Approaching the SWIFT Customer Security Programme – 5 Expert Tips from Independent CSP Assessors

As the halfway of 2022 approaches, both financial and non-financial organizations using the SWIFT network are rushing to understand the new changes to the framework and adapt to them. But that’s just half the job.

Yes, all member organizations need to adopt the latest version of SWIFT’s security frameworks. However, they also need an impartial assessment by an independent assessor to ensure they’re meeting all compliance requirements.

And this needs to be done before the end-of-the-year December deadline! If you haven’t started yet, don’t panic. There’s still time to get it done right. Read on to find out how.

Why is CSP important?

Before we dive into the SWIFT Customer Security Programme process, you may still be wondering what exactly CSP is and how it impacts your organization.

SWIFT is a leading global messaging network that enables financial institutions to send and receive information. It helps organizations conduct secure and efficient monetary transactions worldwide. The SWIFT network has already processed over three billion financial messages in 2022—averaging around five billion each year. Suffice it to say, SWIFT helps keep the wheels of the global banking system turning. And SWIFT takes its responsibility to ensure the safe and secure movement of financial messaging globally very seriously. After all, when there are quite literally millions on the line with each transaction, security is critical.

SWIFT launched its CSP security framework in 2016 to fulfill that purpose. The CSP security framework, as an evolving framework that keeps up with emerging global cyberthreats, ‘raises the bar’ of cyber-security hygiene across all users, reduces the risk of cyber-attacks, and minimizes the financial impact of fraudulent transactions. This is achieved by mandatory and advisory security controls, initiatives, and features that all SWIFT member institutions must comply with to continue using and benefiting from the SWIFT rails. The Customer Security Controls Framework (CSCF) under the CSP has continually evolved over the years. For example, it has evolved from 27 controls in 2017 to 32 controls in the 2022 version. And with every year’s framework, more updates are added to ensure that emerging threats and potential risks are considered. Every SWIFT member is given 18 months to understand, implement the latest CSCF controls, and conduct an independent assessment to confirm their compliance.

Completing the SWIFT CSP assessment may not seem like a priority amidst the constantly changing industry-wide financial security initiatives and regulatory demands you have to adhere to – but trust us, it is. Not only is compliance with SWIFT CSP the key to securing your organization from cybercrime and financial fraud, but a failure to do so can result in your organization being reported to the authorities and noncompliance exposure on SWIFT portals. Without the correct CSP assessor’s assistance and guidance, your organization can be exposed to security and reputational risks.

Getting SWIFT CSP done right

As of 2021, all SWIFT members need to adhere to the latest SWIFT CSP framework and require performing a Community Standard Assessment to show their level of compliance. While attestations can be performed internally, external assessors with certified cybersecurity credentials and SWIFT expertise bring professionalism to the assessment. They bring SWIFT CSP readiness to each architectural type within the operating environment. By covering all CSP framework’s architectural types, external assessors review remediation plans and offer assistance for timely attestation.

And as the SWIFT v2022 framework deadline fast approaches, engaging Axletree SWIFT CSP assessors can save you both money and time.

5 tips to ensure timely compliance with CSP 2022

As a SWIFT-listed CSP assessment provider, we’ve reached out to our team of experts for some of the most insightful tips that can get financial and non-financial organizations up-to-speed on the latest SWIFT CSP requirements.

1. Sooner is always better than later

While it’s true that SWIFT gives its members 18 months to comply with the newest version of its CSP controls and gain attestation through the KYC portal. However, if you start the process too close to the time limit, you’ll have to juggle other potential deadlines, such as SWIFT’s ISO 20022 migration and your end-of-year regulatory audits and reports.

Starting the assessment process early leaves ample time for a thorough assessment and room for any post-assessment remedial action.

2. External assessments are better for business

Although the mandatory CSP assessment is required to be independent, it doesn’t necessarily have to be conducted by an external party. It can be performed by the organization’s second or third line of defense, such as internal auditors, a risk office, or a tailored independent team of assessors.

Whoever does the assessment should be an industry security certified professional with cybersecurity assessment experience and expertise. External assessments are also a better option as it can be difficult to avoid a conflict of interest (COI) when opting for an internal assessment. And even if the internal team meets the experience, expertise, and independence prerequisites, the in-house team ends up dedicating significant time and resources to completing the assessment according to SWIFT standards.

It’s always a better idea to hire an external team of SWIFT CSP assessment providers. In the case of Axletree, the cybersecurity experts have amassed considerable SWIFT network and components expertise.

3. Collaboration gets things moving faster

The time it takes to complete the SWIFT CSP assessment depends significantly on the professional expertise of the assessors and the level of collaboration the hiring institution is willing to offer. In addition to planning a timely assessment, the ease of communication between the client and the CSP assessors can determine the smooth, timely, and cost-efficient completion of the assessment process.

4. Hire someone that will go beyond a simple assessment

Performing a SWIFT CSP assessment does not automatically mean compliance with all controls outlined in the CSCF. Make sure you hire a team of assessors who are familiar with the CSP framework and all its requirements. These experts are best placed to identify compliance gaps and provide post-assessment support, if necessary, to ensure that you meet the SWIFT CSP attestation deadline.

5. It’s always smarter to plan ahead

To avoid unforeseen hiccups in implementation and CSP compliance, it’s important to plan and start reviewing the latest CSP version as soon as it’s released.

To that end, SWIFT CSP 2022 was published last year with critical changes in security controls and protocols. The deadline to complete the assessment and retain your SWIFT compliant status is at the end of 2022. Planning a timely assessment ensures that you meet all framework requirements.

As a SWIFT-listed CSP assessment provider, the experts at Axletree can partner with your organization to provide remediation advice to ensure that you meet all CSP framework requirements on time and within budget.

Get in touch with us at Contact us to learn more about the latest SWIFT CSP requirements and what it means for your organization.

May 27, 2022

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