Robert A. Cohen
Represents companies and individuals in government investigations. Conducts internal investigations. Held senior roles in the SEC Enforcement Division.
Rob brings 15 years of senior-level government experience to his work representing clients in government investigations, including by the SEC, FTC, CFTC and state attorneys general. He also conducts internal investigations for companies and boards.
He represents public companies in investigations concerning disclosures, accounting and internal controls. He advises investment advisers and broker-dealers on regulatory requirements and represents them in investigations. He is an authority on cybersecurity and cryptocurrency, having served as the first-ever Chief of the SEC’s Cyber Unit. He also supervised trading-related investigations as Co-Chief of the SEC’s Market Abuse Unit.
“[Rob is] unafraid to advocate for his clients and to speak with regulators in a transparent, candid and convincing manner” says a source quoted by Chambers USA, while another source states “Rob is super grounded, smart and practical.”
Rob is a member of the SEC Historical Society’s Board of Advisors.
Experience
SEC Investigations
- Obtained termination notices without charges in 21 separate SEC investigations in less than five years (2022-2026)
Rob’s SEC enforcement representations include:
- A large technology public company concerning disclosures
- A Fortune 100 public company, concerning internal controls
- A Fortune 500 public company, concerning metric disclosures
- A manufacturing public company, concerning accounting for supplier rebates
- A large asset manager concerning cash sweep practices
- A private fund regarding valuation practices
- A hedge fund adviser, concerning fixed income trading
- A hedge fund concerning fund formation and investor disclosures
- An apparel company concerning disclosures
- A large broker dealer concerning the Customer Protection Rule
- A public company/medical device manufacturer, concerning disclosures
- A regional bank concerning liquidity
- Multiple financial institutions, concerning off-channel communications
- Several public companies in insider trading investigations
- An individual, concerning auditing standards
Other Government Investigations
- A large technology company in an FTC investigation concerning consumer protection
- A large technology company in investigations by the NY State Attorney General and other state attorneys general
- A digital asset financial services firm in an investigation by the New York State Attorney General
- Multiple broker-dealers in FINRA investigations, including involving underwriting practices, best execution and trade data
Internal Investigations
- Two private funds in separate matters concerning valuation of assets
- A large investment bank in two separate matters involving potential access to material nonpublic information
- A fintech public company concerning internal access to material nonpublic information
- A public company regarding Regulation FD compliance
- A senior executive in an internal investigation
Cryptocurrency & Digital Assets
- Obtained termination notice for Paxos Trust Company following Wells notice in SEC investigation of BUSD, concluding investigation without any charges against Paxos
- A large digital asset financial services firm in SEC, DOJ and CFTC 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
- Featured in Netflix documentary “Bitconned” about one of the first fraud cases of the crypto era
Data Privacy & Cybersecurity
- Multiple public companies in responding to the SEC sweep regarding the SolarWinds compromise
- A public company in an SEC investigation regarding cybersecurity disclosures
- A Fortune 100 company in an internal investigation regarding a cyber 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
Insights
News
Recognition
Chambers USA – Securities: Regulation: Enforcement
Chambers USA – Litigation: White-Collar Crime & Government Investigations, District of Columbia
Chambers FinTech – Crypto-Asset Disputes, USA, Band 1
Securities Docket – “Incident Response Elite,” 2026
Securities Docket – “Enforcement Elite,” 2024 and 2025
Law360 – Securities Editorial Advisory Board, 2021
National Law Journal – “Washington DC Trailblazer,” 2020
Education
Clerkships
Prior experience
- Division of Enforcement, Securities and Exchange Commission, 2004-2019
- Chief, 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