James Tillen was quoted regarding Avon's recent and large settlement as a result of alleged violations of the Foreign Corrupt Practices Act (FCPA). In February, Avon disclosed that the investigation had already cost $344 million, a number that is "amazingly high" according to Tillen. "Even multi-country investigations can often be done more affordably," he said. "There are a variety of factors which can make investigations so costly. It depends on their scope, the amount of documents which must be reviewed and the complexity of the alleged wrongdoing -- but US$344 million remains very much on the high side," Tillen added.