A non-prosecution agreement means that there will be no criminal charges filed against the company. The SEC even said here that it has decided not to charge the company under the Foreign Corrupt Practices Act because of its prompt reporting of the violations on its own initiative. Other reasons cited were the completeness of the information provided and the real-time cooperation with the SEC’s investigation, which saved the agency substantial time and resources.
The SEC went on to say that this NPA is the first that the SEC has entered involving Foreign Corrupt Practices Act misconduct. In parallel criminal proceedings, the Justice Department entered into an NPA with Ralph Lauren in which the company will pay an $882,000 penalty.
The bribe payments and gifts to Argentine officials were shown by the SEC to come to a total of $593,000 during a four-year period. Ralph Lauren agreed to pay $593,000 in disgorgement and $141,845.79 in prejudgment interest. It is almost surprising that shares are down even 1.7% at $166.25 on the day.
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