SEC v. Vikram Luthar, No. LR-26470, Northern District of Illinois (Jan. 27, 2026) — Press Release

U.S. SECURITIES AND EXCHANGE COMMISSIONLitigation Release No. 26470 / January 27, 2026Securities and Exchange Commission v. Vikram Luthar, No. 26-cv-0927 (N.D. Ill. filed Jan. 27, 2026)SEC Charges Former Archer-Daniels-Midland Company CFO with Accounting and Disclosure FraudThe Securities and Exchange Commission today filed accounting and disclosure fraud charges against Vikram Luthar, a former high-ranking finance executive of Archer-Daniels-Midland Company (“ADM”), alleging that as CFO of a critical ADM business segment, Nutrition, and then as ADM’s CFO, Luthar directed improper adjustments to shift operating profit to Nutrition from ADM’s other business segments so that Nutrition would meet the annual operating profit targets that ADM had touted to the investing public.The SEC’s complaint alleges that Luthar and other ADM executives portrayed the Nutrition segment as ADM’s engine for future growth and represented to investors that Nutrition’s operating profit was projected to grow by 15% to 20% per year. When Nutrition was falling short of its operating profit targets for fiscal years 2021 and 2022, Luthar allegedly directed “adjustments” to Nutrition’s transactions with other ADM business segments. According to the complaint, the adjustments included retroactive rebates and price changes that were not customarily available to ADM’s third-party customers and that were essentially one-sided transfers of operating profit to Nutrition, with the goal of making it appear that Nutrition was meeting its performance projections. The adjustments allegedly rendered the disclosure in ADM’s annual and quarterly reports about how it priced intersegment transactions false and misleading, as they resulted in transactions inconsistent with ADM’s representation that intersegment transactions were recorded at amounts “approximating market.” Because of the fraudulent adjustments that Luthar engineered, ADM’s fiscal year 2021 and 2022 periodic reports materially overstated Nutrition’s operating profit and operating profit growth, as alleged in the complaint.The complaint, filed in the U.S. District Court for the Northern District of Illinois, charges Luthar with violating the antifraud provisions of Section 17(a) of the Securities Act of 1933 and Section 10(b) of the Securities Exchange Act of 1934 and Rules 10b-5 and 13a-14 thereunder, aiding and abetting ADM’s violations of the antifraud, reporting, books and records, and internal accounting control provisions of the Exchange Act, and failing to reimburse ADM for certain executive compensation as required by Section 304 of the Sarbanes-Oxley Act of 2002. The complaint seeks permanent injunctions, an officer and director bar, disgorgement of ill-gotten gains with prejudgment interest, civil penalties, and reimbursement of certain executive compensation to ADM pursuant to Section 304 of the Sarbanes-Oxley Act.The SEC’s investigation was conducted by Arefa Patel and Kathleen Sweeney of the Chicago Regional Office, under the supervision of Steven Klawans, Ann Tushaus, and Paul Montoya, and was assisted by Ian Rupell of the Enforcement Office of the Chief Accountant, under the supervision of Ryan Wolfe. The litigation will be led by Tim Leiman, Ashley Dalmau-Holmes, and Timothy Stockwell, under the supervision of Ben Hanauer.

U.S. SECURITIES AND EXCHANGE COMMISSIONLitigation Release No. 26470 / January 27, 2026Securities and Exchange Commission v. Vikram Luthar, No. 26-cv-0927 (N.D. Ill. filed Jan. 27, 2026)SEC Charges Former Archer-Daniels-Midland Company CFO with Accounting and Disclosure FraudThe Securities and Exchange Commission today filed accounting and disclosure fraud charges against Vikram Luthar, a former high-ranking finance executive of Archer-Daniels-Midland Company (“ADM”), alleging that as CFO of a critical ADM business segment, Nutrition, and then as ADM’s CFO, Luthar directed improper adjustments to shift operating profit to Nutrition from ADM’s other business segments so that Nutrition would meet the annual operating profit targets that ADM had touted to the investing public.The SEC’s complaint alleges that Luthar and other ADM executives portrayed the Nutrition segment as ADM’s engine for future growth and represented to investors that Nutrition’s operating profit was projected to grow by 15% to 20% per year. When Nutrition was falling short of its operating profit targets for fiscal years 2021 and 2022, Luthar allegedly directed “adjustments” to Nutrition’s transactions with other ADM business segments. According to the complaint, the adjustments included retroactive rebates and price changes that were not customarily available to ADM’s third-party customers and that were essentially one-sided transfers of operating profit to Nutrition, with the goal of making it appear that Nutrition was meeting its performance projections. The adjustments allegedly rendered the disclosure in ADM’s annual and quarterly reports about how it priced intersegment transactions false and misleading, as they resulted in transactions inconsistent with ADM’s representation that intersegment transactions were recorded at amounts “approximating market.” Because of the fraudulent adjustments that Luthar engineered, ADM’s fiscal year 2021 and 2022 periodic reports materially overstated Nutrition’s operating profit and operating profit growth, as alleged in the complaint.The complaint, filed in the U.S. District Court for the Northern District of Illinois, charges Luthar with violating the antifraud provisions of Section 17(a) of the Securities Act of 1933 and Section 10(b) of the Securities Exchange Act of 1934 and Rules 10b-5 and 13a-14 thereunder, aiding and abetting ADM’s violations of the antifraud, reporting, books and records, and internal accounting control provisions of the Exchange Act, and failing to reimburse ADM for certain executive compensation as required by Section 304 of the Sarbanes-Oxley Act of 2002. The complaint seeks permanent injunctions, an officer and director bar, disgorgement of ill-gotten gains with prejudgment interest, civil penalties, and reimbursement of certain executive compensation to ADM pursuant to Section 304 of the Sarbanes-Oxley Act.The SEC’s investigation was conducted by Arefa Patel and Kathleen Sweeney of the Chicago Regional Office, under the supervision of Steven Klawans, Ann Tushaus, and Paul Montoya, and was assisted by Ian Rupell of the Enforcement Office of the Chief Accountant, under the supervision of Ryan Wolfe. The litigation will be led by Tim Leiman, Ashley Dalmau-Holmes, and Timothy Stockwell, under the supervision of Ben Hanauer.