James G. Tillen
Member
James Tillen's practice focuses on cross-border investigations and compliance matters involving corruption, fraud, money laundering, business and human rights, workplace conduct, and other areas of international corporate compliance. He works with U.S. and non-U.S. clients to address compliance challenges that arise in a variety of contexts, including compliance program design and implementation, transactional counseling, advisory opinions, internal investigations, enforcement actions by the U.S. Department of Justice (DOJ), Securities and Exchange Commission (SEC), and other enforcement authorities, and FCPA monitorships. Mr. Tillen also has conducted merger and acquisition (M&A) and third-party due diligence reviews, assessed client and third-party compliance programs, developed training programs, and performed training for client operations throughout the world.
Who's Who Legal and Global Investigations Review recognize Mr. Tillen as one of the world's leading investigations lawyers, and one source said he "knows FCPA enforcement better than anyone I've ever come across." The "very business savvy" Tillen is "practical, responsive and has excellent, highly particularized experience," according to clients who were quoted by Chambers USA and Chambers Global.
Representative Engagements
- Led compliance due diligence for a client's multi-billion-dollar acquisition of a company in the extractives industry, which included on-the-ground interviews in remote locations and review of the acquisition's compliance program. The review was completed within six months of closing to ensure that the client could avail itself of the DOJ's Safe Harbor policy if violations were detected.
- For a medical device company, conducted an investigation of workplace harassment, discrimination, and fraud allegations involving members of senior management. In connection with findings, advised on remedial measures and compliance program improvements.
- Conducted an investigation of an oil and gas services company's transactions with Petrobras, involving interviews, audits of third parties, forensic imaging, and extensive document review in Portuguese and English. Represented the company in a subsequent investigation by the DOJ and SEC, which closed without an enforcement action.
- Led a global assessment of a client's anti-corruption, anti-money laundering (AML), trade compliance, and human rights compliance program, involving site visits to domestic and international operations in Africa and Europe, dozens of interviews with employees, and review of the company's paper compliance program. Presented findings and recommendations to the client's Board of Directors.
- For a multinational energy exploration company, assisted with a variety of compliance matters: reviewed and revised the policies and procedures comprising the company's global compliance program; performed due diligence on potential business partners in a number of countries (including interviews of partner candidates in West Africa and South East Asia); and conducted on-the-ground risk assessments of the company's operations in West Africa and the Middle East.
- Assisted an oil-field services company with due diligence and compliance integration of an acquisition worth over $2 billion. In connection with the work, performed due diligence on the acquisition's joint venture (JV) partners in Southeast Asia and Africa, involving interviews with employees, JV personnel, and the JV partners, retention of specialized due diligence firms, and review of related contracts.
Rankings and Recognition
- Chambers USA: FCPA (Nationwide), 2015 - 2024
- Chambers Global: FCPA (United States), 2016 - 2024
- Chambers Global: Corporate Crime & Investigations (Latin America-International Counsel), 2015 - 2024
- Chambers Latin America: Corporate Crime & Investigations (International Counsel), 2015 - 2025
- Legal 500 Latin America: International Firms: Compliance and Investigations, 2021 - 2025
- Legal 500: Dispute Resolution: International Trade, 2017 - 2022
- The Best Lawyers in America®: International Trade and Finance Law, 2020 - 2023
- Who's Who Legal: Business Crime Defence, 2017 - 2022
- Who's Who Legal: Investigations, 2014 - 2022, 2024
- Who's Who Legal: Thought Leaders – GIR, 2019
- DC Bar Capital Pro Bono Honor Roll, 2016, 2018, 2020
- Ethisphere Institute's Attorneys Who Matter (Specialists - Private Practice), 2014
- Latin Lawyer Anti-Corruption Survey: Top Lawyer, 2013
Affiliations
- Member, Editorial Board, Global Investigations Review
- Member, Anti-Corruption Committee Advisory Board, Legal Practice Division, International Bar Association
- Co-Chair, Anti-Corruption Committee, International Bar Association, 2014 - 2015
- Vice-Chair, Anti-Corruption Committee, International Bar Association, 2013
- North American Regional Officer, Anti-Corruption Committee, International Bar Association, 2012
- Secretary, Anti-Corruption Committee, International Bar Association, 2008 - 2011
Admissions
State Admissions
- District of Columbia
News and Events
Events
Speaking Engagement
ABC Minds International
Speaking Engagement
Implications of the Foreign Extortion Prevention Act on U.S. Companies Doing Business in Africa
Speaking Engagement
20th Annual IBA Anti-Corruption Conference
Speaking Engagement
2024 ABA International Law Section Annual Conference
Publications
Internal Publication
New Considerations for Companies with U.K. Ties: Home Office Issues Guidance to Organisations on the Offence of Failure to Prevent Fraud
External Publication
Carrots vs. Sticks: How Companies Are Using Corporate Compliance Strategies to Fight Corruption in Latin America
External Publication
Carrots vs. Sticks: Corporate Compliance, Not Enforcement, Is Driving the Fight Against Corruption in Latin America
External Publication
High Risks, Low Institutional Trust: Why Stronger Anti Corruption Laws Do Not Guarantee Increased Reporting of Corruption in Latin America
Internal Publication