ADM Nutrition segment accounting: from CFO leave to a $40 million SEC settlement
ADM Nutrition segment accounting: from CFO leave to a $40 million SEC settlement: a public-record watch file compiled by Falling Shares Intelligence from filings and exchange disclosures, as of 2026-11-08. On 21-22 January 2024 ADM placed its Chief Financial Officer on leave, opened an Audit Committee investigation into Nutrition segment accounting after an SEC voluntary document request, and delayed its results; the shares fell sharply, with reports citing 16% intraday and about 24% on the day.
An SEC document request, a restatement, a CFO on leave and a one-day share collapse in January 2024, then settled charges in January 2026 and a litigated case that is still open.
Falling Shares Intelligence, Edited by Wung Thomas, Editor-in-Chief. As of .
Summary
- On 21-22 January 2024 ADM placed its Chief Financial Officer on leave, opened an Audit Committee investigation into Nutrition segment accounting after an SEC voluntary document request, and delayed its results; the shares fell sharply, with reports citing 16% intraday and about 24% on the day.
- ADM restated its 2023 annual report and the first two 2024 quarterly reports in November 2024 to correct segment reporting errors; it says the changes had no impact on consolidated balance sheet, earnings or cash flows.
- On 27 January 2026 the SEC announced settled charges against ADM ($40 million civil penalty) and two former executives, and a litigated complaint against a third. The SEC says Nutrition operating profit was overstated in fiscal 2019, 2021 and 2022.
- The U.S. Department of Justice closed its investigation with no further action, according to ADM. The litigated case in the Northern District of Illinois has not been resolved and the defendant denies the allegations.
Key figures
| SEC civil penalty (ADM) | $40 million (Settled, without admitting or denying, 27 Jan 2026) |
|---|---|
| Years of overstated Nutrition operating profit | FY2019, 2021, 2022 (Per SEC findings, plus certain quarters) |
| Share fall on 22 Jan 2024 | ~16% intraday; ~24% reported (Sources differ) |
| Restated periods | FY2023 10-K, Q1-Q2 2024 (Restated November 2024) |
| DOJ | Closed, no further action (As stated by ADM) |
The January 2024 shock
CFO on leave, investigation and delayed results
ADM said it placed its Chief Financial Officer on administrative leave pending an investigation by outside counsel and the Audit Committee into accounting practices and procedures in its Nutrition segment, including certain intersegment transactions. The investigation began after ADM received a voluntary document request from the SEC. ADM named an interim CFO, withdrew Nutrition outlook and delayed its fourth-quarter and full-year 2023 results. (21-22 Jan 2024)
Share-price fall
Reports describe shares sliding about 16% in early trading, and one outlet reports a fall of 24% on the day. (22 Jan 2024)
Restatement and internal investigation
Restatement of segment reporting
ADM corrected certain prior-period errors in March 2024 and in November 2024 restated its 2023 Form 10-K and the first and second quarter 2024 Forms 10-Q to fix errors in historical segment reporting. It states the changes had no impact on its reported consolidated balance sheet, earnings or cash flows for those periods. (Mar and Nov 2024)
Audit Committee investigation reported to the SEC
ADM says outside counsel conducted an investigation under the Audit Committee's oversight and that it voluntarily reported the findings to SEC staff. The SEC credits the internal investigation, voluntary reporting, accounting-expert analyses and new intersegment controls. (2024-2026)
The SEC's findings and charges
Settled order against ADM
The SEC found ADM overstated Nutrition's operating profit in fiscal 2019, 2021 and 2022. It found adjustments to intersegment transactions meant such transactions were recorded on terms that did not approximate market, and that retroactive rebates and price changes not customarily available to third-party customers moved profit into Nutrition so the segment appeared to meet projected operating-profit growth of 15% to 20% a year. ADM agreed to a $40 million civil penalty without admitting or denying the findings, and to cooperate with the SEC in the litigation. A Fair Fund will distribute relief to harmed investors. (27 Jan 2026)
Two former executives settle
Former executive Vince Macciocchi, without admitting or denying the findings, agreed to $404,343 in disgorgement and prejudgment interest, a $125,000 civil penalty and a three-year officer and director bar. Former executive Ray Young, also without admitting or denying, agreed to $575,610 in disgorgement and interest and a $75,000 penalty; the SEC found he negligently approved improper adjustments in 2019 and 2021. (27 Jan 2026)
Litigated complaint against a former CFO
The SEC filed a litigated complaint against Vikram Luthar, alleging antifraud, reporting, books-and-records and internal-controls violations, and seeks injunctions, an officer and director bar, disgorgement, civil penalties and reimbursement of certain compensation. His lawyer denies the allegations, calls the complaint one-sided and cites ADM's March 2025 proxy statement, which said an internal investigation did not find him to have engaged in improper conduct. (27 Jan 2026)
Evidence that cuts the other way
DOJ closed its investigation
ADM said the Department of Justice closed its investigation with no further action and that the SEC and DOJ outcomes end the investigations of ADM. (27 Jan 2026)
No effect on consolidated results; remediation
ADM says the restatements did not change consolidated balance sheet, earnings or cash flows and that it made significant changes to its financial leadership and financial controls. Its chief executive cited extensive actions taken to enhance internal controls. (Jan 2026)
Standard
This file compiles SEC documents, company filings and published reporting about accounting for intersegment transactions at Archer-Daniels-Midland Company (ADM). SEC findings in settled orders were agreed without admitting or denying them. Allegations in the SEC's litigated complaint are unproven. Individuals are named only as in the SEC's official documents, with their procedural status. This is news coverage for information only, not investment advice.
Right of reply
Archer-Daniels-Midland Company, and anyone connected with the matter, can send corrections or comments to info@fallingshares.com (or directly to the Editor-in-Chief, Wung Thomas, at wungthomas@fallingshares.com). Material responses will be published alongside the relevant entry.