Overview
Marlon Paz is a leading authority on corporate governance, financial regulation and enforcement with more than 25 years of experience spanning the US Securities and Exchange Commission, private practice, and academia. He advises and defends global banks, public companies, broker-dealers, investment advisers, exchanges, and industry associations in high-stakes transactions and regulatory and enforcement matters. Marlon regularly advises boards of directors and senior management on a variety of issues and is adept at designing and implementing strategies for clients based on his broad experience, deep organizational knowledge, and substantive capabilities.
Clients rely on Marlon when faced with complex matters, including enforcement matters before the SEC and self-regulatory organizations, such as the Financial Industry Regulatory Authority. His advice is sought by the leadership of many corporations and organizations on a wide range of issues, such as matters involving the growing use of Artificial Intelligence, blockchain, digital assets and cybersecurity, insider trading policies and procedures, broker-dealer status and registration requirements (particularly Rule 15a-6), investment research, Regulation M, financial responsibility, short-sale regulation, automated trading, sales practice rules, privacy, Regulation ATS, soft dollars, clearance and settlement, credit rating agency regulations, and rules relating to self-regulatory organizations. He also advises on arbitrations, internal investigations, regulatory examinations, and cross-border compliance.
Marlon has represented financial institutions, multinational companies, and senior executives in enforcement proceedings before the SEC, FINRA, the Inter-American Development Bank, and the World Bank.
At the SEC, Marlon served as Senior Special Counsel to the Director of Trading and Markets, where he advised on broker-dealer regulation, market structure, and enforcement strategy. He played a central role in shaping the SEC’s response to the 2008 financial crisis and worked closely with the Division of Enforcement on significant investigations affecting U.S. markets.
Marlon later served as the principal integrity officer of the Inter-American Development Bank, where he led investigations and prosecutions of fraud and corruption matters across multiple jurisdictions. He oversaw integrity due diligence, anti-money laundering, and sanctions compliance programs.
Marlon is an adjunct professor at the University of Pennsylvania Carey Law School and at Georgetown University Law Center. He teaches courses on financial regulation, securities markets, technological developments in the industry, and international business litigation.
Marlon serves on the Council of the American Bar Association Business Law Section and is a Fellow and regional chair of the American Bar Foundation. He previously served as general counsel to the District of Columbia Bar, president of the Hispanic Bar Association of the District of Columbia, and national vice president of the Hispanic National Bar Association.
- California
- Delaware
- District of Columbia
- New York
- Supreme Court of the United States
- J.D., University of Pennsylvania Carey Law School
- LL.M., Georgetown University Law Center
- M.A., Wesleyan University
- B.A., Trinity College
Areas of Work
Representative Matters
Substantive Responsibility with SEC Regulatory Action
- Status as broker-dealer and registration requirements, particularly Rule 15a-6, Exemption of Certain Foreign Brokers or Dealers, 73 FR 39182 (Jul. 8, 2008); Application of the Investment Advisers Act of 1940 to broker-dealers.
- Interpretive/no action request under Regulation ATS.
- Short sale regulation and disclosure of short selling activity by money managers, such as:
- Regulation SHO; Rule 10a-3T and Form SH, 73 FR 61678 (Oct. 17, 2008); short sale price tests.
- Regulation M – Anti-manipulation Rules Concerning Securities Offerings, Rule 105 – Short Selling in Connection with a Public Offering, 71 FR 75002 (Dec.13, 2006).
- Use of soft-dollars by money managers – Commission Guidance Regarding Client Commission Practices Under Section 28(e) of the Securities Exchange Act of 1934, 71 FR 41978 (Jul. 24, 2006).
- Clearance and settlement – The Roundtable on Proxy Voting Mechanics.
- Broker-dealer financial responsibility issues – Rule 15c3-1 (net capital) and Rule 15c3-3 (customer protection); Rules 17h-1T and 17h-2T (risk assessment); prime brokerage; PCAOB registration of broker-dealer auditors.
- Regulations of credit rating agencies – Proposed Rules for Nationally Recognized Statistical Rating Organizations, 74 FR 63866 (Dec. 4, 2009); References to Ratings of Nationally Recognized Statistical Rating Organizations, 74 FR 52374 (Oct. 9, 2009); SEC Roundtable to Examine Oversight of Credit Rating Agencies, 74 FR 17698 (April 16, 2009).
- Insider Trading Policies and Procedures – Section 15(g), Broker-Dealer Policies and Procedures Designed to Segment the Flow and Prevent the Misuse of Material Non-public Information.
- Self-Regulatory Organizations –Commission Guidance and Amendment to the Rules Relating to Organization and Program Management Concerning Proposed Rule Changes Filed by Self-Regulatory Organizations, 73 FR 40144 (July 11, 2008).
Enforcement and Examination
- Certain registered broker-dealers and their executives in an SEC enforcement action charging fraud for failure to provide best execution.
- A large fund manager and its senior executives in an SEC enforcement action alleging that they improperly accepted travel, entertainment, and other gifts from outside broker-dealers courting trading business that the money manager generated on mutual funds' behalf.
- A British trader in an SEC enforcement action alleging insider trading in the United States using derivatives.
- A hedge fund in an SEC enforcement action involving stock options backdating.
- A hedge fund in an SEC enforcement action alleging market manipulation.
- A life insurance company and its senior vice president in an SEC enforcement action for their roles in a late trading and market timing scheme.
- Certain financial professionals in an SEC enforcement action relating to their engaging in a Ponzi scheme.
- A publicly traded Mexican media company and its senior executive in an SEC enforcement action involving fraud, books and record violations, and internal control deficiencies.
- A trader in an SEC enforcement action alleging a fraudulent trading scheme involving inverse floating rate collateralized mortgage obligations.
- A broker-dealer in an SEC enforcement action relating to its involvement in fraud and an unregistered securities offering.
- Represented a public pension fund in class action litigation alleging that a large publicly traded telecommunication company committed fraud.
- Represented a hedge fund in class action securities litigation alleging that a large Italian dairy company committed fraud.
Speaking Engagements
- Decrypting Crypto: Valuation, Due Diligence, and Legal Risks for Lenders, ABA Business Law Section Fall Meeting, American Bar Association, Toronto, Canada, September 18-20, 2025
News & Publications
Media Mentions
Politico Quotes Marlon Paz on Why Tokenization Doesn't Change the Nature of Securities
February 10, 2026
StepTechToe
Toward a National AI Framework: The Federal Strategy to Override State Regulation
December 17, 2025
By: Michelle Castaline, Tyler Evans, Evelyn Hudson, Micaela Hyams, Michelle Kallen, William M. Keyser, Corey D. Laplante, Michele Nellenbach, Marlon Paz, Christopher Suarez, Peyton Thomas
Client Alerts
CFTC Launches Tokenized Collateral and Stablecoins Initiative
October 1, 2025
By: Alan Cohn, Ryan Hayden, Marlon Paz, Alexandra C. Scheibe
Blockchain Blog
The SEC’s Project Crypto Promises to Transform Regulation of US Capital Markets
August 1, 2025
By: Marlon Paz
StepTechToe
The Trump Administration's AI Action Plan: Deregulation and Global Dominance
July 24, 2025
By: Christian M. Auty, Evan T. Abrams, Michelle Castaline, Tyler Evans, Elizabeth Goodwin, Michelle Kallen, William M. Keyser, Michele Nellenbach, Michel Paradis, Marlon Paz, Claire Rajan, Alexandra C. Scheibe, Christopher Suarez, Jack R. Hayes, Peyton Thomas, Ross Weingarten
Blockchain Blog
FinCEN Postponement and Reopening of Investment Adviser AML/CFT Rule
July 21, 2025
By: Marlon Paz, Jack R. Hayes, Evan T. Abrams, Christopher R. Conte, Alan Cohn, Fernando Q. Merino
Blockchain Blog
Deputy Attorney General Memorandum: "Ending Regulation by Prosecution"
April 11, 2025
By: Marlon Paz, Andrew C. Adams, Evan T. Abrams, Galen Kast, Ryan Hayden, Sophia Breggia
Events
Webinars
AI, Data & Digital Roundtable on AI and the Fair Credit Reporting Act
March 11, 2026
Speakers: Christian M. Auty, Stephen J. Newman, Marlon Paz
Webinars
The US AI Agenda Under Trump: Deregulate, Innovate, Dominate
July 31, 2025
Speakers: Evan T. Abrams, Tyler Evans, Jack R. Hayes, William M. Keyser, Michel Paradis, Marlon Paz, Christopher Suarez
Webinars
AI, Data & Digital Roundtable - Artificial Intelligence and the US Securities Markets
July 23, 2025
Speakers: Scott D. Fisher, Marlon Paz
Noteworthy
- Latino Leaders Magazine, Top Latino Lawyers (2020)
- Latino Leaders Magazine, Top 20 Latino Leaders Under 40 (2010)
- Leadership Award, Hispanic National Bar Foundation (2009)
- Hispanic Business Magazine, 100 Most Influential U.S. Hispanics (2008)
- Equal Employment Opportunity Award, US Securities and Exchange Commission (2008)
- Regional President of the Year Award, Hispanic National Bar Association (2006)
Select Publications
- Chapter 6: Secondary Markets, Research Handbook on Securities Regulation in the United States, (Edward Elgar Publishing Ltd, 2014)
- Tracking New Developments in Securities Litigation, New Developments in Securities Litigation (Thomson Reuters/Aspatore, 2013)
Previous Employment
Past Government and Industry Experience
- Senior Special Counsel to the Director of Trading and Markets, US Securities and Exchange Commission
- Principal Integrity Officer, Inter-American Development Bank
- General Counsel, The District of Columbia Bar
Professional Affiliations
- Council, Business Law Section, American Bar Association
- Fellow and Regional Chair, American Bar Foundation
- Past President, Hispanic Bar Association of the District of Columbia (2009)
- Ambassador, Business Law Section, American Bar Association (2006)
Academic Appointments
- University of Pennsylvania Carey Law School (2021 – Present)
- Georgetown University Law Center (2008 – Present)
- UC Berkeley School of Law (2017 – 2018)