James Tillen was quoted on the involvement of joint ventures in several major Foreign Corrupt Practices Act (FCPA) settlements in 2019, and the need for companies to tailor their compliance programs to a joint venture's risk profile and structure, even when the U.S. issuer holds a minority interest. "[The program] may be able to simplify forms, reduce the number of policies, the approval processes," Tillen said. "Conversely, with a joint venture with an anticipated small number of third parties, you may have to require all of them to have due diligence and in fact have all of them go to the Board of Directors."