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Know Your Third Party: How Your Business Partners Can Get You in Trouble

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Last week, on April 22, 2013, Ralph Lauren Corporation agreed to pay more than $1.6 million to the US government to settle charges that it violated the FCPA by bribing customs officials in Argentina. According to the allegations, Ralph Lauren’s subsidiary in Argentina paid approximately USD 568,000 to a customs broker who in turn paid bribes to customs officials to secure the importation of Ralph Lauren products into Argentina between 2005 and 2009. The subsidiary also allegedly approved gifts of, perfume, handbags and dresses, to three customs officials during the same time period. Ralph Lauren More…

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