Editor’s note: This article has been modified since its original online publication, with a correction made to a dollar amount.

On July 21, 2010, upon signing the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (pdf), President Barack Obama announced that “unless your business model depends on cutting corners or bilking your customers, you’ve got nothing to fear from reform.” In the real world of companies operating in highly regulated industries, what one person defines as bilking customers may be viewed by another as staying within the chalklines. Moreover, despite even the best efforts to promote compliance, all companies face a risk that employees will engage in behavior that subjects the company to liability.

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