SEC Investigation Updates: September 18, 2025
Updates on SEC investigative activity - Ten (10) companies
All-access clients are welcome to contact us anytime to learn more.
Today’s report -
AGCO Corporation - AGCO
Alnylam Pharmaceuticals, Inc. - ALNY
Chevron Corporation - CVX
Crimson Wine Group Ltd - CWGL
Eli Lilly & Company - LLY
JAKKS Pacific, Inc. - JAKK
MACOM Technology Solutions - MTSI
TEVA Pharmaceutical Industries Ltd. - TEVA
TransUnion - TRU
Zscaler, Inc. - ZS
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COMPANY COMMENTS
AGCO Corporation – AGCO
Removed from Watch List.
Latest signal, dated 30-May-2025, suggested an SEC probe was ongoing. An appeal response dated 05-Sep-2025 now suggests SEC investigative activity involving this company is over. Cyber incident in May-2022 had sizable impact across the company’s operations. Cyber-related probes are getting cleared quickly now under Trump 2.0.
Alnylam Pharmaceuticals, Inc. – ALNY
Removed from Watch List.
Latest signal, dated 16-Apr-2025, suggested an SEC probe was ongoing. However, as of 30-Jul-2025, our work concludes ongoing SEC enforcement proceedings do not appear to directly pertain to Alnylam's conduct, transactions, and/or disclosures. We learned Alnylam was involved in a sweeping SEC investigation into employment and separation agreements. Alnylam’s involvement ended in May-2025. We also know the Audit Committee Chair left abruptly, per the 8-K filed 28-Sep-2023. No reason given at the time.
Chevron Corporation – CVX
New Warning.
Added to DI Watch List. Early signal of an undisclosed SEC investigation first received on 14-Apr-2025, later confirmed as an ongoing SEC investigation on 30-Jul-2025. This is a change from 15-Jul-2024, when our work found no signs of SEC investigative activity. Lots of FCPA activity in Chevron’s history.
Disclosure: John P. Gavin, the owner of Disclosure Insight, owns shares of Chevron in a personal account.
Crimson Wine Group Ltd – CWGL
Early Signal Not Confirmed as an Ongoing Investigation
We received an early signal of an undisclosed SEC investigation at Crimson Wine Group on 16-Apr-2025. However, as of 30-Jul-2025, our work concludes ongoing SEC enforcement proceedings do not appear to directly pertain to this company’s conduct, transactions, and/or disclosures.
In Jul-2024, Crimson disclosed a cyber intrusion which likely triggered an SEC investigation now ended. Cyber-related probes are getting cleared quickly now under Trump 2.0.
Eli Lilly & Company – LLY
Removed from Watch List.
Latest signal, dated 13-May-2025, suggested an SEC probe was ongoing. An appeal response, dated 02-Sep-2025, now suggests SEC investigative activity involving this company is over. In Jun-2024, LLY said the CFO was leaving for another opportunity, effective 09-Sep-2024. The timing is notable given we got the early signal in Jul-2024.
JAKKS Pacific, Inc. – JAKK
Early Signal Not Confirmed as an Ongoing Investigation
We received an early signal of an undisclosed SEC investigation at JAKKS on 12-May-2025. However, as of 02-Sep-2025, our work concluded ongoing SEC enforcement proceedings do not appear to directly pertain to this company’s conduct, transactions, and/or disclosures.
In Dec-2022, JAKKS disclosed a cyber intrusion which likely triggered an SEC investigation now ended. Cyber-related probes are getting cleared quickly now under Trump 2.0.
MACOM Technology Solutions – MTSI
Early Signal Not Confirmed as an Ongoing Investigation
We received an early signal of an undisclosed SEC investigation at MACOM on 08-May-2025. However, as of 02-Sep-2025, our work concluded ongoing SEC enforcement proceedings do not appear to directly pertain to this company’s conduct, transactions, and/or disclosures. We know nothing further about the ongoing proceedings.
TEVA Pharmaceutical Industries Ltd. – TEVA
Warning Reiterated
Maintained on DI Watch List. Undisclosed SEC investigation now confirmed as ongoing two times since 06-Jun-2024, most recently on 30-Jul-2025. Internal controls problem disclosed for the first time in the 10-K filed on 12-Feb-2024.
TransUnion – TRU
New Warning.
Added to DI Watch List. Early signal of an undisclosed SEC investigation first received on 16-Apr-2025, later confirmed as an ongoing SEC investigation on 30-Jul-2025. The investigation could easily be related to a restatement in Jan-2024; after which internal controls were still ineffective as of the Oct-2024 10-Q. They were effective again with the 10-K filed on 13-Feb-2025. Cyber incident, Mar-2022.
Zscaler, Inc. – ZS
Early Signal Not Confirmed as an Ongoing Investigation
We received an early signal of an undisclosed SEC investigation at Zscaler on 28-May-2025. However, as of 02-Sep-2025, our work concluded ongoing SEC enforcement proceedings do not appear to directly pertain to this company’s conduct, transactions, and/or disclosures. We know nothing further about the ongoing proceedings.
-- John P. Gavin, CFA, NACD.DC
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.
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Good to see AGCO cleared from the SEC watch list after that May 2022 cyber incidnt. The fact that the investigation is oficially closed as of September 5th should remove some overhang that might have been weighing on the stock. It's interesting that you note cyber-related probes are getting cleared more quickly under the current administration. For AGCO shareholders, having this regulatory uncertainty resolved is helpful, especially given how much operational disruption that cyber incident caused across their operations back in 2022. The timing also aligns well with them being at what many analysts think is the bottom of the ag equipement cycle.