Medical device company Orthofix has settled FCPA charges again, this time based on its Brazilian subsidiary’s use of commercial representatives and distributors to bribe doctors at state-owned hospitals. Pursuant to an SEC order, Orthofix has agreed to pay $6.25 million and retain an independent consultant. Unlike its previous 2012 FCPA settlement, which involved bribery at its Mexican subsidiary, there is no accompanying DOJ enforcement action. We dissect Orthofix’s FCPA resolution and provide enforcement and compliance lessons, including a comparison to Biomet, another repeat offender in the same industry, whose second FCPA resolution came in 2017. See “After Two Extensions of Its DPA, Zimmer Biomet Settles Further FCPA Charges for $30M” (Feb. 1, 2017).