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SWIFT Customer Security Programme (CSP)

A Proven and Cost Effective Approach to Compliance

SWIFT Compliance for Building Societies and Banks

We don’t buy into the myth that SWIFT compliance must be expensive, disruptive, or detached from existing audit and assurance work.

Your customers rely on you to move money safely and securely every day. SWIFT plays a central role in that trust - and with rising cyber threats and increasing regulatory expectations, ensuring your SWIFT environment is secure, compliant, and independently assured has never been more important.

We help you meet the SWIFT Customer Security Programme (CSP) requirements cost effectively and with minimum business disruption.

What is the SWIFT CSP?

The SWIFT CSP is a global initiative designed to strengthen cyber security across the SWIFT community. At its core is the Customer Security Controls Framework (CSCF) - a set of mandatory and advisory security controls updated annually and aligned to industry‑standard frameworks.

All firms using SWIFT must complete an independent assessment of their SWIFT environment. SWIFT expects full compliance with the CSCF mandatory controls by 31 December 2026. This can be completed from July onwards each year and leverage existing assurances.

Approach

We take a structured, “no surprises” approach that reduces the burden on your internal team while giving you a clear, evidence‑based path to full compliance.

1. Mobilisation: We begin by understanding your SWIFT setup and wider control landscape. This includes:

Identifying your SWIFT Architecture Type
Agreeing scope, timelines, and stakeholder engagement
Setting out the evidence required for review

We agree with you a pragmatic project plan with defined roles and responsibilities, evidence needed and path to compliance.

2. Assessment: We work closely with your team to assess your controls against the CSCF. Our assessment includes:

Stakeholder interviews
Review of policies, procedures, and existing assurance
Testing of key controls
Live progress updates so you always know where you stand

Our focus is on control clarity, risk mitigation and practical insight to address any gaps.

3. Reporting and Attestation: We provide a complete, independent view of your compliance position, including:

Confirmed compliance status for each control
Pragmatic recommendations tailored to a building society or bank environment
A prioritised improvement roadmap
Benchmarking against peers to help you understand your position in the sector

Where exceptions exist, we help identify compensating controls or test remediated fixes to support your final attestation.

Why choose Green Dolphin

Sector‑specific expertise: We understand the operational realities and regulatory expectations facing building societies, banks, fintechs and PSPs.
Pragmatic, resource‑light delivery: Designed to minimise disruption to your team.
Clear, actionable outputs: No jargon, no noise, just what you need to achieve compliance.
Trusted assurance: Supporting your annual attestation with evidence that SWIFT, regulators and auditors expect to see.

Referenceable - Just Ask Us

Please let us put you in touch with your peers at other building societies and banks so you can hear first hand how we've helped them achieve compliance.

Typical Green Dolphin Effort

2 to 4 days (Architecture Type B - Mostly Outsourced)

2 to 4 days (Architecture Type A4 - Service Bureau)

3 to 6 days (Architecture Type A1 - Direct Connection and Locally Hosted)

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Case Study

SWIFT CSP Compliance Achieved

Challenge

A Building Society needed to complete its annual SWIFT Customer Security Programme (CSP) assessment. With a small internal team and multiple regulatory priorities running in parallel, they were concerned about the time, cost, and disruption typically associated with SWIFT reviews. They also wanted assurance that the assessment would not simply “tick the box,” but provide meaningful insight into their wider cyber and operational resilience posture.

Approach

We took a streamlined, evidence‑led approach designed to minimise effort for the internal team. Rather than starting from scratch, we leveraged the Building Society’s existing audit and assurance reports, penetration testing results, policy reviews, and operational resilience assessments. This allowed us to focus only on the areas where additional testing or clarification was genuinely needed.

Our work included targeted stakeholder interviews, review of existing assurance, and light‑touch validation of key controls. Throughout the assessment, we provided live progress updates and early visibility of any emerging gaps, ensuring there were no surprises at the end.

Importantly, we didn’t limit our view to SWIFT alone. By analysing the broader control environment, we identified opportunities to strengthen cyber security, improve monitoring, and enhance resilience processes that extended well beyond the SWIFT footprint.

Outcome

The Building Society achieved a clear, independently validated compliance position with minimal disruption to its team. By re‑using existing assurance and focusing effort where it mattered most, the assessment was completed efficiently and ahead of schedule.

Management received not only the required SWIFT attestation evidence, but also a set of practical, prioritised recommendations that improved their wider security and resilience posture. This gave them confidence in their SWIFT environment and strengthened their overall operational resilience narrative for regulators, auditors, and the Board.

Green Dolphin TCCR provides SWIFT accreditation and SWIFT certification in building societies.

SWIFT Customer Security Programme (CSP)

A Proven and Cost Effective Approach to Compliance

Referenceable - Just Ask Us

Case Study

SWIFT CSP Compliance Achieved

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