Robert A. Cohen
  1. Partner

Mr. Cohen brings 15 years of experience in the Securities and Exchange Commission’s Division of Enforcement to his work as a partner in Davis Polk’s Litigation Department in Washington DC. As a member of the firm’s White Collar Defense & Investigations Group, he focuses on representing companies, boards and individuals in regulatory matters and internal investigations.

During his tenure at the agency and as a member of the Enforcement Division’s senior leadership, Mr. Cohen was involved in significant enforcement actions involving insider trading, accounting and disclosure violations, market manipulation and abuse, cryptocurrency, cybersecurity, broker-dealers and investment advisers.

After handling investigations across a wide range of areas, Mr. Cohen specialized in cutting-edge and highly complex investigations. As Co-Chief of the Market Abuse Unit, Mr. Cohen led a nationwide team that investigated potential trading and market structure violations, including high-profile and complex insider trading, large-scale market manipulation, and market structure violations involving order handling, market data, and dark pools.

Mr. Cohen also was the first-ever Chief of the SEC’s Cyber Unit, and led the SEC’s enforcement efforts regarding cryptocurrency and cybersecurity. Mr. Cohen supervised many of the SEC’s groundbreaking enforcement actions concerning cryptocurrency, including the first case involving a digital asset exchange, many of the first cases involving initial coin offerings, and the first case charging an entity for operating as an unregistered broker-dealer in digital assets. Mr. Cohen also led investigations concerning cybersecurity controls and disclosures at broker-dealers, investment advisers, and public companies, as well as cyber-related manipulation.

Work Highlights

Government and Internal Investigations
  • A Fortune 100 company in responding to a SEC Enforcement investigation concerning internal controls
  • A China-based retail company in connection with fraud investigations by DOJ and SEC
  • A public company in an internal investigation regarding a subsidiary
  • An investment trust in response to a SEC enforcement inquiry
  • A large public company regarding a SEC investigation into accounting practices
  • A large public company in a matter regarding SEC reporting
  • A public company in an internal investigation concerning material, nonpublic information
  • A public company in an internal investigation regarding compliance with European financial regulations
  • A broker-dealer in a FINRA investigation
  • A broker-dealer in an SEC investigation
  • A large financial institution in a FINRA investigation
Data Privacy & Cybersecurity
  • A private equity firm concerning cybersecurity advice
  • An internal investigation for a Fortune 100 company regarding a cyber incident
  • A financial services provider regarding a privacy incident
  • A public company in responding to a cyber incident
  • Multiple investment advisers regarding data use policies

Prior to joining Davis Polk, cases that Mr. Cohen supervised at the SEC included:

  • Insider trading, including separate cases involving hedge funds, a member of Congress, tips passed at Grand Central Station, and nonpublic government information
  • Several cases involving public company accounting, controls, and disclosures, including reserves for environmental liability at a Fortune 500 company and revenue recognition practices at a technology company
  • Trading investigations related to order handling and routing, national stock exchanges, and alternative trading systems
  • Cybersecurity procedures at a broker-dealer and investment adviser
  • A hacker and multiple traders who hacked into the SEC's EDGAR system
  • Cryptocurrency matters involving initial coin offerings and digital tokens
  • $118 million case involving collapse of short-term bond fund


  • The National Law Journal “Washington DC Trailblazer,” 2020

Of Note

  • Member, Law360 Editorial Advisory Board: Securities, 2021
  • Co-Chair, Securities Enforcement Subcommittee, D.C. Bar

Professional History

  • Partner, Davis Polk, 2019-present
  • 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
  • Law Clerk, Hon. Alexander Williams Jr., U.S. District Court, Maryland, 1997-1998

Bar Admissions

  • District of Columbia
  • State of Maryland
  • State of New York
  • U.S. District Court, Maryland
  • U.S. District Court, E.D. New York
  • U.S. District Court, S.D. New York


  • B.S., Policy Analysis, Cornell University, 1994
  • J.D., New York University School of Law, 1997