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Robert A. Cohen


Robert A. Cohen

White Collar Defense & Investigations
Washington DC

Represents companies, boards and individuals in government investigations. Conducts internal investigations. Held senior roles in the SEC Enforcement Division.

Rob brings 15 years of senior-level experience in the SEC’s Division of Enforcement to his work representing companies, boards and individuals in government investigations, as well as conducting internal investigations.

He represents public companies in SEC investigations concerning disclosures, accounting and internal controls. He is an authority on cryptocurrency enforcement, having served as the first-ever Chief of the SEC’s Crypto Assets and Cyber Unit and led the SEC’s first wave of cases involving digital assets. Rob frequently advises public companies and other clients in responding to and disclosing cybersecurity incidents, including defense of related government investigations.

Rob is “is a terrific litigator and he really digs in to get to the meat of things,” says a source quoted by Chambers FinTech.

When Rob was Co-Chief of the SEC’s Market Abuse Unit, he handled enforcement actions involving insider trading, market structure, manipulation, broker-dealers, ATSs and exchanges.

Experience highlights

SEC Investigations
  • Obtained termination notices without charges in five separate SEC investigations in 15 months (2023-2024)

Rob’s representations include:

  • A Fortune 100 public company, concerning internal controls
  • A large technology public company concerning disclosures
  • A Fortune 500 public company, concerning metric disclosures
  • A hedge fund adviser, concerning fixed income trading
  • A financial institution, concerning off-channel communications
  • A public company, concerning risk disclosures
  • A public company/medical device manufacturer, concerning disclosures
  • An individual, concerning auditing standards
  • Several post-SPAC companies, a post-IPO company, a large underwriter and an investment trust in separate investigations
Other Government and Internal Investigations
  • Multiple broker-dealers and other financial institutions in SEC and FINRA investigations, including involving trading practices, best execution and trade data
  • A data analytics company in a NY Attorney General investigation
  • A China-based retailer in fraud investigations by the SEC and DOJ
  • Multiple public companies in internal investigations, including regarding a subsidiary; material, nonpublic information; and compliance with European financial regulations
Cryptocurrency & Digital Assets
  • A large digital asset financial services firm in SEC, DOJ, and other government investigations
  • Multiple developers of decentralized finance (DeFi) platforms in SEC investigations
  • A cryptocurrency asset manager, a stablecoin issuer, an executive of a blockchain developer and an NFT creator in separate SEC investigations
Data Privacy & Cybersecurity
  • Multiple public companies in responding to the SEC sweep regarding the SolarWinds compromise
  • A Fortune 100 company in an internal investigation regarding a cyber incident
  • Multiple public companies in responding to cybersecurity incidents
  • A private equity firm concerning cybersecurity advice
  • A financial services provider regarding a privacy incident

Earlier, at the SEC, cases that Rob supervised included:

  • Insider trading cases involving hedge funds, a member of Congress, and passing of notes at Grand Central Station
  • Public company accounting and disclosure cases
  • Trading investigations related to order handling, national stock exchanges and alternative trading systems
  • Hacking of the SEC’s EDGAR system
  • Collapse of a short-term bond fund


SEC & CFTC Enforcement Update



Chambers USA – Securities: Regulation: Enforcement

Chambers FinTech – Crypto-Asset Disputes, USA, Band 1

National Law Journal – “Washington DC Trailblazer,” 2020

J.D., New York University School of Law
B.S., Policy Analysis, Cornell University
Law Clerk, Hon. Alexander Williams Jr., U.S. District Court, Maryland, 1997-1998
Professional history
  • Davis Polk since 2019
  • Division of Enforcement, Securities and Exchange Commission, 2004-2019
    • Chief, Cyber Unit (now named Crypto Assets and Cyber Unit), 2017-2019
    • Co-Chief, Market Abuse Unit, 2015-2017
    • Co-Deputy Chief, Market Abuse Unit, 2013-2015
    • Assistant Director, 2010-2013
  • Associate, Hogan & Hartson, 2001-2004
  • Associate, Proskauer Rose, 1998-2001
Qualifications and admissions
  • District of Columbia
  • State of Maryland
  • State of New York
  • U.S. District Court, E.D. New York
  • U.S. District Court, Maryland
  • U.S. District Court, S.D. New York
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