James Tillen was quoted on Miller & Chevalier's FCPA Winter Review 2019 and the apparent decline in Foreign Corrupt Practices Act investigations launched in 2018. Tillen acknowledged that the data collected for 2018 investigations is incomplete, but he said the numbers are "still a helpful barometer." Tillen also said the "appetite" for enforcement at the Securities and Exchange Commission and the Department of Justice remains steady, and that – despite the statistics – companies should not "take their feet off the pedal."