The DOJ’s recent settlement with medical-device distributor Olympus demonstrates that corruption is not confined to emerging or high-risk markets. Rather, when a company fails to implement effective compliance measures, corruption can occur anywhere, even in the United States. From 2006 to 2011, Olympus Latin America (OLA) attempted to increase medical equipment sales in Central and South America by paying health care practitioners at government-run facilities more than $3 million. Simultaneously, in North America, Olympus employees were paying kickbacks to doctors and hospitals. The charges against Olympus resulted from a False Claims Act lawsuit filed by its former chief compliance officer who allegedly first-reported the claims internally – Olympus executives apparently failed to heed his warnings. See “Whistleblower Advocate and Experts at Gibson Dunn Discuss the Current State of the Dodd-Frank Whistleblower Program” (Jan. 13, 2016).