In a one-two punch this week, the Securities and Exchange Commission finally showed its cards with regard to the scandal around intersegment sales accounting practices that has hung over Archer-Daniels-Midland for two years. Separately, regulators also filed a lawsuit charging accounting fraud against ex-CFO Vikram Luthar, a holdout who served as ADM CFO from April 2022 to mid-2024. As part of the settlement, ADM agreed to pay a $40 million civil fine without admitting or denying the SEC’s findings. Yesterday’s filings contained some clues as to how the arguments may play out, as well as what the SEC’s enforcement actions may look like in the second Trump administration. Here are five takeaways from this week’s ADM developments: