Argentine customs officials; Argentine government officials
Ralph Lauren Corporation ("RLC") is a Delaware corporation headquartered in New York, whose shares are traded on the New York Stock Exchange. The company is in the business of design, marketing, and distribution of apparel, accessories, and other products around the world.
According to the admitted statement of facts attached to the non-prosecution agreement RLC entered into with the DOJ, RLC's Argentine subsidiary ("RLC Argentina") allegedly paid bribes and gifts to Argentine customs officials from 2005 to 2009 to assist in improperly obtaining paperwork necessary for its products to clear customs, permit clearance of items without the necessary paperwork, permit clearance of prohibited goods, and to avoid inspection of products by Argentine customs officials. RLC Argentina had retained a customs broker to assist with issues related to the importation of merchandise into Argentina. Later, the corporation allegedly used this customs broker to faciliate the bribes and pass them on to the customs officials. From approximately 2005 through 2009, the corporation allegedly paid $568,000 to the customs broker for the purpose of bribing Argentine customs officials.
In addition, the general manager of RLC Argentina allegedly directly provided or authorized provision of several gifts to three Argentine government officials to improperly secure the importation of the corporation's products into Argentina. These gifts were allegedly provided between 2005 and 2009, and they included perfume, dresses, and handbags valued at between $400 and $14,000 each.
During the time in which the bribes allegedly occurred, RLC did not have an anti-corruption program in place and did not provide anti-corruption training or oversight to its Argentine subsidiary.
Upon discovery of the bribes, RLC ceased its operations in Argentina.
Under the non-prosecution agreement, Ralph Lauren Corporation agreed to pay a monetary penalty of $882,000.
In the parallel civil action, RLC entered into a non-prosecution agreement with the SEC and agreed to pay $734,845 in disgorgement and prejudgment interest.