Someone whose actions go against the interests of American corporations, even if they received US government money six months ago.
Not to be confused with a "strong leader of a troubled country", which is someone who is still receiving US government money and using it to butcher the locals.
Saddam Hussein (since 1990 only)
Mullah Mohammed Omar
Slobodan Milosevic (in Kosovo/a, but not in Bosnia)
definitely NOT: Jiang Zemin, Putin, Indonesian presidents, the guy in Uzbekistan, Museveni of Uganda etc etc, who aren't ruthless dictators because they still support US interests and/or are too big to bomb