Ralph Lauren: Inadequate Rewards For Exemplary Cooperation

Law360, New York (May 1, 2013, 7:53 PM EDT) -- On April 22, the U.S. Department of Justice and the U.S. Securities and Exchange Commission announced nonprosecution agreements with Ralph Lauren Corporation relating to the bribery of Argentine custom officials to import products into Argentina without necessary inspections and paperwork. The SEC said it decided not to bring charges because the company promptly self-reported the bribes and thoroughly cooperated in the SEC's investigation. Although the government will no doubt cite these NPAs as an exemplar of the benefits of self-reporting and cooperation, we think they reaffirm the importance of careful consideration before a company decides to self-report potential unlawful conduct....

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