Milnor Law PLLC

Milnor Law PLLC · Arlington, Virginia

Discreet, candid counsel for complex securities and enforcement matters.

A boutique securities and enforcement practice led by a former senior attorney at the U.S. Securities and Exchange Commission. Senior judgment, delivered directly.

Principal
Christina Milnor, Former Assistant Secretary, U.S. SEC
Admitted
Virginia · District of Columbia
Focus
SEC and SRO enforcement · Whistleblower representation · Capital raising
10+Years inside the U.S. Securities and Exchange Commission
4SEC offices held, including Assistant Secretary
2Bar admissions, Virginia and DC
1Senior attorney on every matter, start to finish

Substantive judgment in a focused set of securities practice areas. Senior SEC experience, brought to bear on your most sensitive matters.

Christina provides strategic and advisory counsel and drafts the documents that go to regulators and counterparties outside of litigation. She represents clients in FINRA arbitrations. Matters outside the firm's focus are referred when a sensible referral exists.

  • SEC Enforcement Defense

    Subpoena response, Wells notices, on-the-record interviews, settlement negotiation, and disgorgement defense for individuals and entities under Commission investigation.

    Read more →SEC Enforcement Defense
  • Whistleblower Representation

    Form TCR filings, Dodd-Frank protections, anonymous submissions, and award applications — informed by years inside the SEC's Office of the Whistleblower.

    Read more →Whistleblower Representation
  • Securities Compliance

    Compliance program design, examination preparation, and regulatory risk assessment for registered investment advisers, broker-dealers, and fund managers.

    Read more →Securities Compliance
  • Internal Investigations

    Counsel to boards and audit committees on anonymous tips, accounting issues, FCPA flags, and whistleblower complaints — with the regulator-side perspective those reviews require.

    Read more →Internal Investigations
  • Broker-Dealer & Investment Adviser

    FINRA, NYSE, and NASDAQ enforcement defense and disciplinary proceedings. Compliance counsel for RIAs, broker-dealers, and fund complexes.

    Read more →Broker-Dealer & Investment Adviser
  • Comment Letters

    Substantive comment letters to the SEC, FINRA, NYSE, and NASDAQ on proposed rulemakings — a high-value, low-volume niche where senior agency experience materially changes the work.

    Read more →Comment Letters
  • Capital Raising & PPMs

    Regulation D and exempt offerings. Private placement memoranda drafted to withstand later scrutiny — because the nature of the offering, not its size, determines the legal obligations.

    Read more →Capital Raising & PPMs
  • Representation in FINRA Arbitrations

    FINRA Dispute Resolution is a principal forum for securities-industry disputes, both between customers and member firms and among firms and their associated persons.

    Read more →Representation in FINRA Arbitrations
  • Securities Fraud Defense

    Defense of insider trading, market manipulation, and accounting fraud matters — in parallel SEC, DOJ, and SRO postures.

    Read more →Securities Fraud Defense
  • Referral & Local Counsel

    Co-counsel and local counsel arrangements with attorneys whose firms have conflicts, capacity constraints, or no securities depth.

    Read more →Referral & Local Counsel
  • Discuss your matter

    These matters often cross practice lines. The firm will tell you plainly whether it can help.

    After a conflict check, the firm usually schedules a call within forty-eight hours.

Founded
2025
Office
Arlington, VA
Member
Virginia State Bar (since 2009) · DC Bar (since 2010)

About

More than a decade inside the U.S. Securities and Exchange Commission.

Christina Milnor founded Milnor Law PLLC after rising to Assistant Secretary in the SEC’s Office of the Secretary, with prior senior SEC roles in its Office of the General Counsel, the Division of Enforcement (and specifically the Division’s Office of the Whistleblower), and the Office of Administrative Law Judges.

Senior judgment, grounded in more than a decade inside the SEC.

  • 2013–2024

    U.S. Securities and Exchange Commission

    • Assistant Secretary
    • Senior Counsel, Office of the General Counsel (Adjudications)
    • Senior Counsel, Division of Enforcement (Office of the Whistleblower)
    • Office of Administrative Law Judges
  • 2010–2013WilmerHale, Investigations and Criminal Litigation
  • 2009J.D., University of Virginia School of Law
  • 2007Summer Intern (1L), Hon. Colleen McMahon, U.S. District Court for the Southern District of New York
  • 2006A.B., Government, Harvard College, Cum Laude
Read the full bio

A deliberate path from inquiry to engaged counsel.

The firm declines engagements that fall outside its core areas of practice, and refers them out when a sensible referral exists. The attorney on the call is the attorney on the matter.

  1. 01Step

    Outline the matter

    Send a short email describing the matter and the timing.

  2. 02Step

    Conflict check & call

    After a conflict check, the firm usually schedules a call within forty-eight hours. Confidentiality applies from the first conversation.

  3. 03Step

    Engagement letter

    A written engagement letter sets scope, fees, and responsibilities. No attorney-client relationship exists before it is signed.

  4. 04Step

    Direct senior counsel

    The same attorney through every meeting, draft, submission, and call, not a partner introduction handed off to associates. That's the Milnor Law difference, and why Christina founded this firm.

Real legal analysis.

Notes, explainers, and short essays on enforcement, whistleblower procedure, and capital raising. Clear, practical analysis written to inform real decisions.

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

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

Straight talk and candid answers.

The questions below come up most often in initial conversations. See the dedicated FAQ page for additional details. The answers provided are not legal advice.

Do I need a private placement memorandum for a small Regulation D raise?

The legal obligations attached to a private securities offering are determined by the nature of the offering — the type of investor solicited, the exemption relied on, the manner of solicitation — not by the dollar amount raised. Many founders are surprised to learn that a small raise can carry the same disclosure obligations as a much larger one.

Whether a PPM is technically required and whether one should be prepared are separate questions. Both are worth answering deliberately.

What is a Wells notice and how should I respond?

A Wells notice is a letter from SEC enforcement staff advising a person that the staff intends to recommend that the Commission authorize an enforcement action. It is not a charge. It is an opportunity to respond — a Wells submission — before the Commission votes on whether to authorize a case.

The submission is the single highest-leverage moment in an SEC investigation. It should be written with a clear theory of why charges are wrong on the facts, the law, or the public interest, and it should be paced to the staff's timeline, not the client's.

What does engagement with the firm typically look like?

Initial conversations are brief and confidential, subject to a conflict check. The firm declines engagements that fall outside its core competencies, and refers them out when a sensible referral exists.

Because the firm is solo by design, the attorney on the call is the attorney on the matter. There is no associate layer to which the work will be handed.

What jurisdictions does the firm cover?

Christina Milnor is admitted in Virginia and the District of Columbia. Federal regulatory matters, including SEC and SRO proceedings, are handled nationally, subject to pro hac vice admission or local counsel arrangements where required.

Can I file a Form TCR anonymously?

Yes. Under Rule 21F of the Securities Exchange Act, an individual may submit a Form TCR anonymously, provided the submission is made through counsel and counsel verifies the whistleblower's identity to the Commission at the time any award is claimed.

Anonymity is not absolute. There are circumstances — including award claims and certain enforcement contexts — in which identity may need to be confirmed.

All frequently asked questions

Get in touch

A short note, and the firm will follow up.

Complete the form below to begin. The firm runs a conflict check first, then follows up by phone or email, typically within two business days, if it may be able to help.

Request a Consultation

Briefly describe the matter and your timing. We can discuss specifics by phone.

Office

Milnor Law PLLC
3101 Wilson Blvd #545
Arlington, VA 22201
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