Commodities giant Archer Daniels-Midland Company said this week it has reserved $25 million for a potential FCPA settlement with the DOJ and SEC.

The focus of its investigation that started in 2008 and just ended was the handling of grain and feed exports, ADM said.

The company is now in settlement talks with the DOJ and SEC.

It set aside $25 million to cover ‘the estimate of potential disgorgement, penalties or fines that may be imposed,’ although the final amount could be higher, it said.

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Here’s ADM’s full FCPA disclosure from its From 10-Q filed with the SEC on May 7:

Since August 2008, the Company has been conducting an internal review of its policies, procedures and internal controls pertaining to the adequacy of its anti-corruption compliance program and of certain transactions conducted by the Company and its affiliates and joint ventures, primarily relating to grain and feed exports, that may have violated company policies, the U.S. Foreign Corrupt Practices Act, and other U.S. and foreign laws. The Company initially disclosed this review to the U.S. Department of Justice, the Securities and Exchange Commission, and certain foreign regulators in March 2009 and has subsequently provided periodic updates to the agencies. The Company engaged outside counsel and other advisors to assist in the review of these matters and has implemented, and is continuing to implement, appropriate remedial measures. The Company has recently completed its internal review and has initiated discussions with the Department of Justice and the Securities and Exchange Commission on the resolution of this matter. In connection with this review, government agencies could impose civil penalties or criminal fines and/or order that the Company disgorge any profits derived from any contracts involving inappropriate payments. Included in selling, general, and administrative expenses for the quarter ended March 31, 2013 was a $25 million provision for the estimate of potential disgorgement, penalties or fines that may be imposed by government agencies pertaining to this matter. However, a final agreement has not been reached as of the date of this filing, and therefore the ultimate settlement is uncertain and may exceed $25 million. These events have not had, and are not expected to have, a material impact on the Company’s business or financial condition.

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