* ADM contacted U.S. government on possible violations
* Company could face civil, criminal penalties -filing
* ADM terminated some employees following internal review
CHICAGO, Nov 6 Archer Daniels Midland Co
, one of the world's top grain traders, is negotiating
with the U.S. government to resolve possible violations of U.S.
foreign bribery laws and could face penalties, according to the
ADM said in a quarterly report filed on Monday that it
"initiated discussions" with the Justice Department and
Securities and Exchange Commission after recently completing an
internal review of questionable transactions relating to grain
and feed exports. The transactions may have violated the U.S.
Foreign Corrupt Practices Act and other U.S. and foreign laws,
according to the company.
The Justice Department was not immediately available to
comment and the SEC declined to comment.
ADM said it began an internal review of the transactions in
August 2008. It voluntarily disclosed the review to the U.S.
government and "certain foreign regulators" in March 2009, and
has provided periodic updates to the agencies, according to the
ADM declined to provide additional details on the possible
violations, but said in a statement that it terminated employees
as a result of the review.
"As soon as we became aware of some questionable
transactions, ADM undertook a comprehensive internal
investigation and retained an independent auditing firm to
conduct its own review," a spokeswoman said in the statement.
ADM could face civil or criminal fines or be forced to give
up any profits "derived from any contracts involving
inappropriate payments," according to the filing.
The company said it had not yet recorded any liability for
any assessments that might be imposed by government agencies
"because the amount cannot be reasonably estimated." It added
that the potential violations were not expected to have a
"material impact" on the business.