ACFCS Financial Crime SpecialistExam CFCS Question # 67 Topic 2 Discussion

ACFCS Financial Crime SpecialistExam CFCS Question # 67 Topic 2 Discussion

CFCS Exam Topic 2 Question 67 Discussion:
Question #: 67
Topic #: 2

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.

The Policy ofinvoice review - All invoices should be subject to senior management approval not only those above a certain level


C.

Thewhistleblowerpolicy - Reporting should never go through the company's business lines it should lake place anonymously


D.

The promotion of a current employee as head of compliance - Compliance officers should always be hired externally to minimize the chances of internal fraud


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