Christina's Thought Leadership and Written Musings.

SEC investigations vs. charges.

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.

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.

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.

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.

General solicitation is one of the most overcomplicated ideas in private capital raising. It doesn't have to be.

Founders often assume general solicitation means they can only talk to close friends and family about an offering. The law is both broader and more practical than that. The real question is which activities risk broadly soliciting investors, podcasts, public forums, broadcast appearances, communications that condition investor interest, and most people are better served focusing on a handful of higher-risk areas than memorizing every rule.

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.

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.

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.