James Tillen was quoted regarding certain FCPA due diligence necessary as U.S. companies acquire or merge with companies offshore. In discussing the DOJ's recent Opinion Procedure Release addressing M&A due diligence, he noted that more guidance is needed when it comes to accounting and recordkeeping shortcomings that result from acquiring operations with FCPA issues: "The opinion release remarked on how bad a shape the target's books were. It didn't address whether that created the potential for successor liability under FCPA's accounting provisions."