The US Securities and Exchange Commission and the US Department of Justice reached the first ever dual non-prosecution agreement with Ralph Lauren Corporation in respect of FCPA investigations which the company self-reported. In exchange for agreement not to pursue an FCPA prosecution for bribes which an Argentine agent paid to Argentine officials in the period 2005-2009, the company, which had no “meaningful” compliance programme when the behaviour occurred, agreed to pay $1.6m in disgorgement and penalties and implement other reforms including conducting extensive FCPA training for employees world-wide, hiring a designated corporate-compliance lawyer, and enhancing its due diligence protocols for third party agents.