Business Crimes Hotline

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The DOJ noted that Ralph Lauren's Argentinean subsidiary did not have an anti-corruption program in place during the time of the alleged improper payments, but also discussed the company's significant efforts at investigation and remediation ' starting with a self-disclosure of the conduct. Ralph Lauren's investigative efforts included conducting a worldwide risk assessment and presenting the results of the same to the Government, while its “early and extensive” remediation efforts included enhancements to its due diligence protocols for third-party agents, as well as the appointment of a dedicated corporate compliance attorney.

In connection with the DOJ NPA settlement, Ralph Lauren agreed to pay a fine of $882,000. The SEC's settlement included a commitment by the company to pay a total of $734,846 in disgorgement and prejudgment interest.

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NEW YORK

SEC Reaches First FCPA-Related Non Prosecution Agreement with Ralph
Lauren Corp.

On April 22, 2013, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) (collectively, Government) separately announced that they had each reached agreements with Ralph Lauren Corporation in connection with parallel investigations into FCPA allegations at the New York-based clothing company. The SEC's Non Prosecution Agreement (NPA) represents the Commission's first FCPA-related NPA. The settlements principally arise from allegations of improper payments to Argentinean government officials as part of the customs clearance process for the company's merchandise over a five-year period. The payments, which were channeled through a customs agency that generated corresponding false invoices to cover the payments, were provided in exchange for avoiding inspection, securing necessary paperwork, clearing prohibited items, and clearing items without necessary paperwork.'

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The DOJ noted that Ralph Lauren's Argentinean subsidiary did not have an anti-corruption program in place during the time of the alleged improper payments, but also discussed the company's significant efforts at investigation and remediation ' starting with a self-disclosure of the conduct. Ralph Lauren's investigative efforts included conducting a worldwide risk assessment and presenting the results of the same to the Government, while its “early and extensive” remediation efforts included enhancements to its due diligence protocols for third-party agents, as well as the appointment of a dedicated corporate compliance attorney.

In connection with the DOJ NPA settlement, Ralph Lauren agreed to pay a fine of $882,000. The SEC's settlement included a commitment by the company to pay a total of $734,846 in disgorgement and prejudgment interest.

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