On the one hand I can look at what he did and say that his intent was good and he protected those women and protected his company. However, Mr. Sullivan is clearly taking the law into his own hands (even if that law is in another country).

If you look at this as a business deciding that they want to move forward a business deal elsewhere in the world, they would run afoul of the FCPA if they decided to bribe someone to further that business deal. But it seems that hiring PMCs to intimidate and threaten people is permitted. Perhaps the time has come for legislation to cover this particular practice.