Litigator Jonathan Green Discusses Ralph Lauren Bribery Settlement in The Wall Street Journal

The Wall Street Journal reports that Ralph Lauren Corp. has settled with the US government over claims that the company bribed officials in Argentina to obtain clearance of its products through customs, and then proceeded to inflate invoices in order to cover up the payments. The company will pay six-figure sums to both the US Department of Justice and the Securities and Exchange Commission to settle the claims. Ralph Lauren discovered the misconduct in the course of its efforts to improve its compliance systems, conducted a thorough internal investigation, and reported the matter to the Department of Justice and the Securities and Exchange Commission.

According to Kaye Scholer White Collar Litigation & Internal investigations Counsel Jonathan Green, a former senior counsel in the enforcement division of the SEC, “The problem is no one writes ‘bribe’ in the company’s books and records, they record it as something else. That’s why we have inaccurate invoices and inaccurate books and records.”

Green continues, “I think the government would agree it was lenient with Ralph Lauren; that was the point of their non-prosecution agreement. The government wanted to underscore that a company should self-report, cooperate and implement strong anti-corruption compliance measures.”