Dixie L. Johnson is a partner in the firm’s Special Matters and Government Investigations practice group and co-leads the firm’s securities enforcement and regulation practice. She represents businesses and individuals in government securities investigations from her office in Washington, DC. Consistently ranked among the most prominent securities enforcement lawyers in the United States, she represents public companies, financial institutions, public accounting firms, boards of directors and boards of trustees, corporate officers and other individuals in securities enforcement investigations. She appears regularly before the United States Securities and Exchange Commission, the United States Department of Justice, and other federal, state and local agencies, as well as various boards and self-regulatory organizations, including the Public Company Accounting Oversight Board and the Financial Industry Regulatory Authority. She also counsels clients regarding their regulatory and disclosure obligations, assists clients in developing policies and procedures to deter violations, and conducts internal investigations. Few of her client representations ever become known to the public.
Ms. Johnson’s current and recent representations include:
- a bank in parallel DOJ and SEC investigations concerning Regulation FD, adequacy of public disclosures, and loan loss reserves for its residential mortgage portfolios,
- a public company in an SEC investigation concerning its investor relations activities,
- an investment bank in an SEC investigation of cash flow modeling issues in a complex securitization transaction,
- an insurance company in an SEC investigation concerning accounting for earnings and expenses concerning loss mitigation insurance,
- an audit firm in a PCAOB inquiry concerning auditor independence,
- a pension fund in connection with an SEC review of its investment activities,
- multiple asset managers in connection with SEC investigations concerning trading issues,
- multiple companies in connection with following up on issues raised by whistleblowers, and
- individual directors, officers, lawyers, auditors, bankers, portfolio managers and analysts in a variety of SEC and other investigations concerning their activities relating to the federal securities laws involving a variety of issues including disclosure, accounting, internal controls, securities trading, compliance procedures, FCPA, valuation, registration, and suitability.
In addition to representing the businesses and business leaders who are her clients, Ms. Johnson served in 2013-2014 as the elected Chair of the Business Law Section of the American Bar Association, with over 50,000 members, over 50 substantive committees, and over 500 subcommittees, all focused on issues that matter to business lawyers. Previously, as Business Law Secretary and Vice-Chair, Ms. Johnson served as editor-in-chief of the Section's renowned journal, The Business Lawyer, in 2010-2012, and as co-editor-in-chief of the Section's online monthly magazine, Business Law Today, in 2010-2011. In 2006, she received the Business Law Section's "Jean Allard Glass Cutter Award," given annually to a woman who has cut through barriers to attain high accomplishments in Business Law. From 2003-2006, she served as Chair of the Committee on Federal Regulation of Securities, following a long tenure as co-chair of that committee's Subcommittee on Civil Litigation and SEC Enforcement Matters. Ms. Johnson also is an elected member of the American Law Institute.
Prior to becoming a lawyer, she taught in the Albuquerque, New Mexico public school system for six years.
Awards & Recognition
- Chambers USA: America's Leading Lawyers for Business consistently ranks Ms. Johnson as a leading individual in Securities Regulation: Enforcement (National), noting that she is praised by clients for "her ability to craft workable solutions to problems" and commended for "her strong judgment, creative approach and excellent rapport with clients, peers and regulators."
- Consistently recognized by Legal 500 in Financial Services: Litigation and is additionally recognized in White-Collar Criminal Defense
- Named the Best Lawyers’ 2014-15 Washington DC Corporate Compliance Law “Lawyer of the Year” and included in the 2014-15 Edition of The Best Lawyers in America in the practice areas of Administrative/Regulatory Law, Corporate Compliance Law, Litigation – Securities, and Securities Regulation
- Named to Securities Docket’s “Enforcement 40” list of top SEC enforcement lawyers, 2013
- Glass Cutter Award in 2006
- Recognized by Benchmark: Litigation as a Washington, DC Litigation Star
- Selected as one of "Washington's Top Lawyers" by Washingtonian magazine in 2011
- Selected as one of the top ten "Leading Lawyers" in Securities and Corporate Governance by the Legal Times of Washington in 2003.
- ABA's Section of Business Law
- American Law Institute
- Executive Council of the Federal Bar Association, Securities Law Committee
- Securities and Exchange Commission Historical Society Board of Advisors
- Former member of the Securities Board of Editors of the Lexis Nexis Publishing Company (2008-2010)