James (Jim) Vivenzio counsels financial institutions and other clients on all matters involving examination processes, corporate activities, and regulatory compliance with Bank Secrecy Act/Anti-Money Laundering (BSA/AML), Office of Foreign Assets Control (OFAC), and countering the financing of terrorism (CFT) requirements in his role at Perkins Coie LLP. He also provides guidance on newly implemented and proposed regulations and those resulting from the enactment of the Anti-Money Laundering Act of 2020 (AMLA), including the recent final rule on beneficial ownership reporting requirements and the upcoming revisions to the BSA/AML compliance program rules. He draws on his extensive experience to advise all types of financial institutions and other clients on examination findings (including violations of law and matters requiring attention), examination appeal processes, and the ongoing revisions to the Federal Financial Institutions Examination Council (FFIEC) BSA/AML Examination Manual. Jim also advises individuals as well as legal entity clients on the regulatory enforcement actions, investigations, and look backs that result from these BSA/AML, OFAC, and CFT examinations or investigations.
Jim applies knowledge gained in leadership roles at the U.S. Department of the Treasury’s Office of the Comptroller of the Currency (OCC), including his work on numerous legislative, regulatory, policy, and enforcement matters involving BSA/AML over the course of his 32-year career. He has been involved in numerous significant BSA/AML enforcement actions as well as the development of policy while serving as the OCC’s director for BSA/AML Policy and the OCC’s senior counsel for BSA/AML. Jim was a lead OCC lawyer on some of the largest and most complex BSA/AML, OFAC, and CFT enforcement actions ever taken by the OCC. On the policy side, Jim has participated on U.S. and international task forces addressing issues related to stablecoins, cryptocurrency, digital identity, fintech initiatives, international payments identifiers, cannabis banking, and Financial Action Task Force (FATF), and Financial Stability Board (FSB) initiatives. Jim also served as the co-chair of the Bank Secrecy Act Advisory Group (BSSAG) Subcommittee on Innovation and Technology established under the AMLA and has been an outspoken advocate for modernization and responsible innovation in the areas of BSA/AML, OFAC, and CFT to reduce burdens, increase efficiencies, and provide more robust information to law enforcement. Many of these ideas were implemented by the U.S. Congress in the AMLA.
A frequent speaker on BSA/AML topics, Jim was the recipient of both the OCC Leadership Award (2014), the OCC Shared Purpose Award (2017, 2018), and numerous Special Act Awards.
Jim is a clinical professor for the master’s degree in financial integrity program at the Sandra Day O’Connor School of Law, Arizona State University. He also served as an adjunct professor at the Case Western Reserve University School of Law when it offered this program.
Prior to joining the OCC, Jim was an associate at a leading corporate law firm. He also worked in the New York office of Coopers & Lybrand as a senior auditor before attending law school.
