SEC Investigation Updates: October 29, 2025
Updates on SEC investigative activity - Seven (7) companies
All-access clients are welcome to contact us anytime to learn more.
Click on the PDF here to access today’s report or read full text below
Company Comments
AstraZeneca PLC – AZN
Warning Reiterated
Maintained on DI Watch List. We’ve been tracking an undisclosed SEC investigation here since Dec-2023, with enforcement proceedings again confirmed as ongoing on 02-Sep-2025. AZN appears to be a FCPA frequent flyer, going back to 2010. No clear disclosure of SEC investigative activity found since the 20-F filed on 21-Feb-2023, at which time AZN referred to having fully resolved a FCPA investigation with the SEC in Jul-2020.
DI’s Take: As the Trump 47 SEC has reduced its focus on FCPA cases, this suggests AZN may be dealing with something unrelated.
Bank of America Corporation – BAC
New Warning
Added to Watch List. Early signal of an undisclosed SEC investigation first received on 23-Jul-2025, later confirmed as an ongoing SEC investigation on 16-Sep-2025. A separate, undisclosed investigation ended in Mar-2025. We know nothing further on that matter.
Citigroup, Inc. – C
New Warning
Added to Watch List. Early signal of an undisclosed SEC investigation first received on 12-Jun-2025, later confirmed as an ongoing SEC investigation on 08-Sep-2025. We have documents from a 2024 SEC investigation into SPAC underwriters.
KeyCorp – KEY
Disclosed SEC Investigation Ends
New data confirms KeyCorp’s claims an SEC probe into off-channel communications is over, as cited below. However, as of 08-Sep-2025, the company remains in a post-settlement compliance period which could go against them if they violate a related settlement agreement. No other signs of ongoing SEC investigative activity found.
Per the KeyCorp 10-K filed on 22-Feb-2024:
For example, on February 9, 2024, affiliates of Key entered into a settlement agreement with the SEC’s Division of Enforcement to resolve an investigation of the affiliates’ compliance with records preservation requirements related to business communications sent over off-channel electronic messaging platforms.
Novo Nordisk A/S – NVO
Removed from Watch List.
Undisclosed SEC Investigation ends. Recently released documents tell us it was a FCPA probe, from Dec-2023 to Aug-2025, largely focused on Saudi Arabia. We were tracking this since Jul-2024.
We find no signs of a post-settlement compliance period, which is otherwise common in FCPA matters. This is consistent with the Trump 47 SEC having recently lost interest in pursuing FCPA investigations.
Tesla, Inc. – TSLA
Warning Reiterated
We now know Tesla had not one, but two undisclosed SEC investigations; one recently ended. The other one was recently confirmed as ongoing, as of 26-Sep-2025.
An SEC investigation into Musk’s claims about Tesla autopilot, as first reported by Reuters in May-2024, could be the one that closed. We’re trying to get the related records. We have no idea what the other open investigation is about.
Twitter, Inc. – TWTR
Removed from Watch List.
Latest signal, dated 15-May-2025, suggested an SEC probe was ongoing. However, an appeal response, dated 02-Sep-2025, now suggests SEC investigative activity involving the former Twitter is over.
The SEC not once, not twice even – but three times – asked about Twitter’s user metrics in three different investigations since late 2015. It also raised questions about user metrics in comment letters sent to the company three times between 2013-2017.
Our work confirmed ongoing, and undisclosed SEC investigative activity seven times since May-2019. We will not be surprised if we later learn this now-closed investigation was also about user metrics.
-- Disclosure Insight®
This report does not constitute investment advice or an offering to buy, sell or recommend any securities. The information herein is distributed purely as a newsworthy event. All information contained herein is derived from publicly-available disclosures as made by the companies cited in this report, and/or documents obtained from the U.S. Securities and Exchange Commission.
Our Terms of Service, relevant disclosures, and other legal notices can be found here.