Market Manipulation. Search

SEC v. Andeavor LLC (2020)

Settled

Checked against the primary document on October 3, 2026. The library's summary, tags and figures for this record were compared with the regulator's own document by an AI model (Claude) following written instructions, with sampled and disputed records read a second time. No lawyer has reviewed them. A checked record can still contain errors, and checked does not mean endorsed. See how we check records or report a correction.

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In October 2020 the SEC settled with Andeavor LLC, finding it lacked internal accounting controls to ensure share buybacks complied with its policy against repurchasing stock while holding material nonpublic information. It paid a $20 million penalty.

The record

Structured fields for this action, as recorded in our case library.
Agency SEC
Release number 3-20125
Date filed 2020-10-15
Date resolved 2020-10-15
Status settled
Asset class equities
Venue NYSE
Criminal parallel No
Defendants Andeavor LLC (entity)
Techniques

What was ordered

Civil penalty
$20m
Disgorgement
—
Prejudgment interest
—
Total relief
$20m
Alleged gain
—

A dash means the release did not state a figure we could extract, not that the figure is zero. Penalty and disgorgement are stored separately so aggregates across the library do not double-count the same dollars.

What is alleged to have happened

The Securities and Exchange Commission instituted and settled the proceeding on October 15, 2020.

The order finds that Andeavor's board authorised $2 billion of buybacks subject to a policy barring repurchases while in possession of material nonpublic information, but the company had no adequate process to establish what it knew. It bought back stock in early 2018 while merger talks with Marathon were under way. The violation found is of the internal accounting controls provision, Section 13(b)(2)(B).

Andeavor agreed to a $20,000,000 civil penalty. The insider-trading tag was removed because the order charges a controls failure, not trading on inside information.

For the regulator's own account of the facts, read the primary document linked above. This page deliberately summarises the structured record rather than reproducing the release.

Timeline

  1. 2020-10-15 Administrative proceeding instituted (cease-and-desist)

Primary documents

Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.

The linked release is a work of the United States government and is not subject to copyright. Our summary and narrative above are our own writing.

Record added September 10, 2026. submit a correction.