In this Episode, Tom Fox and Mike Volkov discuss the Marx Brothers movie, Coconuts, and the new OFAC Compliance Framework.

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Tom and Mike address the following issues:

1. Why has Mike Volkov called the OFAC Compliance Framework a ‘game-changer’?
2. How does the OFAC Framework illustrate regulatory convergence?
3. What are some of the highlights of the OFAC Framework?
4. What are some of the key lessons learned for the ABC compliance professional?
5. How does data analytics as mandated in the OFAC Framework inform ABC compliance programs going forward?
6. What are the mandates built into the OFAC Framework?
7. How can an ABC compliance practitioner use the OFAC Framework if their company is under FCPA scrutiny?