James Tillen discusses a surprising turn amid the Trump administration's narrowed focus on anti-corruption enforcement – the conviction of Carl Zaglin for conspiracy to commit money laundering, which underscores the Department of Justice's (DOJ) enduring commitment to prosecuting individual actors under the Foreign Corrupt Practices Act (FCPA). "The Zaglin jury conviction indicates that the government maintains some appetite for FCPA enforcement," Tillen said. He added, "Corrupt executives and individuals acting as middlemen for bribes are more likely to be prosecuted than the companies for which they work." Tillen also emphasized the strategic role of cooperating witnesses in complex international bribery cases: "Cooperating individuals bring the case to life, providing critical context for key events, communications and motivations, which otherwise may be difficult to establish using only vague emails and transactional records."