On December 20, 2013, the SEC filed a complaint alleging violations of the Foreign Corrupt Practices Act by Archer-Daniels-Midland Company. The SEC is alleging that the company's subsidiaries paid: "approximately $22 million to two third-party vendors so that they could pass on nearly all that money as bribes to Ukrainian government officials to obtain over $100 million in accumulated value added tax refunds."

On December 20, 2013, the SEC announced that it charged global food processor Archer-Daniels-Midland Company ("ADM") for failing to prevent illicit payments made by foreign subsidiaries to Ukrainian government officials in violation of the Foreign Corrupt Practices Act. According to the SEC's complaint filed in U.S. District Court for the Central District of Illinois, from 2002 to 2008, ADM's subsidiaries in Germany and Ukraine paid $21 million in bribes through intermediaries to secure the release of value-added tax refunds. The payments were then concealed by improperly recording the transactions in accounting records as insurance premiums and other purported business expenses. ADM consented to the entry of a final judgment, which remains subject to court approval. In a parallel action, the U.S. Department of Justice entered into a non-prosecution agreement with ADM and settled criminal charges against an ADM subsidiary, which agreed to pay $17.8 million in criminal fines.

On January 14, 2014, Federal District Judge Harold A. Baker entered final judgment against Archer-Daniels-Midland Company pursuant to the consent of Archer-Daniels-Midland Company. Among other things, the Court Order provided that "Defendant shall comply with all the agreements set forth [in its Consent], including, but not limited to, the requirement to concurrently provide to the Commission any reports it provides to the Department of Justice, pursuant to the obligations contained in the Defendant's Non-Prosecution Agreement with the United States Department of Justice...."