The Society for Worldwide Interbank Financial Telecommunication (SWIFT) is a Belgian cooperative society which provides a global messaging system that financial organisations use to transmit information and instructions securely.  In order to ensure those organisations’ cyber security defences are adequate and up to date, SWIFT introduced its Customer Security Programme (CSP).   As part of the CSP, users are required to submit their attestation of compliance with the SWIFT Customer Security Controls Framework (CSCF) and share these with counterparts.

The latest version of CSCF (i.e., v 2022) contains 31 controls (22 mandatory and 9 advisory) which are mapped against recognised international standards, i.e., NIST, PCI DSS and ISO 27002.  These 31 controls are based on 3 objectives; ‘Secure your Environment’, ‘Know and Limit Access’ and ‘Detect and Respond’ and are underpinned by 8 principles.  

Since 2021, members of the SWIFT community have utilised independent assessors as part of their attestation process.  The assessment by the independent assessor must come to the same conclusion as the user’s self-attestation status for all controls.  There are 2 attestation formats,  assessment or audit, and either format is acceptable provided that a risk-based approach is adopted which addresses the user’s risk drivers, in-scope components and meets the stated control objectives.  

As well as acting as your independent assessor, URM can assist you prepare for assessment by conducting a gap analysis so you fully understand your current position and any shortfalls in terms of conformance.  Furthermore, if any gaps are identified, we can help you remediate any areas of non conformance.

Gap Analysis

URM will conduct a review of your current cybersecurity posture against the CSCF requirements and identify any gaps within your controls that need improvement, as well as determining your organisation’s readiness for attestation.  As part of this gap analysis, URM will identify whether you have scoped your controls appropriately and ensure that security is addressed as part of the organisation’s governance activities.  Following the gap analysis, URM will produce a report which will not only detail those areas where your organisation needs to develop or improve your control implementation, but also a prioritised list and recommendations on how to address any gaps.

Implementation Support

Following your gap analysis, URM can help you with any remediation work necessary to improve and maintain your cybersecurity level, including developing, implementing and improving the effectiveness of the CSCF controls.  Any control implementation will be balanced between meeting CSCF requirements and ensuring improvements are in line with your current approach and working practices.

Independent Assessment

This is where URM’s specialist conducts an independent assessment in order to verify your implementation of the CSCF mandatory controls against the criteria of ‘satisfied’, ‘partially satisfied’ and ‘not satisfied’.   URM will assess your policies, processes, and business practices against CSCF requirements through interviews with key stakeholders, documentation review, site visits, and a review of your operations.

Why URM?

Risk management expertise

Since 2002, URM has been developing and refining its risk assessment methodologies and processes to address the requirements of international standards and has developed a suite of purpose-designed risk management software products (Abriska).

Experience and Competence

URM is not only experienced in assisting organisations comply with the SWIFT CSCF, but also with PCI DSS, ISO 27001/ISO 27002 and NIST SP 800-53, the main standards against which the CSCF controls are mapped.  URM has been involved in assisting hundreds of organisations comply with these standards and will ensure you fully leverage any artefacts gained in complying with these standards as part of your CSCF attestation.

Qualified assessors

URM’s assessors have attained the required industry relevant professional certifications, e.g., PCI QSA, ISO 27001 lead auditors, CISA.

Company accreditations

In addition to its 20 years’ experience of delivering practical solutions in the governance, risk and compliance (GRC) space, URM provides reassurance through its own certification to ISO 27001, ISO 22301 and Cyber Essentials Plus, as well as being a CREST-accredited penetration testing organisation.

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URM were super helpful and knowledgeable, talking and walking me through each one of the tests and providing some useful information on security and how to improve things in the future.
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