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Checklist: governing technology and artificial intelligence in a Geneva institution

  • Establish an inventory of artificial intelligence applications, classify them by risk and designate a responsible person for each, in accordance with FINMA Guidance 08/2024.
  • Verify data quality, test and validate models before they go live, document their limitations and provide for an independent review.
  • Maintain human responsibility for every decision affecting a client or a regulatory obligation, and document the human intervention.
  • Frame outsourcing to cloud services contractually and technically, notably through encryption and data location, and inform clients.
  • Test operational resilience through outage, attack and vendor-failure scenarios, and report serious cyberattacks within the prescribed deadlines.
  • Prepare for the use of the state electronic identity and of open finance in client onboarding and client services.
  • Train staff in the use and supervision of the tools, and focus recruitment on the skills that the tools do not replace.
  • Monitor the Swiss and European frameworks on artificial intelligence, data protection and operational resilience, together with their effects on clients in the Union.

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of September 2025.

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