Do Financial Institutions need a revisit on SWIFT CSP? Common Mistakes & Solutions!
Cyber-attacks are evolving to newer patterns in the digital habitat, and financial entities tend to be the prime mark and most affected. As a result, FIs face massive pressure to shield their customers and network from danger. The rising threats can have critical after-backs if not addressed promptly. Here is where SWIFT Customer Security Program (CSP) makes a crucial difference for the industry.
SWIFT CSP helps financial entities by setting up the required controls adequate to address approaching cyber risks. The 2022 SWIFT Customer Security Controls Framework confines 23 Mandatory and 9 Advisory Controls, directed for the entities to combat newer risk vectors and implement the latest developments in cyber security. However, with this enormity, it is no wonder that many financial entities seem far from staying on top of the implementation.
And through this blog, we help financial entities revisit some of the common mistakes in SWIFT CSP Assessment Compliance and how to address these challenges on the path.
Common missteps made by FI’s in SWIFT Customer Security Program (CSP)
SWIFT requires financial entities to perform an annual assessment using SWIFT Customer Security Controls Framework and attest against the same. Through our years in SWIFT compliance and attestation, here are some of the typical mistakes we have found that the industry faces while looking for successful attestation.
- Unaware of the assessment criticality
What happens if your entity is unaware that you require attestation annually? Probably, you will end up with zero compliance and face many regulatory, financial, and industrial consequences. Entities should be well aware of the changing regulatory norms and conditions, especially in the SWIFT segment, to cope with the transforming threat landscape. Understanding SWIFT Security Framework Controls and aligning them with your business requirements is vital. One way to determine the assessment criticality is to consult the best SWIFT CSP Assessment Providers capable of providing clean advisory for your business requirements.
- Leaving assessment to the later time of the year
Nothing to be taken too lightly as far as cyber security is concerned! Many financial entities consider the assessment process a simple exercise on a straight path and will push it to the verge of the year. Here, they fail to understand how the program help shape their security posture if performed in the early stages. Even though SWIFT has allowed attestations towards the end of the year, entities must consider performing the assessment several months earlier.
The assessing team might also have their timelines of booking that might come into a clash in the later stages.
- Unfit implementation of Customer Security Controls framework
SWIFT Customer Security Control Framework involves 32 controls, and out of that, 23 are mandatory. And what if your financial entity lacks proper knowledge of the particular phase? In fact, you might miss what’s relevant with the control set and incorrectly implements the same. For the situation, financial entities could seek and fetch external support and ensure the appropriate implementation of all the mandatory controls without any falls. The SWIFT CSP Assessment Providers will have the latest information on all the control changes, including the ones added, modified, or deleted as a part of the version changes.
- Facing gaps in the documentation part
Financial organizations often face this challenge in the assessment phase. Entities often believe that they have well-documented processes and procedures and have made it all available for assessment. However, after the review, they understand that unexpected gaps exist in their documentation. They try to patch these identified gaps quickly in a narrow timeframe. That is the root reason that entities must consider the assessment earlier. By doing this, they can have enough time to close the gaps and ensure they go prepared for the following year’s assessment with better documentation in hand.
- Omitting third-party vendors
It is usual to see that a financial entity will have other third-party vendors providing functionalities and supporting or hosting their infrastructure. Any entity using third-party functionalities and relying upon third-party vendors will need to involve them in the assessment. It means getting adequate documents from them and assuring compliance. The process might take time and efficient communication if the vendor is unfamiliar with the compliance procedures. One thing to do here is to get in touch with your third-party suppliers in the earlier stages and provide you with the required documents. A last-minute rush is something that financial firms need to avoid in this aspect of the assessment.
- Not involving all key-groups
The assessment procedure is not a standalone activity performed by the SWIFT team. Financial entities will require the support of many key groups such as their system administrators, network professionals and operations staff to complete their assessment. If not well informed in advance, the approach can be time-consuming as they may not be fully aware of the things required. So getting the support and involvement of all the key groups of your organization is a must for SWIFT Customer Security Program implementation. Training and awareness are other parts you don’t want to miss out on throughout the process.
How to avoid these missteps in SWIFT CSP?
Avoiding these challenges is significant for a successful SWIFT CSP implementation. As pointed out earlier, these are the two things that every financial entity must value to the core to bisect the challenge and move forward.
- Early preparation means easy compliance
Before you start the assessment process, it is vital to keep all your documentation ready and upright. Also, it is significant that entities should have their previous records of used policies procedures in hand. It can help you comprehend what requires for the next assessment phase and what you lack prior to the assessment. Furthermore, communicate well with your stakeholders and partners to keep them involved in the assessment process. Active participation is the key to hold from all ends or groups of your organization. By doing this, you ensure complete compliance within the defined scope.
- Benefiting from external Independent Assessor
The best way to master what is required will be to look for an expert external assessment provider company. Usually, financial institutions lack the in-house capability to deploy adequate security controls and monitor them effectively. In that case, relying on professional hands for a dedicated and customized assessment approach is vital. They can handhold you by providing insights in the documentation phase and help with other procedures to quickly complete your SWIFT assessment. It allows SWIFT experts and auditors to support your entity’s risk and compliance.
ValueMentor – A trusted SWIFT CSP reach out to FI’s
ValueMentor continues to be the top pick for the financial sector to perform its SWIFT CSP assessments with ease, professionalism and experience. The assessment services performed by the team shape up into three phases: –
- SWIFT CSP Gap Assessment
-Performing in-depth gap assessments of SWIFT CSCF controls
-Analysing both mandatory and advisory SWIFT CSP controls
-Furnishing a gap assessment report with the remediation roadmap
- CSCF Remediation
-Providing advisory on the control implementation line with the CSF requirements
-Performing vulnerability assessment and penetration testing for identified SWIFT secure zone
-Providing security monitoring assistance or solution implementation support to meet SWIFT CSP compliance requirements
- SWIFT CSP Attestation
-Conducting annual external SWIFT CSP assessments for the entity’s SWIFT environment
- Compliance Maintenance
-Providing managed compliance program for SWIFT CSP compliance maintenance
-Revalidation and awarding successful SWIFT CSP Attestation.
You can find out more about our solutions capabilities and approach by contacting our SWIFT CSP Team. They can aid you to have quick insights into what latest changes happening around the program and what it means for your entity to stay compliant against the same.