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Dixie Johnson represents businesses and individuals in securities enforcement investigations and conducts internal investigations for corporate board committees and companies. As a partner on our Securities Enforcement and Regulation team and our Special Matters and Government Investigations team, Dixie also serves as Deputy Practice Group Leader for Government Matters, a collection of ten government-facing practices within our firm. She appears regularly before the SEC, DOJ, FINRA, PCAOB and other federal and state authorities. Since she joined King & Spalding in early 2014, the government has closed over forty investigations without charging Dixie’s clients.

Dixie brings to her clients solid judgment and strategic insight from over 30 years of experience in representing public companies, financial institutions, investment managers, broker-dealers, public accounting firms, boards of directors and boards of trustees, law firms, corporate officers and others. She is widely recognized as a legal industry leader in securities enforcement, regulatory compliance, corporate governance and crisis management.

Board committees call on Dixie to investigate accounting and disclosure-related whistle-blower allegations and look to her for guidance in times of crisis. She regularly interacts with lead directors, presiding directors, and non-executive board chairs from many of the largest companies in the world.  She is a Fellow of the American College of Governance Counsel and, for five years, was a member of the Lead Director Network. 

Public companies and regulated entities seek Dixie’s representation in complex securities-related government investigations. C-Suite officers and other professionals look to Dixie for representation in internal and SEC or other investigations when their careers are on the line. She is a lawyer's lawyer, representing law firms and lawyers under scrutiny. Her bench is deep and highly skilled. She analyzes lessons learned and especially enjoys counseling clients on how to avoid problems in the future.

Chambers USA, Legal 500, Benchmark, Who’s Who, Best Lawyers and others all consistently rank Dixie as a leading lawyer, and Chambers included our practice on the 2017 short list of firms for Securities and Financial Services Regulation. Chambers has noted that she is "a very strong and thoughtful lawyer with an encyclopedic knowledge of securities laws," (2019), she “wins praise across the board for her ‘terrific relationship with the SEC.’” (2018) and she leads an “expert, broad-based enforcement practice.” (2017) Dixie also has served in multiple leadership roles within the American Bar Association, including as Business Law Section Chair, Chair of the Federal Regulation of Securities Committee, and co-Chair of the Fellows Committee.  She is a member of the Board of Trustees for the Legal Aid Society of Washington, D.C. and the Board of Advisors for the SEC Historical Society. Before becoming a lawyer, Dixie served for six years as a public school teacher in Albuquerque, New Mexico.

See examples of Dixie’s recent matters in the section below.

Full Bio

Credentials

J.D., University of New Mexico School of Law, Order of the Coif

M.B.A., New Mexico Highlands University, summa cum laude

B.A., Oklahoma Baptist University, Magna Cum Laude

District of Columbia

Advisory Board, Securities & Exchange Historical Society

American Bar Association (Chair, 50,000-member Business Law Section, 2013-2014)

Chair, 2,700-member ABA Committee on Federal Regulation of Securities, 2003-2006

Co-Chair, ABA Business Law Fellows Committee, 2016-2019

Fellow, American College of Governance Counsel

Member, American Law Institute

previously co-chaired Subcommittee on Civil Litigation and SEC Enforcement Matters)

Top Ranked Lawyer, Securities: Regulation: Enforcement


Chambers USA, Nationwide (2006-2022)

Recognized for Administrative/Regulatory Law, Corporate Compliance Law, Securities Litigation and Securities Regulation


Best Lawyers in America, 2020

Named Lawyer of the Year for Washington D.C. Litigation - Securities


Best Lawyers in America, 2019

Named among the world's Top 100 Women in Investigations, in "a competitive and notoriously tough area of law"


Global Investigations Review, 2018

Honored as one of 25 White Collar Regulatory & Compliance Trailblazers


National Law Journal, 2018

Praised by clients for "her ability to craft workable solutions to problems"


Chambers USA, National Securities Regulation: Enforcement, 2007–2018

Commended for "her strong judgment, creative approach and excellent rapport with clients, peers and regulators"


Chambers USA, National Securities Regulation: Enforcement, 2007–2018

Consistently recognized in multiple categories including Financial Services: Litigation and in White-Collar Criminal Def


Legal 500

Named Lawyer of the Year for Washington D.C. Corporate Compliance


Best Lawyers in America, 2014–2016

Consistently highlighted in the practice areas of Administrative/Regulatory Law, Corporate Compliance, Law, Litigation


Securities, Securities Regulation (2014-2017)

Named to Enforcement 40 list of top SEC enforcement lawyers


Securities Docket, 2013 and 2017

Recognized as a Washington D.C. Litigation Star and one of the top 250 women in Litigation


Benchmark: Litigation

Selected as one of Washington's Top Lawyers


Washingtonian magazine, 2011

Awarded the "Jean Allard Glass Cutter Award"


ABA's Business Law Section, 2006

Close

Recognition

Top Ranked Lawyer, Securities: Regulation: Enforcement


Chambers USA, Nationwide (2006-2022)

Recognized for Administrative/Regulatory Law, Corporate Compliance Law, Securities Litigation and Securities Regulation


Best Lawyers in America, 2020

Named Lawyer of the Year for Washington D.C. Litigation - Securities


Best Lawyers in America, 2019

Named among the world's Top 100 Women in Investigations, in "a competitive and notoriously tough area of law"


Global Investigations Review, 2018

Honored as one of 25 White Collar Regulatory & Compliance Trailblazers


National Law Journal, 2018

Praised by clients for "her ability to craft workable solutions to problems"


Chambers USA, National Securities Regulation: Enforcement, 2007–2018

Commended for "her strong judgment, creative approach and excellent rapport with clients, peers and regulators"


Chambers USA, National Securities Regulation: Enforcement, 2007–2018

Consistently recognized in multiple categories including Financial Services: Litigation and in White-Collar Criminal Def


Legal 500

Named Lawyer of the Year for Washington D.C. Corporate Compliance


Best Lawyers in America, 2014–2016

Consistently highlighted in the practice areas of Administrative/Regulatory Law, Corporate Compliance, Law, Litigation


Securities, Securities Regulation (2014-2017)

Named to Enforcement 40 list of top SEC enforcement lawyers


Securities Docket, 2013 and 2017

Recognized as a Washington D.C. Litigation Star and one of the top 250 women in Litigation


Benchmark: Litigation

Selected as one of Washington's Top Lawyers


Washingtonian magazine, 2011

Awarded the "Jean Allard Glass Cutter Award"


ABA's Business Law Section, 2006

Matters

Represented a public company in an SEC investigation regarding its disclosures regarding manufacturing problems - the investigation ended with no enforcement recommendation against our client.

Represented a public company in connection with its 2021 SPAC merger and related disclosures - the investigation ended with no enforcement recommendation against our client.

Represented a token issuer and tool creator for developers building applications on the Bitcoin blockchain in an SEC investigation regarding whether its tokens had become decentralized, whether token sales had been properly conducted consistent with SEC requirements, and whether false or misleading statements had occurred - the investigation ended with no enforcement recommendation against our client.

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Close

Matters

Represented a public company in an SEC investigation regarding its disclosures regarding manufacturing problems - the investigation ended with no enforcement recommendation against our client.

Represented a public company in connection with its 2021 SPAC merger and related disclosures - the investigation ended with no enforcement recommendation against our client.

Represented a token issuer and tool creator for developers building applications on the Bitcoin blockchain in an SEC investigation regarding whether its tokens had become decentralized, whether token sales had been properly conducted consistent with SEC requirements, and whether false or misleading statements had occurred - the investigation ended with no enforcement recommendation against our client.

Represented a pubilc company in a multi-year investigation involving non-GAAP financial measures and related disclosures resulting in a settlement in 2023.

Representing a bank in multiple DOJ, SEC and state investigations concerning residential mortgage backed securities, including matters involving the Presidential RMBS Task Force.

Representing a public healthcare company in an SEC investigation concerning rounding in its calculations of earnings per share (EPS rounding).

Representing a public consumer goods company in an SEC investigation concerning a goodwill impairment charge.

Representing a former manufacturing public company CFO in connection with an SEC investigation concerning accounting and other issues.

Represented a public utility company in an SEC investigation concerning disclosures and accounting related to a significant construction project.

Represented a board of directors of a privately held company concerning its token offerings (sometimes referred to as an initial coin offering, or ICO), another privately held company in an SEC investigation regarding its token offering, and a registered investment adviser in connection with an SEC review of a contract involving crypto-currencies.

Conducted an internal investigation for a public data analytics company audit committee concerning whistle-blower allegations involving revenue recognition, disclosure, internal controls and retaliation.

Represented a law firm in connection with an SEC investigation concerning the firm's former private equity client.

Represented a registered investment adviser in an SEC investigation concerning valuation issues

Conducted an internal investigation for a public energy company special committee concerning product disclosures.

Represented a former CEO of an investment management firm in SEC and DOL investigations concerning investment products

Represented a former CFO of an investment management firm in an SEC investigation concerning accounting issues.

Represented a former medical device public company CFO in connection with SEC and DOJ investigations involving financial statements that the CFO certified and a concurrent FCPA issue.

Represented a broker dealer compliance officer in an SEC investigation concerning trading activities.

Represented a pension fund in connection with an SEC investigation involving the fund's investment activities, after which the SEC closed the investigation without bringing charges.

Represented a public life sciences company in an SEC investigation concerning its investor relations activities.

Represented an audit firm in a PCAOB inquiry concerning auditor independence.

Matters

Represented a public company in an SEC investigation regarding its disclosures regarding manufacturing problems - the investigation ended with no enforcement recommendation against our client.

Represented a public company in connection with its 2021 SPAC merger and related disclosures - the investigation ended with no enforcement recommendation against our client.

Represented a token issuer and tool creator for developers building applications on the Bitcoin blockchain in an SEC investigation regarding whether its tokens had become decentralized, whether token sales had been properly conducted consistent with SEC requirements, and whether false or misleading statements had occurred - the investigation ended with no enforcement recommendation against our client.

See more

Close

Matters

Represented a public company in an SEC investigation regarding its disclosures regarding manufacturing problems - the investigation ended with no enforcement recommendation against our client.

Represented a public company in connection with its 2021 SPAC merger and related disclosures - the investigation ended with no enforcement recommendation against our client.

Represented a token issuer and tool creator for developers building applications on the Bitcoin blockchain in an SEC investigation regarding whether its tokens had become decentralized, whether token sales had been properly conducted consistent with SEC requirements, and whether false or misleading statements had occurred - the investigation ended with no enforcement recommendation against our client.

Represented a pubilc company in a multi-year investigation involving non-GAAP financial measures and related disclosures resulting in a settlement in 2023.

Representing a bank in multiple DOJ, SEC and state investigations concerning residential mortgage backed securities, including matters involving the Presidential RMBS Task Force.

Representing a public healthcare company in an SEC investigation concerning rounding in its calculations of earnings per share (EPS rounding).

Representing a public consumer goods company in an SEC investigation concerning a goodwill impairment charge.

Representing a former manufacturing public company CFO in connection with an SEC investigation concerning accounting and other issues.

Represented a public utility company in an SEC investigation concerning disclosures and accounting related to a significant construction project.

Represented a board of directors of a privately held company concerning its token offerings (sometimes referred to as an initial coin offering, or ICO), another privately held company in an SEC investigation regarding its token offering, and a registered investment adviser in connection with an SEC review of a contract involving crypto-currencies.

Conducted an internal investigation for a public data analytics company audit committee concerning whistle-blower allegations involving revenue recognition, disclosure, internal controls and retaliation.

Represented a law firm in connection with an SEC investigation concerning the firm's former private equity client.

Represented a registered investment adviser in an SEC investigation concerning valuation issues

Conducted an internal investigation for a public energy company special committee concerning product disclosures.

Represented a former CEO of an investment management firm in SEC and DOL investigations concerning investment products

Represented a former CFO of an investment management firm in an SEC investigation concerning accounting issues.

Represented a former medical device public company CFO in connection with SEC and DOJ investigations involving financial statements that the CFO certified and a concurrent FCPA issue.

Represented a broker dealer compliance officer in an SEC investigation concerning trading activities.

Represented a pension fund in connection with an SEC investigation involving the fund's investment activities, after which the SEC closed the investigation without bringing charges.

Represented a public life sciences company in an SEC investigation concerning its investor relations activities.

Represented an audit firm in a PCAOB inquiry concerning auditor independence.

Credentials

J.D., University of New Mexico School of Law, Order of the Coif

M.B.A., New Mexico Highlands University, summa cum laude

B.A., Oklahoma Baptist University, Magna Cum Laude

District of Columbia

Advisory Board, Securities & Exchange Historical Society

American Bar Association (Chair, 50,000-member Business Law Section, 2013-2014)

Chair, 2,700-member ABA Committee on Federal Regulation of Securities, 2003-2006

Co-Chair, ABA Business Law Fellows Committee, 2016-2019

Fellow, American College of Governance Counsel

Member, American Law Institute

previously co-chaired Subcommittee on Civil Litigation and SEC Enforcement Matters)

Top Ranked Lawyer, Securities: Regulation: Enforcement


Chambers USA, Nationwide (2006-2022)

Recognized for Administrative/Regulatory Law, Corporate Compliance Law, Securities Litigation and Securities Regulation


Best Lawyers in America, 2020

Named Lawyer of the Year for Washington D.C. Litigation - Securities


Best Lawyers in America, 2019

Named among the world's Top 100 Women in Investigations, in "a competitive and notoriously tough area of law"


Global Investigations Review, 2018

Honored as one of 25 White Collar Regulatory & Compliance Trailblazers


National Law Journal, 2018

Praised by clients for "her ability to craft workable solutions to problems"


Chambers USA, National Securities Regulation: Enforcement, 2007–2018

Commended for "her strong judgment, creative approach and excellent rapport with clients, peers and regulators"


Chambers USA, National Securities Regulation: Enforcement, 2007–2018

Consistently recognized in multiple categories including Financial Services: Litigation and in White-Collar Criminal Def


Legal 500

Named Lawyer of the Year for Washington D.C. Corporate Compliance


Best Lawyers in America, 2014–2016

Consistently highlighted in the practice areas of Administrative/Regulatory Law, Corporate Compliance, Law, Litigation


Securities, Securities Regulation (2014-2017)

Named to Enforcement 40 list of top SEC enforcement lawyers


Securities Docket, 2013 and 2017

Recognized as a Washington D.C. Litigation Star and one of the top 250 women in Litigation


Benchmark: Litigation

Selected as one of Washington's Top Lawyers


Washingtonian magazine, 2011

Awarded the "Jean Allard Glass Cutter Award"


ABA's Business Law Section, 2006

Close

Recognition

Top Ranked Lawyer, Securities: Regulation: Enforcement


Chambers USA, Nationwide (2006-2022)

Recognized for Administrative/Regulatory Law, Corporate Compliance Law, Securities Litigation and Securities Regulation


Best Lawyers in America, 2020

Named Lawyer of the Year for Washington D.C. Litigation - Securities


Best Lawyers in America, 2019

Named among the world's Top 100 Women in Investigations, in "a competitive and notoriously tough area of law"


Global Investigations Review, 2018

Honored as one of 25 White Collar Regulatory & Compliance Trailblazers


National Law Journal, 2018

Praised by clients for "her ability to craft workable solutions to problems"


Chambers USA, National Securities Regulation: Enforcement, 2007–2018

Commended for "her strong judgment, creative approach and excellent rapport with clients, peers and regulators"


Chambers USA, National Securities Regulation: Enforcement, 2007–2018

Consistently recognized in multiple categories including Financial Services: Litigation and in White-Collar Criminal Def


Legal 500

Named Lawyer of the Year for Washington D.C. Corporate Compliance


Best Lawyers in America, 2014–2016

Consistently highlighted in the practice areas of Administrative/Regulatory Law, Corporate Compliance, Law, Litigation


Securities, Securities Regulation (2014-2017)

Named to Enforcement 40 list of top SEC enforcement lawyers


Securities Docket, 2013 and 2017

Recognized as a Washington D.C. Litigation Star and one of the top 250 women in Litigation


Benchmark: Litigation

Selected as one of Washington's Top Lawyers


Washingtonian magazine, 2011

Awarded the "Jean Allard Glass Cutter Award"


ABA's Business Law Section, 2006