Theodore Banks is a partner at Scharf Banks Marmor LLC in Chicago, and President of Compliance & Competition Consultants, LLC. He is the editor of the Corporate Legal Compliance Handbook, published by Wolters-Kluwer, and an adjunct professor at Loyola University Chicago School of Law, where he teaches corporate compliance. This article is based on a presentation to the University of Denver Sturm College of Law (March 2015).