Christina Zaroulis Milnor

Attorney
Christina Zaroulis Milnor

Christina Zaroulis Milnor has a distinguished career practicing securities and white collar law and conducting investigations. She spent over a decade as a senior attorney at the U.S. Securities and Exchange Commission, serving there as Assistant Secretary, in its General Counsel’s office, and in its Division of Enforcement. She began working on the SEC whistleblower program soon after the program’s foundation, advising the Commission on applicants’ eligibility for whistleblower awards.

Christina Zaroulis Milnor brings more than a decade of in-house experience as senior staff at the U.S. Securities and Exchange Commission to her private practice. She is a passionate advocate to financial-industry clients in high-stakes investigative and litigation matters. Her years of experience at the SEC provide her with an unparalleled, in-depth understanding of how the enforcement process works up until and through litigation and how whistleblower information becomes a valuable asset. Christina’s goal is to use this inside perspective to help smaller financial institutions, and individuals, navigate government and quasi-government enforcement and regulatory bodies to achieve their desired outcomes. She most enjoys working to assist whistleblowers in participating in whistleblower reporting programs at the SEC, CFTC, FinCEN, and Department of Justice.

Representative matters

Christina has experience with a wide variety of litigative matters, but most prominently in securities and white collar spaces. Christina spent fourteen months as Assistant Secretary at the U.S. Securities and Exchange Commission, reporting to its Secretary, where she had primary responsibility for the Office of the Secretary’s portfolio of issues and matters relating to enforcement, fair fund, and administrative proceedings. She was involved in assessing all enforcement recommendations’ readiness for a vote by the Commission and central to assisting senior prosecutorial staff with finalizing and making effective administrative enforcement actions. 

Prior to joining the staff of the SEC, Christina spent four years working in the white-collar and investigations practice group of a globally operating, corporate law firm.

Christina counsels as to:

  • Broker-dealer regulation and compliance.
  • Investment-adviser regulation and compliance.
  • Auditor and accountant regulation and compliance.
  • Federal agency administrative proceedings.
  • The U.S. Foreign Corrupt Practices Act and the UK Bribery Act.
  • Anti-corruption-specific deal due diligence.
  • Sanctions compliance.
  • Anti-money laundering compliance.
  • FINRA, NYSE, other SRO, and PCAOB rules and enforcement.

Christina has experience in whistleblower law and bounty programs, having spent three years working in the SEC's Division of Enforcement, Office of the Whistleblower. There, she engaged with investigative and trial staff about use of whistleblower information and made recommendations to the Commission about whistleblower award eligibility and awards amounts, and coordinated with SEC senior staff on legal interpretation of provisions of the new Regulation 21F-17.

Christina was involved in constitutional challenges to the SEC's use of administrative hearings and adjudication to resolve securities enforcement issues. She is eager to lend her experience in administrative law to assist clients with navigating new and emerging legal precedent impacting agency powers.