James Tillen Quoted in Dow Jones Regarding FCPA Compliance

"To Comply With Bribery Laws, Companys Must Decide Who's 'Official'"
Dow Jones Newswire
04.29.10James Tillen discusses the Foreign Corrupt Practices Act, explaining that the FCPA defines "foreign official" as "any officer or employee of a foreign government or any department, agency, or instrumentality thereof," and that "instrumentality" has been at the heart of the broadening definition. "The statute itself has a definition. It's quite broad, and it's interpreted even more broadly by the [Securities and Exchange Commission] and the Justice Department," Tillen said. "Corporations and companies don't fight these matters and don't litigate them. They usually settle because it's costly and it could damage a company's reputation."
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