ACFCS Practice Test – Anti-Financial Crime
Certification Study Guide and Practice Questions.
SECTION 1: FINANCIAL CRIME CONVERGENCE (Questions 1-25)
Q1: A compliance officer at a U.S. bank reviews a new business account opened by a foreign
precious metals dealer. The customer conducts frequent wire transfers to multiple
jurisdictions, uses shell companies in secrecy jurisdictions, and structures cash deposits just
below reporting thresholds. Which stage of money laundering is MOST likely represented by
the structuring behavior?
A. Integration, because the funds are being moved into the legitimate economy
B. Layering, because the transactions are designed to obscure the audit trail
C. Placement, because cash is being introduced into the financial system
D. Extraction, because funds are being removed from the banking system
Correct Answer: C
Rationale: Correct because placement is the initial stage of money laundering where illicit
cash is introduced into the financial system; structuring deposits to avoid CTR filing is a classic
placement technique per FinCEN guidance and FATF standards.
Q2: A financial institution's transaction monitoring system generates an alert on a corporate
customer. The customer receives multiple wire transfers from unrelated third parties in high-
risk jurisdictions, immediately converts the funds to cryptocurrency, and transfers them to
wallets in sanctioned countries. Per FATF Recommendation 15, what is the PRIMARY
regulatory concern?
A. Inadequate customer identification procedures
B. Misuse of virtual assets for sanctions evasion and terrorist financing
C. Failure to file a currency transaction report
D. Violation of the Bank Secrecy Act's recordkeeping requirements
Correct Answer: B
Rationale: Correct because FATF Recommendation 15 specifically addresses the risks of virtual
assets and virtual asset service providers being misused for money laundering, sanctions
,evasion, and terrorist financing; the immediate conversion to cryptocurrency and transfer to
sanctioned jurisdictions represents this exact typology.
Q3: Under the USA PATRIOT Act Section 312, which category of customer requires enhanced
due diligence including reasonable steps to ascertain the source of funds and purpose of the
account?
A. All retail customers opening checking accounts
B. Correspondent accounts for foreign financial institutions
C. Private banking accounts for non-U.S. persons
D. All commercial lending relationships
Correct Answer: C
Rationale: Correct because Section 312 of the USA PATRIOT Act specifically mandates
enhanced due diligence for private banking accounts maintained for non-U.S. persons,
including ascertaining the source of funds and monitoring transactions to detect suspicious
activity.
Q4: A U.S. multinational corporation discovers that a foreign subsidiary made a $50,000
payment to a customs official to expedite the clearance of goods. The payment was recorded
as a "consulting fee" in the subsidiary's books. Under the Foreign Corrupt Practices Act
(FCPA), which element is MOST critical for establishing a bribery violation?
A. The payment exceeded $10,000 in value
B. The payment was made to a foreign government official to obtain or retain business
C. The payment was recorded inaccurately in the books and records
D. The payment was made by a subsidiary rather than the parent company
Correct Answer: B
Rationale: Correct because the FCPA's anti-bribery provisions prohibit corrupt payments to
foreign government officials for the purpose of obtaining or retaining business; the payment
to a customs official to expedite clearance directly satisfies this element regardless of
recording method.
,Q5: A bank's sanctions screening system flags a wire transfer beneficiary that matches an
entry on the OFAC SDN List with a 72% algorithmic match score. Per OFAC guidance, what is
the MOST appropriate initial action?
A. Immediately reject the transaction and freeze the funds
B. Conduct additional due diligence to confirm or refute the match
C. File a Suspicious Activity Report and continue processing the transaction
D. Block the transaction only if the match score exceeds 85%
Correct Answer: B
Rationale: Correct because OFAC guidance requires institutions to conduct additional due
diligence on potential matches to determine whether a true hit exists; automated match
scores alone are insufficient for blocking decisions without human verification of identifying
information.
Q6: A compliance officer reviews a customer's account activity. The customer, a U.S. resident,
maintains accounts at multiple foreign financial institutions in jurisdictions with strict bank
secrecy laws. The customer receives regular deposits from a shell company in a tax haven and
has not reported these accounts to the IRS. Which regulatory framework is PRIMARILY
implicated?
A. The Bank Secrecy Act's currency transaction reporting requirements
B. The Foreign Account Tax Compliance Act (FATCA)
C. The USA PATRIOT Act's customer identification program
D. The Office of Foreign Assets Control's sanctions programs
Correct Answer: B
Rationale: Correct because FATCA requires U.S. taxpayers to report foreign financial accounts
and assets, and imposes withholding and reporting obligations on foreign financial
institutions; unreported accounts in secrecy jurisdictions with shell company deposits
represent classic FATCA evasion indicators.
Q7: A financial intelligence unit receives a suspicious transaction report involving a charity
that received a sudden influx of large donations immediately following a natural disaster
, overseas. The donations came from multiple unrelated individuals in a single geographic
region, and the charity has no history of disaster relief operations. Per FATF guidance, what
typology is MOST likely indicated?
A. Trade-based money laundering through charitable organizations
B. Terrorist financing using charitable organizations as conduits
C. Ponzi scheme operations disguised as charitable giving
D. Tax evasion through fraudulent charitable deductions
Correct Answer: B
Rationale: Correct because FATF guidance identifies sudden patterns of charity donations
overseas, particularly from geographic concentrations with no operational history in disaster
relief, as a red flag for terrorist financing; charities are commonly exploited as conduits to
move funds to terrorist organizations under the guise of legitimate humanitarian aid.
Q8: A bank's correspondent relationship with a foreign bank is subject to termination due to
concerns about the foreign bank's AML controls. Under Section 311 of the USA PATRIOT Act,
what authority does the U.S. Treasury Department possess?
A. Authority to impose civil money penalties on the U.S. bank only
B. Authority to designate the foreign bank as a primary money laundering concern and
impose special measures
C. Authority to arrest executives of the foreign bank
D. Authority to automatically revoke the foreign bank's banking charter
Correct Answer: B
Rationale: Correct because Section 311 of the USA PATRIOT Act grants the Secretary of the
Treasury the authority to designate a foreign jurisdiction, financial institution, or class of
transactions as a primary money laundering concern and impose one or more of five special
measures to combat the risk.
Q9: A compliance officer reviews a customer's wire transfer activity. The customer, a small
import-export business, sends wires to a trading company in a high-risk jurisdiction. The
stated purpose is "payment for electronics," but the amounts are inconsistent with typical
Certification Study Guide and Practice Questions.
SECTION 1: FINANCIAL CRIME CONVERGENCE (Questions 1-25)
Q1: A compliance officer at a U.S. bank reviews a new business account opened by a foreign
precious metals dealer. The customer conducts frequent wire transfers to multiple
jurisdictions, uses shell companies in secrecy jurisdictions, and structures cash deposits just
below reporting thresholds. Which stage of money laundering is MOST likely represented by
the structuring behavior?
A. Integration, because the funds are being moved into the legitimate economy
B. Layering, because the transactions are designed to obscure the audit trail
C. Placement, because cash is being introduced into the financial system
D. Extraction, because funds are being removed from the banking system
Correct Answer: C
Rationale: Correct because placement is the initial stage of money laundering where illicit
cash is introduced into the financial system; structuring deposits to avoid CTR filing is a classic
placement technique per FinCEN guidance and FATF standards.
Q2: A financial institution's transaction monitoring system generates an alert on a corporate
customer. The customer receives multiple wire transfers from unrelated third parties in high-
risk jurisdictions, immediately converts the funds to cryptocurrency, and transfers them to
wallets in sanctioned countries. Per FATF Recommendation 15, what is the PRIMARY
regulatory concern?
A. Inadequate customer identification procedures
B. Misuse of virtual assets for sanctions evasion and terrorist financing
C. Failure to file a currency transaction report
D. Violation of the Bank Secrecy Act's recordkeeping requirements
Correct Answer: B
Rationale: Correct because FATF Recommendation 15 specifically addresses the risks of virtual
assets and virtual asset service providers being misused for money laundering, sanctions
,evasion, and terrorist financing; the immediate conversion to cryptocurrency and transfer to
sanctioned jurisdictions represents this exact typology.
Q3: Under the USA PATRIOT Act Section 312, which category of customer requires enhanced
due diligence including reasonable steps to ascertain the source of funds and purpose of the
account?
A. All retail customers opening checking accounts
B. Correspondent accounts for foreign financial institutions
C. Private banking accounts for non-U.S. persons
D. All commercial lending relationships
Correct Answer: C
Rationale: Correct because Section 312 of the USA PATRIOT Act specifically mandates
enhanced due diligence for private banking accounts maintained for non-U.S. persons,
including ascertaining the source of funds and monitoring transactions to detect suspicious
activity.
Q4: A U.S. multinational corporation discovers that a foreign subsidiary made a $50,000
payment to a customs official to expedite the clearance of goods. The payment was recorded
as a "consulting fee" in the subsidiary's books. Under the Foreign Corrupt Practices Act
(FCPA), which element is MOST critical for establishing a bribery violation?
A. The payment exceeded $10,000 in value
B. The payment was made to a foreign government official to obtain or retain business
C. The payment was recorded inaccurately in the books and records
D. The payment was made by a subsidiary rather than the parent company
Correct Answer: B
Rationale: Correct because the FCPA's anti-bribery provisions prohibit corrupt payments to
foreign government officials for the purpose of obtaining or retaining business; the payment
to a customs official to expedite clearance directly satisfies this element regardless of
recording method.
,Q5: A bank's sanctions screening system flags a wire transfer beneficiary that matches an
entry on the OFAC SDN List with a 72% algorithmic match score. Per OFAC guidance, what is
the MOST appropriate initial action?
A. Immediately reject the transaction and freeze the funds
B. Conduct additional due diligence to confirm or refute the match
C. File a Suspicious Activity Report and continue processing the transaction
D. Block the transaction only if the match score exceeds 85%
Correct Answer: B
Rationale: Correct because OFAC guidance requires institutions to conduct additional due
diligence on potential matches to determine whether a true hit exists; automated match
scores alone are insufficient for blocking decisions without human verification of identifying
information.
Q6: A compliance officer reviews a customer's account activity. The customer, a U.S. resident,
maintains accounts at multiple foreign financial institutions in jurisdictions with strict bank
secrecy laws. The customer receives regular deposits from a shell company in a tax haven and
has not reported these accounts to the IRS. Which regulatory framework is PRIMARILY
implicated?
A. The Bank Secrecy Act's currency transaction reporting requirements
B. The Foreign Account Tax Compliance Act (FATCA)
C. The USA PATRIOT Act's customer identification program
D. The Office of Foreign Assets Control's sanctions programs
Correct Answer: B
Rationale: Correct because FATCA requires U.S. taxpayers to report foreign financial accounts
and assets, and imposes withholding and reporting obligations on foreign financial
institutions; unreported accounts in secrecy jurisdictions with shell company deposits
represent classic FATCA evasion indicators.
Q7: A financial intelligence unit receives a suspicious transaction report involving a charity
that received a sudden influx of large donations immediately following a natural disaster
, overseas. The donations came from multiple unrelated individuals in a single geographic
region, and the charity has no history of disaster relief operations. Per FATF guidance, what
typology is MOST likely indicated?
A. Trade-based money laundering through charitable organizations
B. Terrorist financing using charitable organizations as conduits
C. Ponzi scheme operations disguised as charitable giving
D. Tax evasion through fraudulent charitable deductions
Correct Answer: B
Rationale: Correct because FATF guidance identifies sudden patterns of charity donations
overseas, particularly from geographic concentrations with no operational history in disaster
relief, as a red flag for terrorist financing; charities are commonly exploited as conduits to
move funds to terrorist organizations under the guise of legitimate humanitarian aid.
Q8: A bank's correspondent relationship with a foreign bank is subject to termination due to
concerns about the foreign bank's AML controls. Under Section 311 of the USA PATRIOT Act,
what authority does the U.S. Treasury Department possess?
A. Authority to impose civil money penalties on the U.S. bank only
B. Authority to designate the foreign bank as a primary money laundering concern and
impose special measures
C. Authority to arrest executives of the foreign bank
D. Authority to automatically revoke the foreign bank's banking charter
Correct Answer: B
Rationale: Correct because Section 311 of the USA PATRIOT Act grants the Secretary of the
Treasury the authority to designate a foreign jurisdiction, financial institution, or class of
transactions as a primary money laundering concern and impose one or more of five special
measures to combat the risk.
Q9: A compliance officer reviews a customer's wire transfer activity. The customer, a small
import-export business, sends wires to a trading company in a high-risk jurisdiction. The
stated purpose is "payment for electronics," but the amounts are inconsistent with typical
