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Robert Johnston is a partner in the firm’s Investment Management Group and White Collar Defense Practice, and he focuses on internal investigations, SEC examinations and enforcement, regulatory compliance advice and counseling, compliance program design and implementation, cross-border due diligence, compliance auditing and monitoring, and commercial disputes. He regularly advises investment advisers, family offices, hedge funds and private equity funds, and their related portfolio companies on matters related to the Foreign Corrupt Practices Act (FCPA), anti-money laundering (AML) statutes and related know your customer (KYC) regulations, trade sanctions, fraud, conflicts of interest, electoral engagement, pay-to-play, gifts and entertainment, and compliance best practices.
Rob has led investigations and compliance projects in over 30 countries across six continents on behalf of U.S. and multinational corporations. He frequently counsels clients on matters involving the U.S. Department of Justice, the U.S. Securities and Exchange Commission, and other state and local regulatory bodies.
In addition to complex regulatory enforcement matters and internal investigations, clients turn to Rob for his knowledge of compliance program design and implementation. He provides clear, commercial, practical, and actionable compliance advice that balances business objectives and risk management. As leader of the firm’s AML team, Rob focuses his practice on the strategic analysis and application of AML, KYC, FCPA, and other regulatory frameworks with respect to practical and efficient solutions to address his clients’ most complex compliance challenges to meet their business objectives.
Rob has extensive experience with compliance monitoring, having advised a publicly traded financial institution through the timely resolution of a three-year monitor imposed by the DOJ and SEC, served as counsel to a World Bank-imposed monitor of a logistics company, and counseled a construction company as it agreed to the imposition of a World Bank-imposed monitor. He regularly conducts compliance risk assessments, audits, ongoing monitoring, and due diligence on behalf of his clients.
Prior to joining Lowenstein, Rob was in-house counsel at Sculptor Capital Management, formerly known as Och-Ziff, most recently as Managing Director and General Counsel-Asia and previously as Managing Director and Deputy Chief Compliance Officer. During his time at Sculptor, he developed an industry-leading FCPA and AML compliance program through the development and implementation of proprietary, web-based, technological solutions.
Before Sculptor Capital, Rob practiced in the litigation departments at two Am Law 50 firms, with a focus on internal investigations, white collar defense, compliance advice, and M&A due diligence. He spent a year in the Shanghai office of one firm, where he acted on behalf of multinational corporations investigating allegations of bribery, corruption, and fraud in their Chinese and East Asian operations.
Rob’s pro bono work includes advising a South American nation on its judiciary modernization efforts and on the implementation of newly enacted anti-money laundering laws similar to the U.S.A. PATRIOT Act, assisting a South American charity with the repatriation of funds raised abroad, and representing unaccompanied minors in immigration proceedings.
Rob is a Certified Anti-Money Laundering Specialist with the Association of Certified Anti-Money Laundering Specialists (ACAMS).
Rob speaks French and Spanish.