James Tillen discusses the charges brought against eight former Siemens A.G. executives and agents of violating the Foreign Corrupt Practices Act in a scheme to bribe senior government officials in Argentina. The charges follow December 2008 guilty pleas by Siemens and its Buenos Aires-based subsidiary to criminal violations of the FCPA. Commenting on the DOJ and SEC charges, Tillen said at the time of the Siemens guilty plea in 2008, observers believed that, given the amount of liability, there had to be individuals who were liable as well. "I think there's a lesson there that just because a company settles a case, it doesn't mean the matter is over with," just that it may take longer to take action against individuals.

Tillen said the agencies' action also shows their "appetite for bringing cases against individuals has not waned." Putting executives in jail conveys a "stronger message than simply fining a company and [the DOJ and SEC will] continue to do that even though it's more challenging to bring those matters."