Architecture review

CAPABILITIES · BANKING & FINTECH

AI in banking and FinTech that meets FINMA's expectations.

Since December 2024, FINMA has expected supervised institutions to adequately identify, assess, manage and monitor the risks of using AI. We build and run the architecture for it in Switzerland and the EU, with a traceable audit trail, and assess the use case in ClearSky.

The typical client

FINMA-supervised banks, licensed FinTechs, asset managers and payment service providers that use or want to use AI, for example to pre-screen alerts, draft client correspondence or search directives and contracts.

What FINMA expects

In its guidance 08/2024 “Governance and risk management when using artificial intelligence”, FINMA set out its expectations. It names operational risks, including model risks such as lack of robustness, correctness and explainability as well as bias, plus data risks, IT and cyber risks, dependence on third parties, and legal and reputational risks. For banks, Circular 2023/1 on operational risks and resilience applies as well.

Traceable audit trail

Every agent action is signed with Ed25519 and stored hash-chained, so any later change can be proven. We use this approach in our own systems. For the supervisor and internal audit this means: who decided what and when, with which model and which data, can be evidenced.

Data location, choice of model and third parties

Processes, data and audit trail live on our platform in the EU or on your own infrastructure. You choose the language model. Every service and every provider used is assessed in ClearSky, so your outsourcing and third-party register is complete.

Payments without card data

For FinTechs and merchants we run PayHub, our billing for subscriptions and one-off payments on a self-hosted Hyperswitch payment router, connected to PostFinance Checkout. Card data never touches our systems; payment happens on the payment provider's page.

What we do not do

We are not a licensing or legal advisory and do not provide core banking or KYC software. We do not promise that FINMA will accept a result. We provide the architecture and the evidence your compliance function can argue with.