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.
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
| 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 |
| Techniques |
What was ordered
- Civil penalty
- $20m
- Disgorgement
- —
- Prejudgment interest
- —
- Total relief
- $20m
- Alleged gain
- —
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
Primary documents
Everything on this page derives from the documents below. Where our summary and the primary document disagree, the primary document is right.