From Vaudeville to the Silver Screen to the Small Screen, the Marx Brothers made an impact wherever people found them. Now Tom Fox and Mike Volkov have wedded their love of the Marx Brothers with their passion for compliance and bring them into the boardroom to help explain and explore the sometimes-chaotic world of governance, risk-management, ethics and compliance. In this episode they discuss the movie Coconuts and how it informs the OFAC Compliance Framework.  Highlights from the podcast include:

  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?


  1. From Tom Fox-see articles on the OFAC Compliance Framework.
  2. Introduction
  3. Management Commitment
  4. Risk Assessment
  5. Internal Controls
  6. Testing, Training and Auditing
  7. From Mike Volkov-See article on the OFAC Compliance Framework.
  8. Introduction
  9. Risk Assessments and Internal Controls
  10. Testing and Auditing and Training
  11. Review of Lessons Learned
  12. Download a copy of the OFAC Compliance Framework, here.

Marx Brothers

Coconuts-the full movie on YouTube.