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 Criminal Defense and Government Investigations Group, he focuses on representing companies, boards and individuals in regulatory matters and internal investigations.

During his tenure at the agency, Mr. Cohen was involved in significant enforcement actions including securities fraud, insider trading, market manipulation and abuse, financial fraud, cybersecurity and cryptocurrency.

After beginning his career by handling investigations across a wide range of areas, Mr. Cohen joined the Division’s senior leadership and specialized in cutting-edge and highly complex investigations.

First, Mr. Cohen was Co-Chief of the Market Abuse Unit, supervising market structure and trading investigations, including violations by national securities exchanges, dark pools and large broker-dealers, high-profile and complex insider trading, and large-scale market manipulation.

Then Mr. Cohen became the first-ever Chief of the Cyber Unit as cybersecurity issues became a prominent issue in the financial industry. Mr. Cohen supervised investigations concerning cybersecurity controls and disclosures at broker-dealers, investment advisers, stock exchanges and public companies, and cyber-related manipulation.

Mr. Cohen also led the SEC’s enforcement response to the emergence of cryptocurrency in the securities markets, supervising a wave of investigations involving initial coin offerings and other conduct involving digital assets.

Mr. Cohen is admitted to practice in New York and Maryland, and is practicing in DC under the supervision of partners of the firm.

Work Highlights

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

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, District of Maryland, 1997-1998

Bar Admissions

  • 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

Education

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