On March 26, 2012, the U.S. Department of Justice (“DOJ”) announced that Biomet, Inc., a medical device maker, agreed to pay a $17.28 million criminal penalty and enter into a three year deferred prosecution agreement (“DPA”) to settle several claims brought under the Foreign Corrupt Practices Act (“FCPA”), 15 U.S.C. § 78dd-1, et seq. See information United States v. Biomet, Inc., No. 12-cr-00080 (D.D.C. Mar. 26, 2012). From 2000 to 2008, Biomet allegedly paid more than $1.5 million in payments to government-employed physicians and administrators at public hospitals in Argentina, Brazil, and China in exchange for using Biomet’s products. The DOJ further alleged that Biomet improperly recorded the payments on its books as consulting fees, royalties, or sales and marketing expenses. In addition to the criminal penalty, Biomet’s DPA requires the company to appoint an independent external compliance monitor for at least the first 18 months of the DPA. The DOJ’s investigation into Biomet’s conduct was part of a larger investigation into bribery allegations against medical device companies of government-employed health care providers, and Biomet’s DPA is similar to previous DPAs reached between the DOJ and Johnson & Johnson and Smith & Nephew, Inc. pertaining to similar allegations.