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Legal Risk Management and Governance Framework for the Use of AI

– Based on the FSA's AI Discussion Paper –

As AI technology advances, financial institutions are adopting AI on an increasing basis, and the establishment of risk management and governance frameworks for the use of AI have become a critical issue. In March 2025, the Financial Services Agency of Japan (FSA) published the “AI Discussion Paper (Version 1.0)” (“Discussion Paper”), which presents an initial set of discussion points to promote the sound use of AI in the financial sector. The Discussion Paper not only highlights potential negative impacts of AI but also points to the “risk of not taking on challenges”—the risk that financial institutions may fall behind in technological innovation and struggle to provide high-quality financial services over the medium to long term. The paper thus encourages proactive use of AI...To read the full article, please see the PDF file

Finance Law & Robotics / Artificial Intelligence Newsletter Download PDF [228 KB]

Authors

福岡 真之介

In the area of Robotics/Artificial Intelligence, Shin Fukuoka mainly handles AI, Big Data and IoT. He acts as a Member of The Cabinet Office’s “Committee on Human-centered AI Social Principles” and Committee Member of the Ministry of Economy, Trade and Industry Investigative Commission on "The AI and Data Contract Guidelines Review Committee". He has also contributed to many publications, including "Law and Strategy of the Internet of Things and Artificial Intelligence", "Artificial Intelligence: Law and Issues" and "Data Contract Law". In the area of Corporate, he mainly handles M&A and Corporate Governance. In the area of Restructuring/Insolvency, he has been involved in numerous restructuring and insolvency cases, with a focus on cross-border insolvency cases, representing both debtor parties and creditor parties. Most recently, he represented Daiichi Chuo Kisen Kaisha and Japan Airlines as a legal counsel of the debtor and Elpida, Takefuji and Mt.Gox as a creditor’s counsel. He has also handled a number of real estate related disputes.

山本 俊之

Since 2009, as an attorney in the firm’s finance team, Toshiyuki has been handling various financial transactions and financial regulatory/compliance matters, with a focus on asset management and derivatives, his main practice areas. He advises both domestic and foreign asset managers, financial institutions, and corporates on financial regulation matters in the asset management and derivatives spaces, as well as on contract drafting, regulatory analyses, and development of internal controls for new product launches. Further, he has been involved in numerous cross-border finance transactions and investment transactions by fund operators. Recently, his practical experience expanded to the FinTech space, such as digital securities, and he has been publishing articles and giving presentations on artificial intelligence/machine learning in relation to finance industries. In addition to finance matters, he has extensive experience in handling regulatory defense matters and foreign class actions in cooperation with foreign law firms. Prior to being registered as an attorney-at-law in 2009 and joining the firm, he worked at a Japanese credit rating agency and the Tokyo arm of a U.S. investment bank as a credit analyst in the securitization space. He is a Certified Member Analyst of the Securities Analysts Association of Japan and a Certified International Investment Analyst.