(Allegation) RLC’s Argentine subsidiary paid bribes to customs officials to clear goods through customs that either lacked the proper paperwork or were outright prohibited by Argentine law. All the bribes were authorized by RLC Argentina’s general manager and spanned a four-year period.
(Agency-theory) Both DOJ and SEC characterized the general manager as RLC’s “agent,” apparently based solely on his position as general manager of the subsidiary and the fact that RLC had appointed him to that position. Neither agency included any allegation of any authorization, direction or control by RLC.