STEPHEN COHEN is the global practice leader of the Regulatory and Enforcement group and a member of the firm’s Executive Committee. He advises clients on a comprehensive range of government and internal investigations, enforcement-related litigation, whistleblower complaints, cyber breaches and regulatory and compliance issues, including clients seeking to strengthen corporate governance and compliance programs. Stephen joined Sidley in 2017 after twelve years at the Securities and Exchange Commission, most recently serving as Associate Director in the Enforcement Division where he earned the Distinguished Service Award, the agency’s highest honor. He oversaw hundreds of investigations involving broker-dealers, investment advisers, exchanges, securities offerings, insider trading and a range of public company and accounting issues. The Society of Corporate Compliance and Ethics presented Stephen with its 2017 International Compliance & Ethics award, recognizing him for his significant contributions to the compliance and ethics profession. Stephen is a Chambers-ranked member of Sidley’s global Securities Enforcement and Regulatory practice, which received the 2019 Chambers USA Award for Financial Services Regulation, and was named the “Law Firm of the Year” for Securities Regulation in 2020 and 2017 by U.S. News – Best Lawyers.

Stephen L. Cohen
- Securities Enforcement and Regulatory
- ホワイトカラーの弁護と捜査
- 公認会計士・職業賠償責任
- 政策戦略
経験
- 代表案件
- メンバーシップ&アクティビティ
Since joining Sidley in 2017, Stephen has represented several public companies and their Audit Committees or Special Committees as well as SEC registrants in internal investigations and matters involving the SEC, Department of Justice, FINRA, PCAOB, CFTC, state attorneys general and securities regulators. Stephen is ranked in Chambers for Securities Enforcement, which noted his “wide-reaching capabilities in regulatory enforcement. He is highly effective in representing asset managers and public companies before the SEC in disclosure and reporting matters, as well as in FCPA issues.” Representative matters include:
Public Companies and Auditors
- HP Inc. in disclosure-related SEC settlement.
- Herbalife Nutrition in FCPA investigation resulting in SEC settlement and DOJ deferred prosecution agreement, and a disclosure-related SEC matter.
- BorgWarner, Inc. in restatement-related SEC settlement.
- MiMedx in SEC and DOJ investigations, including an SEC settlement and DOJ declination.
- Large multinational company in internal investigation and investigations by SEC and DOJ involving the Foreign Corrupt Practices Act.
- Fortune 100 company in SEC accounting and disclosure investigation.
- Multiple big four audit firms and partners, as well as international member firms, in SEC and PCAOB investigations.
- Multiple public company boards of directors on governance, compliance and regulatory issues.
SEC-Registered Firms
- Principal of substantial hedge fund manager in an SEC investigation resulting in no enforcement action.
- Rialto Capital Management in SEC settlement.
- Registered investment adviser in an SEC investigation resulting in closure with no enforcement action.
- Multiple investment advisers in SEC’s revenue sharing and mutual fund share class disclosure.
- Multiple investment advisers in SEC exams.
- Major bank in conjunction with internal investigation and FINRA inquiry involving mortgage-backed securities trading.
- Major financial institution in conjunction with SEC investigation involving international private fund, which was closed without enforcement action.
- Credit rating agency in SEC investigation.
Cybersecurity and Cryptocurrency
- Large financial institution in internal investigation involving cybersecurity incident.
- Large public investment bank in internal investigation and regulatory guidance related to cyber breach.
- Investment adviser in cyber-related SEC examination.
- Multiple individuals in SEC initial coin offering investigation.
While at the SEC, Stephen oversaw domestic and international enforcement activities involving accounting and disclosure fraud, auditor misconduct, the Foreign Corrupt Practices Act, insider trading, registered and unregistered securities offerings, market abuses, broker-dealers, investment advisers and other regulated entities. Stephen held many division-wide and agency-wide leadership positions. In addition, in various different contexts, he worked closely with individuals in many federal regulatory and law enforcement agencies, including investigative coordination and providing advice and training on enforcement and investigations issues to regulators and law enforcement agencies around the world. He also served as part of a task force with other federal agencies for cybersecurity issues.
Prior to his appointment as associate director, Stephen was a senior adviser to former SEC Chairman Mary Schapiro. He was instrumental in advising on legal, policy and administrative matters with a focus on enforcement and compliance, legislative matters and congressional hearings. Stephen led the SEC’s work in relation to the whistleblower provisions in Dodd-Frank and subsequent rulemaking, oversaw the rulemaking establishing a Consolidated Audit Trail, and he directed the creation of the agency’s Tips, Complaints and Referrals system.
Stephen won the SEC’s Distinguished Service Award in 2016, the agency’s highest honor, for his skill in managing one of the division’s most productive groups, bringing many of the commission’s most significant actions, significantly expanding the SEC’s ability to protect investors and driving initiatives that improved the division’s performance. In 2013, he received the Chairman’s Award for Excellence in recognition of his work on the Consolidated Audit Trail rulemaking. Stephen also received the agency’s Law and Policy award in 2011 for his involvement in the implementation of the Dodd-Frank Act, including the Whistleblower Program.
Before joining the SEC, Stephen handled litigation matters and government investigations at a national law firm. Prior to that, he worked at the Department of Justice as a trial lawyer through the Attorney General’s Honors Program after clerking for a federal district judge.
Stephen is a frequent speaker on SEC enforcement and has participated in numerous conferences nationwide. He has also been interviewed on television news programs, including CNBC and Fox News and programs such as Dateline and American Greed.
- Member, Steering Committee, District of Columbia Bar’s Corporation, Finance and Securities Law Community, recipient of the District of Columbia Bar’s 2021 Community of the Year Award.
- Member, Editorial Board, Journal of Financial Compliance.
- Member, Board of Advisors, SEC Historical Society.
得意分野
- Securities Enforcement and Regulatory
- ホワイトカラーの弁護と捜査
- 公認会計士・職業賠償責任
- 政策戦略
- マネーロンダリング対策
- ビッグデータ・モノのインターネット・人工知能
- 証券会社
- コンプライアンス カウンセリング - ホワイト カラー
- 議会による調査
- サイバーセキュリティ・サイバー犯罪・データ侵害
- ドッド=フランク法
- 海外腐敗行為防止法/汚職禁止
- 金融情報とプライバシー法
- 金融機関訴訟
- 財務報告と開示
- 金融サービス訴訟
- 会計士に関する政府および規制当局の捜査
- ヘッジファンドと未公開株訴訟
- ヘッジファンド
- インサイダー取引
- 内部調査
- 国際会計士責任例
- 投資顧問・ミューチュアル ファンド
- 法律事務所代表
- M&A訴訟
- 国家安全保障
- プライベート証券訴訟
- 株式公開企業の会計監視委員会
- リテール金融サービス
- 米国証券取引委員会(SEC)への開示
- 第10条A
- 第16条報告と責任
- 会計士に対する証券訴訟
- 証券、投資信託、商品取引活動
- 役員と取締役による証券取引
- 公判
- 行政法控訴
- 金融、証券、会計賠償責任控訴審
- グローバル金融サービス
- Crisis Management and Strategic Response
- Public Companies
- Securities Enforcement
- Blockchain
- Fintech
- Investment Adviser Enforcement
- 投資顧問
- プライベート不動産ファンド
- Securities Regulatory Counseling and Compliance
- Banks and Financial Institutions Crisis Management and Strategic Response
- Pre-Commercial Life Sciences Companies
- UK Accountancy Investigations and Enforcement
- デリバティブ
ニュース&インサイト
資格
弁護士資格・登録
- U.S. Court of Appeals, 5th Circuit
- U.S. Court of Appeals, D.C. Circuit
- District of Columbia
- Florida
- Massachusetts
学歴
- University of Miami School of Law, J.D., 1997 (magna cum laude, University of Miami Law Review)
- Boston University, B.A., 1993 (cum laude)
クラークシップ
- Ursula Ungaro, U.S. District Court, S.D. of Florida (1997 - 1998)