Christina K. McGlosson, Special Counsel: Dodd-Frank Whistleblower Practice, represents clients in the presentation and prosecution of fraud claims before the U.S. Securities and Exchange Commission (SEC), U.S. Commodity Futures Trading Commission (CFTC), Internal Revenue Service, and other government agencies.
Before joining Cohen Milstein, Christina served as the Acting Director of the Whistleblower Office (WBO) in the Division of Enforcement at the U.S. Commodity Futures Trading Commission. She directed and administered the CFTC’s Whistleblower Program, created under Section 748 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank). Under her leadership, the CFTC awarded four deserving whistleblowers $24 million in the last two weeks of fiscal year 2023 and $18 million in the first two weeks of fiscal year 2024.
She simplified, streamlined, and accelerated processes to move award recommendations forward with less delay. She advised commissioners on policy matters relating to the Whistleblower Program and provided technical assistance in the continued development and implementation of major CFTC and Division of Enforcement initiatives relating to whistleblowers.
Christina is a recognized Dodd-Frank and federal securities law expert. She is one of only two attorneys who have worked in both the SEC’s Office of the Whistleblower and the CFTC’s Whistleblower Office. She has been quoted numerous times in the press, including the Wall Street Journal, Reuters, Law360, among others, and is the go-to speaker on regulatory Dodd-Frank Whistleblower programs and government investigations.
Prior to returning to the CFTC, Christina was a Director of Compliance, led the federal securities law practice, and advised the derivatives and futures markets practice at Promontory Financial Group, a business unit of IBM Consulting. Her practice included overseeing and advising clients on all aspects of regulatory, compliance and risk-mitigation. She advised asset managers, broker-dealers, FinTechs, banks, other regulators, private and public companies, private equity funds, and hedge funds on SEC and CFTC enforcement, SEC examinations, and whistleblower compliance.
Christina previously served as the Deputy Director in the Division of Enforcement’s WBO at the CFTC. She supervised the attorneys in the WBO, reviewed all whistleblower award determinations and memoranda prior to Commission circulation, and directed the whistleblower claims review and award processing procedures.
For over eighteen years, Christina served in a variety of positions in the SEC’s Division of Enforcement, including Senior Counsel to the Director of Enforcement, and Senior Adviser to the Chief of the Office of Market Intelligence, where she implemented Congress’s directives post-Madoff and led the team to create the SEC’s Office of the Whistleblower. She also served as Senior Special Counsel to the SEC’s Chief Economist in the Division of Economic and Risk Analysis, providing guidance and counsel on a wide variety of Commission legal and policy matters and their intersection with SEC economic policy.
Prior to her leadership positions at the SEC, Christina investigated and litigated complex financial fraud cases involving Fortune 100 companies. She also successfully investigated, brought before the Commission, and litigated in U.S. District Court, insider trading, executive compensation, and microcap fraud cases. She spent time in Basel, Switzerland, working with the Financial Stability Board and the Bank of International Settlements as a member of the United States delegation.
Christina received her J.D. cum laude, from The Catholic University of America’s Columbus School of Law, where she received a certification in Federal Securities Law. She holds an A.B. in Government and Economics from Georgetown University, where she graduated with First Honors.
Christina’s practice is limited to matters and proceedings before federal courts and agencies.
- New York
- Virginia
- Catholic University of America-Columbus School of Law, J.D., cum laude
- Georgetown University, A.B., Government and Economics, First Honors
September 12, 2024
FinCEN Publishes Final AML/CFT Rule: A Whistleblower Call to Action
On September 4, 2024, the Financial Crimes Enforcement Network published its final rule in accordance with the Bank Secrecy Act that imposes minimum standards for establishing anti-money laundering/ countering the financing of terrorism programs.
Articles | Cohen Milstein
August 9, 2024
SEC v. Ripple: A Whistleblower Call to Action
On August 7, 2024, the U.S. Securities and Exchange Commission secured a ruling in a groundbreaking case, SEC v. Ripple Labs Inc., et al., that certain cryptocurrency and digital asset token transactions must be registered with the SEC. Failure to register such transactions under Sections 5(a) and 5(c) of the Securities Act of 1933 will result in enforcement actions and penalties.
Articles | Cohen Milstein
August 1, 2024
CFTC Takes Public Stand on Whistleblower Carveouts in Employee Agreements
On June 17, 2024, the U.S. Commodity Futures Trading Commission’s Division of Enforcement (CFTC) issued an order in an Enforcement action that simultaneously settled charges against Trafigura Trading LLC for several CFTC violations, including, significantly, not disclosing whistleblower carveout language in its employee agreements in violation of Regulation 165.19(b). By not including this carveout language, […]
Articles | Medium
July 23, 2024
CFTC Whistleblower Program at Risk Without Lawmakers’ Help
A stopgap measure that kept a key US financial regulator’s whistleblower office afloat during a funding crisis is set to expire unless lawmakers revive it, putting the cash-for-tips program in jeopardy. The Commodity Futures Trading Commission, under a program established by Congress after the 2008 financial crisis, offers awards to whistleblowers whose tips lead to […]
In the News | Bloomberg Law
July 1, 2024
Blowing the Whistle on Financial Fraud, a Q&A
We caught up with Christina McGlosson for a discussion about current SEC/CFTC Enforcement Division priorities, the types of information whistleblowers can provide to help these enforcement divisions open investigations and combat fraud, and more. Christina recently joined our Whistleblower practice as our expert in the Dodd Frank whistleblower provisions. She previously served as the former […]
Articles | Cohen Milstein
June 4, 2024
Blow the Whistle on Financial Institutions Not in Compliance with the Amended Rules Governing Treatment of Consumers’ Nonpublic Personal Information
The SEC has strengthened Customer Data Protection to address the expanded use of technology and risks by financial institutions. On May 16, 2024, the U.S. Securities and Exchange Commission (SEC) announced the adoption of amendments to Regulation S-P: Privacy of Consumer Financial Information and Safeguarding Customer Information (the “Amendments”), which govern the treatment of nonpublic […]
Articles | Medium
May 28, 2024
Blow the Whistle on Investment Adviser Marketing Rule Deficiencies
The SEC’s Recent Risk Alert Highlights the Potential for Fraud On April 18, 2024, the U.S. Securities and Exchange Commission (SEC) issued a Risk Alert summarizing the staff’s preliminary observations involving compliance by registered investment advisers with Rule 206(4)-1 of the Investment Advisers Act of 1940, as amended (the Marketing Rule). The Risk Alert addresses the “general […]
Articles | Medium
May 10, 2024
GC Cheat Sheet: The Hottest Corporate News Of The Week
Help for lawyers in dealing with legal data challenges has come, thanks to corporate and law firm leaders who founded a new industry framework called Legal Data Intelligence. And at least one U.S. senator is questioning Amazon and Walmart’s use of new tech to create “dynamic pricing” that may harm consumers. These are some of […]
In the News | Law360
May 10, 2024
Whistleblowing Work Is Fueling Law Firm Growth
Over her two decades with federal financial regulatory agencies, Christina K. McGlosson saw increased appreciation of the value of information provided by whistleblowers. Today, there is wide recognition of how an insider’s expertise can help build a case and fight fraud, she recently told Law360 Pulse. As a result, she said, “everyone wants those whistleblowers. Everyone […]
In the News | Law360
May 9, 2024
More Regulators Eye Whistleblower Award Programs Hoping for Insider Tips
More than a decade after a global financial crisis and the Bernie Madoff Ponzi scheme led to the establishment of two whistleblower award programs in the U.S., more U.S. regulators and other agencies worldwide are seeing the benefits of paying individuals for helpful information, signaling a change in momentum on the debate. Regulators both inside and outside the […]
In the News | Wall Street Journal
April 2, 2024
Cohen Milstein Hires CFTC Whistleblower Office Leader In DC
Cohen Milstein Sellers & Toll PLLC has hired the acting director of the Commodity Futures Trading Commission’s whistleblower office, who brings more than two decades of experience working in related roles in public service to the platform. Christina K. McGlosson joins Cohen Milstein as special counsel: Dodd-Frank whistleblower practice, after spending 10 months as acting […]
In the News | Law360
April 1, 2024
Cohen Milstein Sellers & Toll Grows Its Whistleblower Practice
Cohen Milstein announced today that Christina K. McGlosson has joined as Special Counsel: Dodd-Frank Whistleblower Practice in the firm’s Whistleblower practice.
Press Releases | Cohen Milstein