James Tillen is Chair of the International Department. His practice focuses on matters involving the Foreign Corrupt Practices Act (FCPA), money laundering, business and human rights, and other areas of international corporate compliance. He has had significant experience with every facet of an FCPA enforcement matter, from inception to completion, including developing work plans for internal investigations, conducting internal investigations (including in-country witness interviews and document collections and reviews), developing remediation strategies (including employee discipline, compliance program enhancements, and employee training), disclosing issues to the U.S. government, negotiating resolutions with the U.S. government, developing strategies for collateral issues (including public relations and related litigation), selecting independent monitors, and interfacing with independent monitors on behalf of clients.
Mr. Tillen also has conducted anti-corruption due diligence reviews and compliance audits, drafted numerous anti-corruption compliance programs, developed training programs, and performed training for client operations throughout the world. He has created anti-money laundering compliance programs for a variety of multinational financial and non-financial institutions. In the area of business and human rights, Mr. Tillen has conducted risk assessments, advised on transactions presenting human rights risks, and developed corporate human rights policies.
Last year, the DOJ issued new or revised policies that impact Foreign Corrupt Practices Act (FCPA) prosecutions and expectations for corporate compliance programs. These policies include a new Safe Harbor Policy for voluntary self-disclosures made in...