James Tillen discusses the Foreign Corrupt Practices Act, explaining that the FCPA defines "foreign official" as "any officer or employee of a foreign government or any department, agency, or instrumentality thereof," and that "instrumentality" has been at the heart of the broadening definition. "The statute itself has a definition. It's quite broad, and it's interpreted even more broadly by the [Securities and Exchange Commission] and the Justice Department," Tillen said. "Corporations and companies don't fight these matters and don't litigate them. They usually settle because it's costly and it could damage a company's reputation."