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Company A a multinational manufacturing corporation, recently acquired a local company in Country Z that has a high level of state involvement in ihe economy and history of corruption Before purchasing the company. Company A hired a major international law firm to conduct a due diligence review and uncover any potential violations of global anti-corruption laws When the review came back free of issues Company A completed its acquisition.
Two years later executives from Company A were conducting their first anti-corruption compliance training with employees from the Country Z office During the training session Company A executives were alerted by Country Z-based employees that the distributors the company uses may be bribing government officials Company A had not conducted a review of distributors in Country Z, and when it began to look into the allegations it found widespread potential Foreign Corrupt Practices Act (FCPA) violations.
Which are two weaknesses in Company A's anti-corruption compliance program? Choose 2 answers

• A. Company A failed to reach out directly togovernmentagencies within Country Z to request information on any history of corrupt payments at the company it was acquiring
• B. Company A should have conducted anti-corruption compliance training as soon as possible after acquiring the company in Country Z
• C. The due diligence review should have been exclusively conducted by local counsel from within Country Z becausetheywould be better versed in the country's culture and laws
• D. Company A did not include its distributors within Country Z when conducting its anti-corruption due diligence and training

You are investigating a multi-national company for financial fraud As part of your investigation, you would like to determine whether the company has complied with applicable tax laws in the jurisdictions in which it operates As a preliminary starting point you need to know the applicable laws relating to exchange of tax information.
Other than contacting the governments of each jurisdiction which organization's website would have the MOST effective resources for obtaining such information?

• A. Internal Revenue Service (IRS)
• B. United Nations Office of Drugs and Crime (UNODC)
• C. World Bank Doing Business Project
• D. Organization for Economic Cooperation and Development (OECD)

Which scenario is an example of the placement stage of money laundering?

• A. A Ponzi scheme operator uses his debit card associated with his British Virgin Islands bank account to withdraw cash from an ATM machine in the U.S.
• B. A multiple lax refund scheme fraudster transfers the proceeds of his illicit tax refund from a prepaid debit card to a foreign bank account through an online funds transfer service
• C. A Mexican money broker deploys couriers across the U S border where they deposit drug cash into the U S National Bank of San Diego
• D. A money laundering organization moves illicit drug proceeds into the U S financial system through a wire transfer into the correspondent account of a Guatemalan Bank domiciled at a U S financial institution

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

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