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 across a wide range of areas, including securities fraud, insider trading, market manipulation and abuse, financial fraud, cybersecurity and cryptocurrency.

As the first-ever Chief of the Cyber Unit, he supervised investigations concerning cybersecurity events, controls and disclosures at broker-dealers, investment advisers, stock exchanges and public companies, initial coin offerings and other conduct involving digital assets, and cyber-related market manipulations.

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

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

Selected cases that Mr. Cohen supervised at the SEC involved:

  • Misconduct in initial coin offerings, including widespread fraud in one offering and a case of celebrities failing to disclose the compensation they received for promoting ICOs
  • Several issuers that sold digital tokens in unregistered securities offerings 
  • The founder of an unregistered securities exchange that traded digital tokens 
  • A hacker and multiple traders who hacked into the SEC's EDGAR system 
  • Deficient cybersecurity procedures at a broker-dealer and investment adviser
  • National stock exchanges for regulatory failures in connection with multiple episodes, including periods of market disruption
  • Violations of federal securities laws in the operation of dark pools and other alternative trading systems
  • Misleading disclosures about retail order handling and order routing
  • Insider trading, including separate cases involving hedge funds, a member of Congress and nonpublic government information
  • $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

Practice Focus

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