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Enforcement
SEC investigations vs. charges.
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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.
SEC investigations vs. charges.
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Insider trading surveillance has gone AI. Here's what that means.
The SEC now pairs a market-wide data feed — the Consolidated Audit Trail — with an agency-wide push to deploy artificial intelligence in examinations and enforcement. Detection is faster and broader than the pattern-matching systems of the last decade. But by the Chairman's own account, an algorithm cannot be the sole basis of an enforcement action. The gap between a flag and a case is where defense happens.
Enforcement2 min read
What Independent Agency Decisions Feel Like Inside the Room
Much of the discussion around the Supreme Court's recent decision in Trump v. Slaughter has focused on constitutional doctrine. I keep thinking about the conference room. Institutional change often appears first in meeting rooms and deliberations, before it appears in rules, orders, or court opinions.
Enforcement2 min read
Fraud cases and reduced fanfare: my take on what the drop in SEC press releases reveals about the current SEC's enforcement approach.
Since Inauguration Day 2025, SEC enforcement press releases have dropped sharply. The cases brought are significant, but the SEC is choosing a different way of talking, or not talking, about its work. What that means for practitioners.
Enforcement6 min read