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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