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Jon Leibowitz

Vice Chairman at Brand Engagement Network
Board

About Jon Leibowitz

Jon Leibowitz (age 67) has served as an independent Class II director of BNAI since 2024 and was appointed Vice Chairman of the Board. He is an Audit Committee member and designated audit committee financial expert, and he chairs both the Nominating & Corporate Governance Committee and the Special Litigation Committee. He holds a J.D. from NYU School of Law and a B.A. from the University of Wisconsin, and previously served as FTC Commissioner (2004–2009) and Chairman (2009–2013). He is Chairman of the National Consumers League and previously was a senior partner at Davis Polk & Wardwell LLP (2013–2021) .

Past Roles

OrganizationRoleTenureCommittees/Impact
Federal Trade Commission (FTC)Chairman2009–2013Led antitrust, consumer privacy, unfair competition policy; focus on pharma and technology industries
Federal Trade Commission (FTC)Commissioner2004–2009Policy leadership on antitrust and consumer protection
Davis Polk & Wardwell LLPSenior Partner (Antitrust)2013–2021Advised on complex antitrust aspects of M&A and investigations
U.S. Senate Subcommittees (Antitrust; Terrorism & Technology; Juvenile Justice)Senior Staff1991–2000Legislative experience in antitrust and technology policy

External Roles

OrganizationRoleTenurePublic Company?
National Consumers LeagueChairman of the BoardCurrentNo (non-profit); Other public company directorships: 0

Board Governance

  • Roles: Vice Chairman; Audit Committee member (financial expert), Chair of Nominating & Corporate Governance Committee, and Chair of Special Litigation Committee .
  • Independence: Board determined Leibowitz is independent under Nasdaq rules; Other public boards: 0 .
  • Committee structure and attendance: In 2024 the Board met 8 times; Audit 4; Compensation 1; Nominating 0. All incumbent directors attended >75% of aggregate Board and committee meetings during their service period in 2024 .
  • Audit Committee status: The Audit Committee currently does not meet Nasdaq/SEC composition requirements (only two members). The Board states it is in process of appointing a third independent director (Ruy Carrasco) to maintain compliance .
  • Special Litigation Committee (SLC): Formed August 15, 2025; composed of independent directors Jon Leibowitz (Chair) and Richard Isaacs with full delegated authority to investigate and manage litigation, including ongoing AFG-related matters; empowered to engage independent counsel and approve settlements .

Fixed Compensation

Item2024 Actual Cash ($)Current Policy / Structure
Annual cash retainer (standard director)$0 (Fees earned or paid in cash shown as “-”) Directors stock ownership guidelines reference an annual cash retainer “currently $45,000” used to set 3x ownership target

Note: The proxy discloses zero cash fees for 2024 and a policy reference to a $45,000 cash retainer used for ownership guidelines, but does not show cash paid in 2024. No separate meeting or committee cash fees are disclosed for 2024 .

Performance Compensation

ComponentDetailValue/Mechanics
2024 non-employee director stock awards (Jon Leibowitz)Total stock awards reported for 2024$116,278; no cash fees; total compensation $116,278
Business Combination initial grant10,000 restricted shares to each director at closingValued at $7.70 per share (ASC 718), per table footnote
12/30/2024 award (service for FY2024)RSUs to each non-employee director under 2023 LTIPAggregate award value $35,000 per director; number determined by 20‑day average ending first trading day of Aug 2024; shares granted 1/2/2025 at $1.07 reference price (per footnote)
Ongoing quarterly director equityRestricted stock, granted in four quarterly installmentsAggregate annual value $45,000; each quarterly grant sized by 20‑day average price before grant date
Annual meeting equityRSUs granted after each annual meetingAggregate value $75,000; vests at next annual meeting or 1 year, whichever earlier
Committee chair and special committee equityAdditional equity for leadership/serviceNon-Exec Board Chair: $50,000; Audit Chair: $20,000; Compensation Chair: $15,000; Nominating Chair: $10,000; Special Committee members: $20,000 (all annual values, delivered quarterly; shares sized by 20‑day average)

Performance metrics: None disclosed for director equity; awards are time-based restricted stock/RSUs with vesting per policy (no TSR/EBITDA/ESG metrics for directors) .

Other Directorships & Interlocks

CategoryCurrent Count / Detail
Public company boards0
Potential interlocks with competitors/suppliers/customersNone disclosed
Notable external governance rolesChairman, National Consumers League

Expertise & Qualifications

  • Audit Committee Financial Expert and financially sophisticated under SEC/Nasdaq rules .
  • Deep antitrust, consumer privacy, and competition policy expertise from FTC leadership and private practice; technology and pharma sector exposure .
  • Legal credentials: J.D. (NYU), B.A. (University of Wisconsin) .

Equity Ownership

MetricAmount
Shares beneficially owned (Leibowitz)76,708
Ownership % of outstanding<1% (asterisk denotes <1%)
Shares outstanding (as of 9/30/2025)44,880,795
Hedging/PledgingProhibited for directors (no hedging, no margin, no pledging)
Stock ownership guidelines3x annual cash retainer within 5 years; directors must retain 50% of net shares until compliant
Compliance statusAs of Oct 1, 2025, all non-employee directors are on track to meet guidelines within required timeframe

Governance Assessment

  • Strengths and investor-alignment signals

    • Independent director designated as audit committee financial expert; Vice Chairman role provides experienced governance leadership .
    • Chairs two key committees (Nominating & Corporate Governance; Special Litigation), positioning him to influence board composition, governance standards, and objective litigation decisions .
    • Equity-heavy director pay (no 2024 cash fees disclosed) increases alignment; robust anti-hedging/pledging policy and 3x ownership guidelines with progress tracking reinforce skin-in-the-game .
  • Risks and red flags

    • Audit Committee non-compliance: Currently only two members; board “in process” of appointing a third independent director. Prolonged non-compliance is a governance risk for financial reporting oversight .
    • Independence inconsistency regarding proposed Audit Committee composition: the proxy states the Board is appointing Dr. Ruy Carrasco as a third “independent” director to maintain compliance, yet an earlier 8‑K disclosed he was not independent under Nasdaq due to employment status—this discrepancy bears monitoring before final committee reconstitution (process and rationale disclosure) .
    • Board vacancies and turnover: Board size set at nine with multiple open seats; recent leadership changes (Chair transition in Aug 2025; director resignation in Sep 2025) may signal governance flux and execution risk during strategic initiatives .
  • Compensation committee process and consultant independence

    • Compensation Advisory Partners engaged for 2024 with no conflict found; company in process of engaging Payscale for 2025; Compensation Committee met independence requirements (1 meeting in 2024) .
  • Litigation risk oversight

    • SLC formed (Aug 15, 2025) with independent directors (Leibowitz Chair) granted full authority to pursue/settle/dismiss litigation, including AFG-related matters; independent counsel authorized—this structure is designed to mitigate conflict risk in litigation decisions .
  • Attendance and engagement

    • All incumbent directors exceeded 75% attendance in 2024 across Board/committee meetings during their service period; Board met 8 times (Audit 4; Comp 1; Nominating 0) .

Overall: Leibowitz brings material regulatory and antitrust expertise, chairs two governance-critical committees, and is designated as an audit committee financial expert—positive for investor confidence. The outstanding Audit Committee compliance gap and conflicting disclosures around the “independence” of a prospective third member should be resolved promptly to avoid ongoing governance risk. Equity-centric director pay and strict trading policies align interests, while SLC independence reduces litigation-related conflict risk .