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Enforcement Action Dataset

 

Initiation Date:    04/22/2013  Information

Prosecuting Agency:    US Department of Justice

Name of Prosecuting Attorneys:   

  • Loretta E. Lynch, United States Attorney
  • Sarah Coyne, Chief, Business & Securities Fraud Section
  • Jeffrey H. Knox, Chief, Fraud Section, Criminal Division
  • Daniel S. Kahn, Trial Attorney, Fraud Section, Criminal Division

Assisting Agencies:    U.S. Securities and Exchange Commission

Type of Action:    DOJ Criminal Proceeding

Docket or Case Number:    N/A

Court:    N/A

Origin of the Proceeding:    Voluntary disclosure

Whistleblower:    Unknown

Case Status:    Resolved


Summary  Information

Ralph Lauren Corporation ("RLC") is incorporated in Delaware with its principal place of business in New York, New York. RLC is a world-wide designer, marketer and distributor of premium apparel, accessories, fragrances and other products. RLC's stock is registered pursuant with the SEC and is listed on the New York Stock Exchange.

P.R.L. - S.R.L. ("RLC Argentina") was an indirect wholly-owned subsidiary of RLC headquartered and incorporated in Argentina. RLC Argentina marketed and sold RLC and other merchandise, including merchandise that was imported from outside Argentina.

From approximately 2004 through approximately 2009, RLC Argentina's General Manager and others who worked at RLC Argentina approved bribe payments of approximately $580,000 to be made to Argentine customs officials through Agent 1 to assist in improperly obtaining paperwork necessary for RLC products to clear customs, to permit clearance of items without the necessary paperwork, to permit the clearance of prohibited goods, and to avoid inspection of products by Argentine customs officials.

On April 22, 2013, the DOJ entered into a two year Non-Prosecution Agreement with RLC. Under the terms of the NPA, RLC agreed to pay a monetary penalty of $882,000, to continue to implement and enhance its anti-corruption compliance policies and procedures, and to submit annual reports to the DOJ for the duration of the NPA on the progress of its anti-corruption compliance. The DOJ determined that an NPA was appropriate due to RLC's discovery and self-report of the misconduct as well as the company's extensive, thorough, real-time cooperation with the DOJ and SEC and its extensive remedial efforts.

In a related proceeding on April 18, 2013, the SEC entered into a Non-Prosecution Agreement with RLC. Under the terms of the NPA and without admitting or denying the allegations in the NPA's statement of facts, RLC agreed to disgorgement of $593,000 plus prejudgment interest of $141,846. The SEC determined that an NPA was appropriate due to RLC's discovery and self-report of the misconduct as well as the company's extensive, thorough, real-time cooperation with the SEC and DOJ and its extensive remedial efforts.

Country(ies) involved:    Argentina

Region(s) involved:    Latin America

Total $ Sanctions Imposed by U.S. Government (FCPA-Related Charges Only):    $882,000

Sanction to Bribe Ratio:    $882,000 / $580,000 = 152.07 %

Sanction to Revenue Ratio:    Not Applicable

Sanction to Profit Ratio:    Not Applicable

FCPA Matter Name:   Ralph Lauren's Involvement in Argentina from 2005 to 2009 Information

Number of Related Enforcement Actions (Including This Enforcement Action):    2

Country(ies) involved:    Argentina

Region(s) involved:    Latin America

Total $ Bribery Payments:    $580,000

Total $ Revenue Generated from Bribery:    Unknown

Total $ Profit Earned or Expenses Avoided from Bribery:    Unknown

Total $ Sanctions Imposed by U.S. Government (FCPA-Related Charges Only):    $1,616,846

Sanction to Bribe Ratio:    $1,616,846 / $580,000 = (278.77 %)

Sanction to Revenue Ratio:    Not Applicable

Sanction to Profit Ratio:    Not Applicable

Name:    Ralph Lauren Corporation

Entity Type:    Public Company

Place of Incorporation:    United States

HQ Country(ies):    United States

Industry:    Consumer Goods

FCPA Claims:    Anti-Bribery, Primary, Issuer (15 U.S.C. § 78dd-1)

Related Claims:    None

Statutory Basis for FCPA Jurisdiction:    Issuer

Name:    P.R.L. - S.R.L.

Entity Type:    Subsidiary

Place of Incorporation:    Argentina

HQ Country:    Argentina

Industry:    Consumer Goods

Period of Bribery:   2004 - 2009

Total Bribery Payments:    $580,000

Total Revenue Generated from Bribery:    Unknown

Total Profit Earned or Expenses Avoided from Bribery:    Unknown

Country(ies) involved:    Argentina

Region(s) involved:    Latin America

Officials Potentially Influenced (Name; Title; Organization): 

  • Name Unknown, Officials; Argentine customs

Affiliates, Subsidiaries and Joint Ventures Involved in the Misconduct:    P.R.L. - S.R.L. - Subsidiary

Third-Party Intermediary:   

  • Agent 1 , Agent/Consultant/Broker

Type of Bribe:   Money

Cash, Wire or Check:    Unknown

Purpose of Bribe:    Facilitate import/export/delivery of products

TRANSACTION OVERVIEW
Bribery of Argentine officials

Period of Bribery:   2004 – 2009

Total Bribery Payments:    $580,000

Total Revenue Generated from Bribery:    Unknown

Total Profit Earned or Expenses Avoided from Bribery:    Unknown

Country(ies) involved:    Argentina

Region(s) involved:    Latin America

Officials Potentially Influenced (Name; Title; Organization):  

  • Name Unknown, Officials; Argentine customs;

Affiliates, Subsidiaries and Joint Ventures Involved in the Misconduct:    P.R.L. - S.R.L. - Subsidiary

Third Party Intermediary:    Agent 1 - Agent/Consultant/Broker

Type of Bribe:   Money

Cash, Wire or Check:    Unknown

Purpose of Bribe:    Facilitate import/export/delivery of products

Misconduct by Subsidiary?  Yes

Parent:    Ralph Lauren Corporation

  • Subsidiary:  P.R.L. - S.R.L.

    • Percentage of Ownership:    Unknown
    • Direct or Indirect Ownership:    Unknown
    • Parent Had Knowledge of Sub’s Bribery?:    No
    • Subsidiary Expressly Alleged to Be Parent's Agent:    No
    • Parent Liable for Sub Misconduct?:    No

M&A Negotiated or Completed During Misconduct, Investigation, or Resolution?     No

Not Applicable

Mitigating Factors Referenced by the Government (Company Defendants):

Defendant Self-Report Cooperation Voluntary Remedial Measures Misconduct Limited to Low Level Individuals Other factors
Ralph Lauren Corporation    

Aggravating Factors Referenced by the Government (Company Defendants):

Defendant Insufficient Cooperation Insufficient Remedial Measures
Ralph Lauren Corporation    

Total Global Monetary Sanctions (All Charges):    $882,000

Total Monetary Sanctions Imposed by U.S. Government (FCPA-Related Charges Only):    $882,000

Total Monetary Sanctions Owed to U.S. Government (FCPA-Related Charges Only):    $882,000

Case Status:    Resolved


Disposition:    Non-Prosecution Agreement

Date of Disposition:    04/22/2013

Ralph Lauren Corporation

—  Total Monetary Sanctions Imposed by U.S. Government for Defendant (FCPA-Related Charges Only):    $882,000

—  Organizational Probation:    None

—  Compliance Obligation:    Yes

—  Reporting Obligation:    Self-reporting

—  Admission of Guilt/Acceptance of Responsibility:    Yes

No Document Title Date Category