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United States securities and exchange commission logo





                            May 22, 2024

       Ismael Roig
       Chief Financial Officer
       Archer-Daniels-Midland Co
       77 West Wacker Drive
       Suite 4600
       Chicago, IL 60601

                                                        Re:
Archer-Daniels-Midland Co
                                                            Form 10-K for the
Year Ended December 31, 2023
                                                            Form 8-K Filed
March 12, 2024
                                                            File No. 001-00044

       Dear Ismael Roig:

                                                        We have reviewed your
filing and have the following comments.

              Please respond to this letter within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe a
       comment applies to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to this letter, we may have additional comments.

       Form 10-K for the Year Ended December 31, 2023

       Non-GAAP Financial Measures, page 42

   1.                                                   Please quantify the
components of the adjustment    asset impairment, restructuring and net
                                                        settlement
contingencies    and describe the nature of each material component. For each
                                                        material component as
well as the adjustment for "railroad maintenance", please tell us
                                                        your consideration of
Item 10(e)(1)(ii)(B) of Regulation S-K and Question 100.01 of the
                                                        SEC's Compliance &
Disclosure Interpretations on Non-GAAP Financial Measures in
                                                        determining the costs
do not represent normal, recurring operating costs.
   2.                                                   We note your
presentation of segment operating profit, adjusted segment operating profit
                                                        and segment adjusted
EBITDA, which all appear to be non-GAAP measures. Please tell
                                                        us how you determined
these measures comply with Rule 100(b) of Regulation G. We
                                                        note that the measures
remove corporate overhead and other items, which appear to be
                                                        normal, recurring, cash
operating expenses necessary to operate your business. Refer to
                                                        Question 100.01 of the
SEC's Non-GAAP Compliance and Disclosure Interpretations.
 Ismael Roig
Archer-Daniels-Midland Co
May 22, 2024
Page 2
         Please revise future filings to eliminate segment total measures or
tell us how you intend
         to revise them to comply with Regulation G and Item 10(e) of
Regulation S-K. This
         comment also applies to your earnings releases filed on Form 8-K.
Critical Accounting Policies and Estimates
Goodwill, page 54

3.       Your disclosures indicate that you performed a quantitative goodwill
impairment analysis
         on two reporting units. Please identify for us the goodwill reporting
unit beyond Animal
         Nutrition for which you performed the two-step quantitative assessment
and quantify the
         amount of goodwill allocated to this reporting unit. Additionally, we
note that you used
         both income and market approaches in determining the fair value of
your reporting
         units. Tell us the relative weighting used for each approach and how
you determined such
         weighting was appropriate. Further, tell us and revise future
disclosures to explain how
         you performed the market approach, including significant estimates and
assumptions used.
Notes to the Consolidated Financial Statements
Note 17. Segment and Geographical Information, page 106

4.       We note you have disclosed a correction of certain segment-specific
historical financial
         information. It appears that you are classifying the errors as a
revision rather than a
         restatement. Please explain to us how you determined your disclosure
relating to this
         error is appropriate. As part of your response, address both
quantitative and qualitative
         factors and tell us how your treatment complies with ASC-250-10-50-7.
As part of your
         response, provide us with your materiality analysis prepared in
accordance with SAB
         Topic 1:M and 1:N.
5.       We note your inventory accounting policy disclosure which states that
certain
         merchandisable agricultural commodities inventories, including
inventories acquired
         under deferred pricing contracts, are stated at market value. We
further note from your
         segment disclosures, that intersegment sales have been recorded at
"amounts
         approximating market". Please explain why your intersegment sales
differ from market
         value and how you determine such values.
Form 8-K filed March 12, 2024

Exhibit 99.1, page 1

6.     Your Full-Year 2023 Highlights discloses segment operating profit,
adjusted segment
       operating profit and trailing four-quarter average adjusted return on
invested capital which
FirstName LastNameIsmael Roig
       are all non-GAAP measures. Please disclose the most directly comparable
GAAP
Comapany    NameArcher-Daniels-Midland
       measure                              Co
                 with equal or greater prominence,  whenever you present a
non-GAAP measure.
May 22,Refer
         2024toPage
                 Item210(e)(1)(i)(A) of Regulation S-K.
FirstName LastName
 Ismael Roig
FirstName  LastNameIsmael
Archer-Daniels-Midland Co Roig
Comapany
May        NameArcher-Daniels-Midland Co
     22, 2024
May 22,
Page 3 2024 Page 3
FirstName LastName
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       Please contact Mindy Hooker at 202-551-3732 or Kevin Stertzel at
202-551-3723 if you
have questions regarding comments on the financial statements and related
matters.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of
Manufacturing
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