Associate General Counsel, Artificial Intelligence

The AI Associate Counsel will serve as a subject matter expert on legal and regulatory issues related to the use of artificial intelligence (AI) by Vanguard. This role combines deep legal expertise with a strong understanding of emerging technologies and business objectives to manage legal risk while enabling responsible AI adoption across investment, operations, and client-facing functions.

Key Responsibilities:

Regulatory & Compliance Oversight

• Interpret and synthesize cross-jurisdictional legal advice re: AI laws and regulations and their impact on Vanguard's business activities and operations ((e.g., EU AI Act, Colorado AI Act).
• Serve as Legal's subject matter expert ("SME") on requirements under Vanguard's Enterprise AI Governance Policy and related policies, standards, and procedures.
• Collaborate with and advise senior managers to help set the strategy for AI adoption, including whether and under what circumstances Vanguard should develop AI Systems subject to these requirements.
• Develop and maintain AI governance frameworks and "guardrails" for the responsible use of AI Systems, ensuring compliance with applicable legal and regulatory requirements, as well as Vanguard's policies and AI Ethics Principles.
• Monitor, analyze, and respond to legislative and regulatory developments relevant to the development and use of AI Systems, particularly those related to financial services and asset management.

• Develop standardized contract templates and terms related to AI in vendor agreements; review and negotiate contracts with AI vendors, focusing on data usage, IP rights, liability, and indemnification clauses.
• Ensure third-party AI tools meet firm standards for security, ethics, and regulatory compliance.

• Participate in Enterprise AI System review process to identify, mitigate, and document key risks and considerations related to AI Systems; Advise Enterprise stakeholders, including Risk and IT, on legal considerations tied to proposed use of AI Systems
• Partner with Legal and Compliance stakeholders on AI System capabilities, and assist in their efforts to account for Division-specific risks and obligations
• Implement controls for AI model training, data governance, and algorithmic transparency.

• Draft and update internal policies on AI procurement, development, and acceptable use.
• Advise on procedures that will operationalize Enterprise AI Govern ance Policy and related Policies.
• Conduct periodic reviews of AI-related practices to identify gaps and align with evolving regulations.

• Work closely with IT, Divisional Legal and Compliance representatives and others to integrate AI responsibly into products and services.
• Provide training and guidance to internal stakeholders on legal implications of AI adoption.

• Education: J.D. degree and active bar membership in relevant jurisdiction.
• Minimum 10 years in technology law, preferably within financial services or asset management.
• Familiarity with AI governance, data protection laws, and financial regulations.
• Strong understanding of AI technologies, machine learning concepts, and their application in investment management.
• Excellent drafting, negotiation, and analytical skills.
• Ability to translate complex technical issues into clear legal guidance.

• Knowledge of AI ethics frameworks and responsible AI principles.
• Experience with legal tech platforms (e.g., HarveyAI, Kira Systems, LawGeex).
• Comfort working in a fast-paced, innovation-driven environment.