Late last month, the Securities and Exchange Commission (“SEC”) announced a non-prosecution agreement (“NPA”) with Ralph Lauren Corporation (“RLC”), through which the company must disgorge more than $700,000 in illicit profits (and interest) obtained between 2005 and 2009 in connection with bribes paid by a subsidiary to government officials in Argentina. In a second NPA, RLC contemporaneously resolved the same matter with the Department of Justice (“DOJ”), agreeing to pay an additional penalty of $882,000.
