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The SEC’s newly proposed "Regulation Crypto Assets."
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Christina's Thought Leadership and Written Musings.
Notes, explainers, and short essays, written for readers who already understand the subject and want the next layer of detail.
Also find ample writings on Christina's LinkedIn page.
The SEC’s newly proposed "Regulation Crypto Assets."
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U.S. federal law will pay you to tell the truth. Which agency pays, and how much, depends on the fraud.
Most people picture a single whistleblower award program. In fact, at least five federal programs exist — SEC, CFTC, IRS, FinCEN, and the False Claims Act — each with its own rules on awards, anonymity, and process. Two are paying record sums, one is newly taking shape at FinCEN, and the oldest is facing a constitutional challenge. Here is the plain-English map, and why the differences matter before you come forward.
Compliance2 min read
Most people who raise a concern don't think of themselves as whistleblowers. They think of themselves as reporters.
Most people who raise a concern don't think of themselves as whistleblowers. They think of themselves as reporters, trying to figure out whether something is wrong and how to say so without derailing their careers. What they want is clarity, safety, and confidence. The companies that treat good-faith reports as information rather than threats are the ones that get things right.
Compliance1 min read
Nine justices, one answer: the SEC can recover unlawful profits without proving investor loss.
A unanimous Supreme Court decision in Sripetch v. SEC affirms the SEC's ability to seek disgorgement without proving identifiable investor losses. Sometimes the hardest thing to measure is harm. That doesn't mean the harm isn't real.
Compliance1 min read
Since Digital Realty, the law quietly rewards going to the SEC. Most compliance programs still assume otherwise.
Companies still build their programs around getting employees to raise concerns internally first. But since Digital Realty Trust v. Somers, Dodd-Frank's anti-retaliation protections reach only whistleblowers who report to the SEC, which quietly rewards going external. The report may already sit with a regulator before the company hears a word. The question for compliance leaders is no longer whether an issue goes outside, but how fast they can respond once it surfaces inside.
Compliance1 min read
Binance fired the staff who flagged $1 billion to sanctioned Iranian groups.
Internal investigators reported it through proper channels, exactly what every speak-up policy tells employees to do, and were fired for it. The pattern is painfully familiar, and it's exactly why I do what I do.
Compliance2 min read
Why culture remains the most underestimated source of regulatory risk.
Compliance failures rarely begin with a missing policy. They show up in the leadership huddle where a concern is brushed aside, the closed-door conversation that never makes the record, the quiet decision not to speak up because the personal risk feels higher than the organizational one.
Compliance5 min read