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SEC Enters First-Ever Non-Prosecution Agreement in FCPA Case

Bruce Carton | April 23, 2013

Yesterday the SEC announcednon-prosecution agreement (NPA) with Ralph Lauren Corporation related to alleged bribes a subsidiary of the company paid to government officials in Argentina from 2005 to 2009. The agency noted in a press release that the NPA with Ralph Lauren Corp. was the first that the SEC had entered involving Foreign Corrupt Practices Act misconduct. In May 2011, the SEC resolved an FCPA investigation into Tenaris, a manufacturer of steel pipe products, via its first-ever deferred prosecution agreement (DPA).

According to the SEC, Ralph Lauren Corp. discovered the misconduct on its own through an internal review and promptly reported it to the SEC. The agency stated that based on the company's "prompt reporting of the violations on its own initiative, the completeness of the information it provided, and its extensive, thorough, and real-time cooperation with the SEC's investigation," the SEC decided to resolve the matter through an NPA rather than an enforcement action charging the company with violations of the FCPA.

In a parallel criminal proceeding, the DOJ also entered into an NPA with Ralph Lauren Corp. in which the company will pay a penalty of $882,000. The DOJ stated that in addition to the monetary penalty, 

RLC agreed to cooperate with the Department of Justice, to report periodically to the department concerning RLC's compliance efforts, and to continue to implement an enhanced compliance program and internal controls designed to prevent and detect FCPA violations.  If RLC abides by the terms of the agreement, the Department will not prosecute RLC in connection with the conduct.

he SEC has determined not to charge Ralph Lauren Corporation with violations of the Foreign Corrupt Practices Act (FCPA) due to the company's 
he SEC has determined not to charge Ralph Lauren Corporation with violations of the Foreign Corrupt Practices Act (FCPA) due to the company's