James Tillen comments on the investigation of News Corporation over its payment to a U.S. soldier for photographs of Saddam Hussein in his underpants. Tillen said the suggestion that The Sun newspaper might have paid a U.S. official to obtain the pictures of Saddam Hussein was "very relevant" to on-going investigations into News Corporation.

"If the authorities are already looking into News Corp -- and there is every indication that they are -- this is definitely another piece of relevant information to consider," he said. "The fact that the Sun may be incorporated in the UK certainly wouldn't be a complete inoculation from being punished in the United States, if they were shown to have made a payment to a U.S. official. That's certainly something the Department of Justice could be looking into, if these allegations are true."

The Foreign and Corrupt Practices Act (FCPA) requires U.S. companies to show that they have not paid bribes to foreign officials, and that they and their foreign affiliates have used company money for legal purposes.

"The FCPA applies to public companies such as News Corp and requires them to maintain certain controls, to ensure that their money is spent for legitimate things. And also a part that requires them to keep accurate books and records," Tillen said. "Establishing a pattern of bribery may have implications on the anti-bribery side, but would also have implications on the internal control side, because they would suggest that News Corp wasn't maintaining a system of policies and controls to show that their money was going for legitimate activities."