The former Dell employees had received Wells notices that indicate Securities and Exchange Commission staff had made a preliminary decision to recommend the SEC begin a civil or administrative action against them, Dell said in a regulatory filing late on Thursday.
A Wells notice signals that a civil charge may be imminent and gives the receiver a chance to respond.
Dell said the notices were related to a previously reported SEC inquiry, started in August 2005, into the accounting and financial reporting of the world's third-largest seller of personal computers for periods beginning in 2001.
It is possible that other individuals have received or will receive such notices, Dell said in the statement.
In 2006, Dell disclosed that the U.S. Attorney for the Southern District of New York had subpoenaed documents related to the company's financial reporting dating back to 2002.
At the time, analysts criticized Dell's handling of the probe, which caused the company to delay filing some quarterly financial reports.
The company said on Thursday that it was continuing to cooperate with the investigation and was in preliminary talks with the SEC about a potential settlement.
Dell believes that any resolution would likely include monetary penalties, which cannot be quantified at this time, the company said.
Dell shares, which had closed 0.2 percent higher at $15.05, were not active in late afternoon trading on Nasdaq, when the Wells Notices were reported by the company.
(Reporting by Braden Reddall and Alexandria Sage; Editing by Bernard Orr, Leslie Gevirtz)