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• ADM will pay a $40 million civil penalty

• Macciocchi will pay $404,343 in disgorgement and interest plus a $125,000 civil penalty

• Young will pay $575,610 in disgorgement and interest plus a $75,000 civil penalty

Macciocchi also accepted a three-year ban from serving as an officer or director of a public company.

Luthar Case Moves Forward

The SEC alleges Luthar violated federal securities anti-fraud provisions, aided and abetted reporting and internal controls violations, and failed to reimburse ADM for certain executive compensation.

The agency is seeking civil penalties, disgorgement with interest, reimbursement of pay, and an officer-and-director ban.

Regulators say ADM’s periodic filings were materially false and misleading — and that Luthar personally benefitted from the alleged misconduct.

ADM: Errors Corrected, Controls Strengthened

ADM said it cooperated fully with the SEC, commissioning an internal investigation led by outside counsel under the oversight of its audit committee and voluntarily reporting findings to regulators.

The company said it corrected prior-period errors in March 2024, and later restated its 2023 Form 10-K and 2024 first- and second-quarter 10-Qs to address segment-reporting errors.

ADM emphasized the issues did not affect consolidated earnings, balance sheets, or cash flows, and said it has since made significant changes to its financial leadership team and internal controls.

Defense Pushes Back Hard

Luthar’s attorney, Junaid A. Zubairi, called the SEC’s allegations “meritless,” arguing the complaint ignores exculpatory facts and mischaracterizes long-standing company practices.

He said an internal investigation found no improper conduct by Luthar and described the transactions as transparent, approved, and carried out in good faith.

“Mr. Luthar adamantly denies the allegations,” Zubairi said, adding that his client rejected settlement and intends to clear his name in court.

SEC: Transparency Is Non-Negotiable

Margaret A. Ryan, director of the SEC’s Division of Enforcement, said transparent disclosure is essential to market integrity and credited ADM for its cooperation and remedial efforts.

ADM President Juan Luciano said the company is ready to move forward.

“These past years reinforced what matters most — strengthening our controls, accuracy and integrity,” Luciano said.

Legal Representation

The SEC is represented by Timothy Leiman, Timothy J. Stockwell, Ashley E. Dalmau Holmes, and Arefa Patel.

ADM is represented by Stephanie Avakian of WilmerHale.
Luthar is represented by Junaid A. Zubairi of Vedder Price.
Macciocchi is represented by Brian A. Jacobs of Morvillo Abramowitz Grand Iason & Anello PC.
Young is represented by Pravin Rao of Perkins Coie LLP.

Counsel for Macciocchi declined to comment, and counsel for Young did not immediately respond.