Swift CSP-Assessor - Customer Security Programme Assessor Certification(CSPAC)

Alliance Gateway (SAG) is a SWIFT product that facilitates connectivity between messaging interfaces and the SWIFT network. Let’s evaluate the statement:

•A messaging interface in SWIFT terminology refers to applications like Alliance Access (SAA) or Alliance Entry, which are responsible for creating, validating, and processing SWIFT messages (e.g., FIN MT messages). These interfaces handle the business logic of message flows, interfacing with back-office systems and preparing messages for transmission.

•Alliance Gateway, however, is classified as a communication interface. It acts as a hub to consolidate message flows from multiple messaging interfaces (e.g., Alliance Access) and connects them to the SWIFT network via SwiftNet Link (SNL). SAG does not create or process messages; it manages their transport, ensuring secure transmission over the SWIFT Secure IP Network (SIPN). This distinction is clear in SWIFT documentation, where SAG is described as a connectivity layer, not a messaging interface.

•The CSCF reinforces this separation by applying specific controls to messaging interfaces (e.g., "2.1 Internal Data Transmission Security" for Alliance Access) and communication interfaces (e.g., "1.1 SWIFT Environment Protection" for SAG). Since SAG does not perform the functions of a messaging interface, the statement is false.

Summary of Correct Answer:

Alliance Gateway is a communication interface, not a messaging interface, making the statement false.

References to SWIFT Customer Security Programme Documents:

•SWIFT Customer Security Controls Framework (CSCF) v2024: Differentiates messaging interfaces (Control 2.1) from communication interfaces (Control 1.1).

•SWIFT Alliance Gateway Documentation: Describes SAG as a communication interface for SWIFTNet connectivity.

•SWIFT Architecture Glossary: Clarifies the roles of messaging interfaces (e.g., Alliance Access) versus communication interfaces (e.g., Alliance Gateway).

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Verifying the applicability of a CSCF control to a specific component involves consulting relevant SWIFT documentation and processes. The "Swift Customer Security Controls Framework v2025" and associated guidelines provide the framework for this determination. Let’s evaluate each option:

•Option A: Check in the CSP Policy document

This does not apply. The "Swift Customer Security Controls Policy" is a high-level document outlining the CSP’s objectives and requirements but does not provide detailed guidance on control applicability to specific components. Control applicability is determined by the CSCF itself (e.g., through appendices or the control matrix), not the policy document, which is more strategic than operational.

•Option B: Check appendix F of the CSCF

This applies. Appendix F of the CSCF (or a similar appendix in the v2025 version) typically includes guidance on control applicability, mapping controls to different architecture types and components. This is a standard action for assessors, as noted in the "Independent Assessment Process for Assessors Guidelines."

•Option C: Check carefully the Introduction section of the CSCF

This applies. The Introduction section of the CSCF provides an overview of the framework’s scope, objectives, and how controls apply to various components, making it a relevant resource for verification.

•Option D: Open a case with SWIFT support via the case manager on swift.com if further information or solution cannot be found in the documentation

This applies. If documentation does not resolve the applicability question, SWIFT support via the case manager on swift.com is a recognized escalation path, as outlined in the "Independent Assessment Framework" and SWIFT operational guidelines.

Summary of Correct Answer:

Checking the CSP Policy document (A) does not apply, as it is not the appropriate resource for verifying control applicability to specific components.

References to SWIFT Customer Security Programme Documents:

•Swift Customer Security Controls Framework v2025: Provides applicability guidance in appendices (e.g., Appendix F) and the Introduction.

•Independent Assessment Process for Assessors Guidelines: Recommends using CSCF appendices and support channels.

•CSP_controls_matrix_and_high_test_plan_2025: Supports control applicability analysis.

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The "Swift Customer Security Controls Policy" and "Independent Assessment Framework" outline the consequences of non-compliance with the CSP. Let’s evaluate each option:

•Option A: To be reported to their supervisors (if applicable)

This does not apply. Non-compliance is managed by SWIFT, not internal reporting to supervisors, unless specified by the user’s internal governance (not a CSP requirement).

•Option B: To be seen as non-compliant to their counterparts in KYC-SA

This applies. Non-compliance is reflected in the KYC-SA portal, where counterparties can view the user’s status, impacting trust and business relationships, as per the "Independent Assessment Framework."

•Option C: To be contacted by SWIFT to provide the CSP assessment report and detailed information about the reason of non-compliance

This applies. SWIFT engages with non-compliant users, requesting assessment reports and remediation plans, as outlined in the "Swift_CSP_Assessment_Report_Template" and "Independent Assessment Process for Assessors Guidelines."

•Option D: To be delisted from the BIC directory

This does not apply. Delisting is an extreme measure not automatically triggered by non-compliance; it requires persistent failure to remediate after engagement, which is not guaranteed.

Summary of Correct Answers:

Possible impacts include being seen as non-compliant in KYC-SA (B) and being contacted by SWIFT for reports (C).

References to SWIFT Customer Security Programme Documents:

•Independent Assessment Framework: Details non-compliance impacts.

•Swift_CSP_Assessment_Report_Template: Supports SWIFT follow-up.

•CSP_controls_matrix_and_high_test_plan_2025: Reflects KYC-SA visibility.

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The "Independent Assessment Process for Assessors Guidelines" governs the conduct of CSP assessments, including location and method. Let’s evaluate each option:

•Option A: Remote assessments are not permitted under any circumstances

This is incorrect. The CSP allows remote assessments under specific conditions, as clarified in the guidelines, not an absolute prohibition.

•Option B: This is permitted provided the same level of comfort can be guaranteed

This is incorrect. While ensuring equivalent assurance is important, the CSP requires formal validation for remote assessments, not just assessor discretion.

•Option C: It is possible to perform an assessment remotely only with valid reasons. These reasons must be formally validated by SWIFT CSP office

This is correct. The "Independent Assessment Process for Assessors Guidelines" permits remote assessments when justified (e.g., geographical distance, logistical challenges), but such arrangements must be approved by the SWIFT CSP office to ensure compliance and security. This aligns with the "Independent Assessment Framework" emphasis on maintaining assessment integrity.

•Option D: It is not allowed to conduct an assessment remotely under any circumstances. However, force majeure circumstances like the global pandemic are an exception to this

This is incorrect. The CSP does not categorically ban remote assessments; it allows them with prior validation, not just as exceptions for force majeure.

Summary of Correct Answer:

Remote assessments are permitted with valid reasons and formal validation by the SWIFT CSP office (C).

References to SWIFT Customer Security Programme Documents:

•Independent Assessment Process for Assessors Guidelines: Allows remote assessments with approval.

•Independent Assessment Framework: Ensures assessment integrity.

•CSP_controls_matrix_and_high_test_plan_2025: Supports validated remote methods.

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The "SWIFT footprint" refers to the extent of SWIFT-related infrastructure (hardware, software, and connectivity components) that a user must manage within their environment. A smaller footprint means less local infrastructure to maintain, typically achieved through cloud-based or managed services. Let’s evaluate each option:

•Option A: Full stack of products up to the Messaging Interface

This refers to an on-premises deployment where the user manages a complete set of SWIFT components, including the messaging interface (e.g., Alliance Access), communication interface (e.g., Alliance Gateway), SwiftNet Link (SNL), HSM, and VPN boxes for connectivity to the SWIFT network. This setup requires significant local infrastructure, including servers, security devices, and network components, resulting in a large SWIFT footprint.

•Option B: Alliance Remote Gateway

Alliance Remote Gateway (ARG) is a service where the Alliance Gateway is hosted remotely by SWIFT or a third party, but the user still maintains a messaging interface (e.g., Alliance Access) locally. While this reduces the footprint slightly by outsourcing the communication interface, the user still manages the messaging interface, HSM, and local connectivity components, resulting in a moderate footprint.

•Option C: Lite 2 or Alliance Cloud

This is the correct answer. Alliance Lite2 and Alliance Cloud are cloud-based solutions designed for smaller institutions or those seeking a minimal local footprint. In Alliance Lite2, the user connects to SWIFT via a lightweight client (Alliance Lite2 AutoClient) or a browser-based interface, with most infrastructure (e.g., messaging interface, communication interface, HSM) hosted by SWIFT in the cloud. Alliance Cloud similarly hosts the full SWIFT stack (including Alliance Access and Alliance Gateway) in a SWIFT-managed cloud environment, requiring only minimal local infrastructure (e.g., a secure connection to the cloud). This results in the smallest SWIFT footprint, as the user manages very little on-premises infrastructure. The CSCF still applies, but many controls are managed by SWIFT (e.g., "1.1 SWIFT Environment Protection").

•Option D: A user with a Messaging Interface behind a Service Bureau

A Service Bureau is a third-party provider that hosts SWIFT infrastructure (e.g., Alliance Gateway, SNL) for multiple users, but the user still maintains a local messaging interface (e.g., Alliance Access) to connect to the Service Bureau. This setup reduces the footprint compared to a full on-premises deployment, as the user does not manage the communication interface or network connectivity components. However, the local messaging interface and associated security components (e.g., HSM) still constitute a larger footprint than a fully cloud-based solution like Alliance Lite2 or Alliance Cloud.

Summary of Correct Answer:

Alliance Lite2 or Alliance Cloud (C) has the smallest SWIFT footprint, as most infrastructure is hosted in the cloud by SWIFT, minimizing the user’s local management responsibilities.

References to SWIFT Customer Security Programme Documents:

•SWIFT Customer Security Controls Framework (CSCF) v2024: Control 1.1 applies to cloud deployments like Alliance Cloud, reducing the user’s local footprint.

•SWIFT Alliance Lite2 Documentation: Describes the minimal infrastructure required for Lite2 users.

•SWIFT Alliance Cloud Documentation: Highlights the fully hosted nature of the solution, minimizing the SWIFT footprint.

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The "Independent Assessment Framework" and "Independent Assessment Process for Assessors Guidelines" mandate that CSP assessments and attestations be conducted by an independent, certified assessor, not the user’s internal audit department. Let’s evaluate each option:

•Option A: Yes, providing this is agreed by the head of IT operations and the CISO

This is incorrect. Internal agreement does not override the CSP’s requirement for independence.

•Option B: No, this is never an option

This is correct. The CSP prohibits internal audit departments from submitting or approving attestations on the KYC-SA portal, as they lack the independence required by the "Independent Assessment Framework." Only an external, certified assessor can perform and approve the assessment, with the CISO or designated user submitting the attestation based on the assessor’s report.

•Option C: Yes, an internal auditor can submit the attestation for approval provided they have the appropriate credentials for swift.com. The CISO remains in charge of the approval of the attestation

This is incorrect. Internal auditors cannot submit or approve attestations, even with credentials, due to the independence requirement.

•Option D: Yes, with approval from the Chief Auditor

This is incorrect. Chief Auditor approval does not satisfy the CSP’s independence mandate.

Summary of Correct Answer:

An internal audit department cannot submit or approve the attestation (B).

References to SWIFT Customer Security Programme Documents:

•Independent Assessment Framework: Requires independent assessors.

•Independent Assessment Process for Assessors Guidelines: Prohibits internal assessments for attestation.

•Swift_CSP_Assessment_Report_Template: Specifies external assessor input.

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The SWIFT CSP requires a consistent and independent assessment process, as specified in the "Independent Assessment Framework" and "Independent Assessment Process for Assessors Guidelines." Let’s evaluate each option:

•Option A: Yes, a SWIFT user can combine multiple assessment types (internal and external assessment) as long as all controls are covered

This is incorrect. The CSP mandates that the assessment be conducted by a single, independent assessor or firm to ensure uniformity and objectivity. Mixing internal audits (which lack independence) with external assessments does not meet the requirement, as per the "Independent Assessment Framework."

•Option B: No, because the SWIFT user cannot be sure the same approach and quality will be delivered

This is incorrect as the primary reason. While consistency is a concern, the main issue is the lack of independence, not just quality variation.

•Option C: Yes, but only if there is a signed agreement between all involved assessors

This is incorrect. A signed agreement does not resolve the CSP’s requirement for a single independent assessment. The "Independent Assessment Process for Assessors Guidelines" does not allow hybrid assessments.

•Option D: No, SWIFT can reject the attestation in such situations

This is correct. SWIFT reserves the right to reject attestations if the assessment process does not comply with the requirement for a fully independent assessment by a certified assessor. The "Swift_CSP_Assessment_Report_Template" and "CSCF Assessment Completion Letter" must reflect a single, consistent evaluation, and the "Independent Assessment Framework" explicitly prohibits reliance on internal audits for compliance attestation.

Summary of Correct Answer:

This approach is not acceptable, and SWIFT can reject the attestation (D).

References to SWIFT Customer Security Programme Documents:

•Independent Assessment Framework: Requires a single independent assessor.

•Independent Assessment Process for Assessors Guidelines: Prohibits mixed assessment types.

•Swift_CSP_Assessment_Report_Template: Reflects a unified assessment process.

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This question addresses the obligations of Swift users regarding the submission of assessment-related documents to Swift under the Customer Security Programme (CSP).

Step 1: Understand CSP Assessment Submission Requirements

TheSwift Customer Security Controls Framework (CSCF) v2024and theIndependent Assessment Frameworkoutline the process for CSP assessments, including what must be submitted to Swift. The focus is on ensuring compliance through attestation, with specific deliverables defined.

Step 2: Evaluate Each Option

A. Yes, all documents produced from the assessment must be provided proactively to SwiftThis is incorrect. TheIndependent Assessment Frameworkdoes not require proactive submission of all assessment documents (e.g., detailed reports, working papers). Only the completion letter and attestation are typically submitted unless otherwise requested by Swift.Conclusion: Incorrect.

B. No, it is not required to provide Swift with any documents by default. However, Swift can request a copy of the Assessment completion letterTheCSCF v2024andIndependent Assessment Frameworkstate that users are not required to proactively submit the full assessment report or other documents. However, Swift retains the right to request the completion letter (certifying assessment completion) or additional evidence during quality assurance reviews. This aligns with theSwift CSP Compliance Guidelines.Conclusion: Correct.

C. Yes, a copy of (only) the assessment report must be provided to Swift, no other documentsThis is incorrect. The full assessment report is not mandated for proactive submission; only the completion letter is typically required unless requested. TheIndependent Assessment Frameworkemphasizes the completion letter as the key deliverable.Conclusion: Incorrect.

D. Yes, in cases where a customer performs an Independent assessment rather than an audit then a copy of the assessment report must be provided. However, it is not required for the Swift user to provide any forms when an Internal/External Audit is performedThis is partially misleading. TheIndependent Assessment Frameworkdoes not distinguish between independent assessments and audits in terms of mandatory report submission. For both, the completion letter is the default submission, with reports requested only if needed. The differentiation based on assessment type is not supported byCSCF v2024guidelines.Conclusion: Incorrect.

Step 3: Conclusion and Verification

The correct answer isB, as theCSCF v2024andIndependent Assessment Frameworkdo not require proactive submission of the full assessment report, but Swift can request the completion letter as part of its oversight process.

References

Swift Customer Security Controls Framework (CSCF) v2024, Section: Independent Assessment Requirements.

Swift Independent Assessment Framework, Section: Deliverables and Submission.

Swift CSP Compliance Guidelines, Section: Document Submission Rules.

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This question identifies which operator session flows must be protected for confidentiality and integrity under theSwift Customer Security Controls Framework (CSCF) v2024.

Step 1: Understand Session Protection Requirements

TheCSCF v2024, underControl 2.4: Secure Session Management, mandates that all sessions involving access to Swift-related components or secure zones must be protected using strong encryption (e.g., TLS) and integrity controls to prevent unauthorized access or data tampering. This applies to operator and administrator sessions interacting with the Swift environment.

Step 2: Evaluate Each Option

A. System administrator sessions towards a host running a Swift related componentAdministrator sessions to hosts running Swift components (e.g., Alliance Access, Gateway) are in scope, as they require protection perControl 2.4to ensure confidentiality and integrity of administrative actions.Conclusion: Correct.

B. All sessions to and from a jump server used to access a component in a secure zoneJump servers are used to access secure zones (perControl 1.1: Swift Environment Protection), and all sessions to and from them must be encrypted and integrity-protected, as specified inControl 2.4.Conclusion: Correct.

C. All sessions towards a secure zone (on-premises or hosted by a third-party or a Cloud Provider)Secure zones, whether on-premises or hosted (e.g., by outsourcing agents or cloud providers), contain Swift components and must have all incoming sessions protected perControl 2.4andControl 1.1.Conclusion: Correct.

D. All sessions towards a Swift related application run by an Outsourcing Agent, a Service Bureau or an L2BA ProviderSessions to Swift-related applications managed by outsourcing agents or service bureaus (e.g., Components C, D, E in the diagram) are in scope, as they handle Swift traffic and must be secured perControl 2.4and theSwift Outsourcing Guidelines.Conclusion: Correct.

Step 3: Conclusion and Verification

All options (A, B, C, D) are correct, asControl 2.4of theCSCF v2024requires protection of all listed session types to ensure confidentiality and integrity across the Swift ecosystem, including secure zones, hosted environments, and outsourced applications.

References

Swift Customer Security Controls Framework (CSCF) v2024, Control 2.4: Secure Session Management, Control 1.1: Swift Environment Protection.

Swift Security Best Practices, Section: Session Security.

Swift Outsourcing Guidelines, Section: Session Protection.

This question asks whether a Swift user can implement security controls (e.g., logging and monitoring) in systems not directly in scope of the CSCF. Let’s analyze this based on Swift CSP guidelines.

Step 1: Define CSCF Scope and Security Controls

TheSwift Customer Security Controls Framework (CSCF) v2024defines its scope as the Swift-related infrastructure, including messaging interfaces, communication interfaces, and operator systems (asdetailed in Question 4). Security controls likelogging and monitoringare mandated underControl Objective 6: Detect Anomalous Activity, specifically in controls likeControl 6.1: Security Event Logging.

Step 2: Analyze the Question

The question focuses on whether a Swift user can apply CSCF security controls (e.g., logging and monitoring) to systemsnot directly in scopeof the CSCF. Systems not in scope include back-office systems, general-purpose servers, or other infrastructure that does not directly process Swift messages or connect to the Swift network.

Step 3: Evaluate Swift CSP Guidance

The CSCF mandates that security controls must be applied to in-scope systems to ensure the security of the Swift environment. However, Swift also encourages adefense-in-depthapproach, as outlined in theSwift Customer Security Programme – Security Best Practices. This approach recommends extending security practices beyond the minimum scope to enhance overall security.

Control 6.1: Security Event Loggingrequires logging and monitoring for in-scope systems to detect anomalous activity. While this control is mandatory for in-scope systems, the CSCF does not prohibit applying similar controls to out-of-scope systems. In fact, theSwift CSP FAQ(available on swift.com) clarifies that users may implement additional security measures on out-of-scope systems to reduce risks to the Swift environment (e.g., monitoring back-office systems that interact with Swift middleware).

Implementing logging and monitoring on out-of-scope systems can help detect threats that might indirectly affect the Swift environment, such as lateral movement from a compromised back-office system to a Swift-related system.

Step 4: Conclusion and Verification

A Swift usercanchoose to implement security controls like logging and monitoring on systems not directly in scope of the CSCF. This is not mandatory but is considered a best practice under Swift’s defense-in-depth strategy. The CSCF does not restrict users from applying additional security measures beyond its defined scope, and such actions align with the broader goal of enhancing cybersecurity across the user’s environment.

References

Swift Customer Security Controls Framework (CSCF) v2024, Control 6.1: Security Event Logging.

Swift Customer Security Programme – Security Best Practices, Section: Defense-in-Depth.

Swift CSP FAQ, Section: Scope and Applicability of Security Controls.