CSCF Control 2.9 (Transaction Business Controls) requires institutions to implement measures to ensure the accuracy and integrity of SWIFT transactions (e.g., payment validation, authorization). Compliance can be achieved through various methods, as outlined in the "Swift Customer Security Controls Framework v2025" and its implementation guidelines. Let’s evaluate each option:
•Option A: More than one of the measures proposed in the implementation guidelines are implemented
This ensures compliance. The CSCF provides implementation guidelines for Control 2.9, suggesting measures like dual authorization or automated validation. Implementing multiple measures meets the control’s objective of ensuring transaction integrity.
•Option B: A customer-designed implementation that encounters the control objective and addresses the risk driver
This ensures compliance. The CSCF allows flexibility for customer-designed solutions, provided they meet the control objective (e.g., preventing fraudulent transactions) and address the identified risk drivers (e.g., human error), as validated in the "Assessment template for Mandatory controls."
•Option C: Reliance on a recent business assessment or regulator response confirming effectiveness of the existing control
This ensures compliance. If a recent assessment (e.g., by an internal audit or regulator) confirms that existing controls effectively meet the CSCF 2.9 requirements, this can be accepted as evidence of compliance, per the "Independent Assessment Framework."
•Option D: Any implementation if approved by the CIO
This does not ensure compliance. The Chief Information Officer (CIO) approval alone does not guarantee that the implementation meets CSCF requirements. Compliance must be based on objective evidence and alignment with the control’s intent, as assessed against the "CSP_controls_matrix_and_high_test_plan_2025" and validated by an independent assessor, not just internal approval.
Summary of Correct Answer:
Reliance on CIO approval alone (D) does not ensure compliance with CSCF 2.9.
References to SWIFT Customer Security Programme Documents:
•Swift Customer Security Controls Framework v2025: Control 2.9 and implementation guidelines.
•Independent Assessment Framework: Requires objective validation, not just CIO approval.
•Assessment template for Mandatory controls: Specifies evidence-based compliance.
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