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# SEC Investigation Updates: October 29, 2025
- URL: https://www.disclosureinsight.com/sec-investigation-updates-october-355-2/
- Published: 2025-10-28T23:57:21.000Z
- Updated: 2026-07-03T18:01:43.000Z
- Description: Updates on SEC investigative activity - Seven (7) companies
- Author: John P. Gavin, CFA
- Tags: Newsletter, #Migrated-1783101638980, #Import 2026-07-03 14:01

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[SEC Investigation Updates - October 29, 2025SEC Investigation Updates - October 29, 2025305 KBdownload-circle](https://www.disclosureinsight.com/api/v1/file/06967e43-51fe-437c-bd81-82ea3dd3f271.pdf "Download")

## 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.

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