April 30, 2013

SEC Enters Into First FCPA Non-Prosecution Agreement

Arnold & Porter Advisory

On April 22, 2013, the Securities and Exchange Commission (SEC) announced its first-ever non-prosecution agreement (NPA) in a matter involving potential violations of the Foreign Corrupt Practices Act (FCPA). The SEC heralded this NPA -- which it entered into with Ralph Lauren Corporation (Ralph Lauren) -- as an example of the "substantial and tangible" benefits that companies may earn through the SEC Enforcement Division's Cooperation Initiative (Cooperation Initiative). However, exactly when a company may be able to secure an NPA from the SEC and exactly what benefits accrue from such a resolution remain to be seen.


Arthur Luk
Arthur Luk
Washington, DC
Daniel Bernstein
Daniel Bernstein
Senior Attorney*
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