Rebecca Leon is a corporate attorney in Holland & Knight's West Palm Beach and Miami offices and member of the Corporate, M&A and Securities Practice Group. She is co-head of the firm's Broker-Dealer Regulation and Compliance Team. Ms. Leon is an experienced broker-dealer and investment adviser regulatory attorney who focuses on counseling clients on global regulatory and compliance matters.
Ms. Leon has extensive experience guiding financial services clients on structuring and developing their international operations, including their cross-border and in-country business.
In addition, Ms. Leon counsels domestic and foreign clients on U.S. federal and state securities laws and the rules of the Financial Industry Regulatory Authority (FINRA). She frequently advises clients on clearing and custody arrangements, net capital and customer protection rules, broker-dealer registration and material changes in business, outsourcing, referral arrangements, expense and personnel sharing arrangements, and the intersection of U.S. and foreign regulations impacting financial services providers. She assists clients with a panoply of intercompany, customer and industry agreements. Ms. Leon frequently advises clients entering the U.S. market and advises on the intricacies of establishing foreign offices and global operations.
Ms. Leon's holistic approach helps financial services firms look beyond licensing to understand the wide array of global legal and regulatory risks inherent to their business models, including in areas such as data protection, tax, exchange controls, provision of credit, deposit taking, consumer protection, fly-in meetings and reporting requirements. She assists clients in building their global policies and procedures, and in preparing documentation and training programs with a view to mitigating U.S. and foreign legal and compliance risks.
Prior to rejoining Holland & Knight, Ms. Leon was a partner in the financial regulation and enforcement practice at an international law firm in its Miami office. Ms. Leon previously was a partner with Holland & Knight from 2016 to 2020. In addition, she has worked at law firms in New York and Miami, where she also assisted clients with private placements, securities arbitrations, and investigations by the U.S. Securities and Exchange Commission (SEC) and FINRA. Notably, she also has prior experience as a staff attorney in the Enforcement Division of the SEC's New York Regional Office.
While in law school, she maintained internships at the New York Stock Exchange (NYSE) and the U.S. Commodity Futures Trading Commission (CFTC).
- Advised broker-dealers on piggyback clearing arrangements with domestic and foreign firms, establishing personnel and expense sharing arrangements with affiliates, financial advisors as independent contractors, private securities transaction and outside business activities rules, registration and termination of registered representatives, and statutory disqualification
- Prepared global and country-by-country cross-border policies, procedures and customer documentation for more than 75 countries for private wealth businesses of dually registered broker-dealers/investment advisers
- Counseled clearing brokers on the regulatory considerations related to provision of cross-border securities custody, execution, clearing and settlement services, as well as margin financing, bank and money market sweep programs, debit card and check services and other ancillary services
- Advised on global considerations related to cross-referrals of securities-related business, lending and real estate investment management among affiliated and third-party banks, broker-dealers and investment advisers, including under FINRA rules, the Investment Advisers Act of 1940, Securities Exchange Act Rule 15a-6 and foreign laws
- Guided banks and broker-dealers on foreign regulatory issues related to the provision of consumer and wholesale banking and securities products in Latin America and the Caribbean, including credit and deposit products, treasury management and payment services, investment banking and capital markets services, institutional sales and trading, and trustee services, including analysis of licensing requirements, privacy laws, anti-bribery and anti-corruption laws, consumer protection regulations, anti-money laundering laws and reporting requirements
- Analyzed the risks associated with the use of electronic signatures, social media marketing and virtual group marketing events in more than 60 jurisdictions as applicable to cross-border financial service providers
- Counseled clients on global regulatory considerations with respect to distribution of investment funds, annuities and new issue securities, and in servicing employee stock option plans, retirement plans, wrap account programs and transfer on death accounts
- Brooklyn Law School, J.D.
- Case Western Reserve University, MBA
- Case Western Reserve University, B.A.
- New York
- Securities Industry and Financial Markets Association (SIFMA) Compliance and Legal Society
- The Best Lawyers in America, International Trade and Finance law, 2023
- Top 100 Female Lawyers in Latin America, Latinvex, 2020