds. During your investigations, you uncovered a network of legal entities that you believe have been used to transfer and conceal the proceeds of this corruption scheme.
Through public record searches requests to law enforcement in other jurisdictions and subpoenas to financial institutions you have outlined the following arrangement.
* The associate contacted a relationship manager at a small private bank based in Country X to open a private bank account
* The associate's attorney created an offshore investment company Tropico, Ltd that holds the private banking account
* The associates attorney then appointed three shelf companies formed in Panama as Tropico's directors
* A fourth shelf company formed in the Cayman Islands was named as the primary shareholder You are now trying to determine the true owners behind the funds and assets concealed through this corporate structure Wh.ch is the MOST effect.ve next steptoidentify these individuals?
A) Obtain transaction records from the private bank to determine who transferred funds into the account after it was established
B) Obtain articles of incorporation for the shelf company formed in the Cayman Islands that was listed as primary shareholder
C) Obtain articles of incorporation for the three shelf companies formed in Panama and listed as Tropics directors
D) Obtain a subpoena that requires the relationship manager to provide testimony on the ownership structure of the legal entities
3. Bank A receives a wire transfer Irom Bank B located in another country. When run through Bank A's sanctions screening process, some of the identifying information of the entity initialing the transfer appears as a partial match with an entity on a sanctions list Bank A routinely processes wire transfers from Bank B and almost never runs into matches with sanctions lists.
Which further review should Bank A conduct on the wire transfer?
A) Bank A should contact Bank B lor confirmation that the entity is not on the sanctions list Once it receives written confirmation from Bank B's compliance staff it can complete the transfer without further investigation
B) No review is required Bank B would already have conducted due diligence for sanctions violations and further action would be duplicative and unnecessary
C) Bank A should reject the wire transfer and alert the regulatory or enforcement agency that administers the sanction immediately
D) Bank A should not complete the wire transfer until it gathers more information It should consult the full identifying information in the sanctions entry and attempt to find that information in the transfer
4. You are a law enforcement agent who has received an anonymous tip about suspicious financial activities at Labor Way Inc. a company in your jurisdiction. Labor Way contracts with large corporations internationally to provide temporary employees, and handles payroll processing and lax withholding lor its temporary employees.
You begin an investigation into Labor Way and discover the following information:
* Labor Way's corporate bank account was opened in the name of a law firm that is acting as nominee
* Labor Way's financial records show a sharp increase in revenues and a corresponding increase in temporary employment contracts over the past two years
* Labor Way's transaction history shows periodic withdrawals of large amounts of cash that correspond with its payroll coming due
* Labor Way has recently gained a number of clients in other countries (where it is not located) including several in which it did not previously operate Based on (his information which is your MOST likely conclusion?
A) Labor Way may be involved m a terrorist financing scheme because it has recently entered into contracts in overseas indications to which it has no prior business connections
B) Labor Way may be committing employment tax fraud because its transaction records indicate it is paying all of US temporary employees in cash
C) Labor Way may be committing internal accounting fraud due to the substantial and unexplained increase in revenues
D) Labor Way may be involved in a money laundering scheme due to the presence of a beneficial owner who is hiding behind the nominee account
5. You are an examiner for a financial industry regulator One of your smaller firms has shown a dramatic increase in wire activity that you think may be indicative of them facilitating money laundering. You request their outgoing wire transactionsfor the past six months and they provide you a spreadsheet with nearly 10,000 wires.
Which two criteria would be the MOST effective way to narrow down your sample for investigation? Choose
2 answers
A) The client(s) with multiple third-party wires to different foreign beneficiaries
B) The client(s) with multiple wires just below the reporting threshold
C) The client(s) with the highest number of foreign wires
D) The client(s) with an address outside the country where your firm is domiciled
Solutions:
| Question # 1 Answer: C | Question # 2 Answer: A | Question # 3 Answer: D | Question # 4 Answer: D | Question # 5 Answer: A,B |






