In the case that nothing has changed in the SWIFT user’s infrastructure, is it possible...

The "Independent Assessment Framework" and "Independent Assessment Process for Assessors Guidelines" govern the frequency and reliance on previous assessments. Let’s evaluate each option:

•Option A: Yes, full reliance can be provided without the need of an independent assessment if nothing has changed

This is incorrect. The CSP requires an annual independent assessment, even if no changes occur, to verify ongoing compliance, as per the "Independent Assessment Framework."

•Option B: No, even if nothing has changed, an independent assessor needs to assess the conditions before being able to rely on the previous year’s assessment

This is correct. While the previous report can be used as a baseline, the assessor must perform a review (e.g., walkthroughs, spot checks) to confirm no changes or degradation in compliance, as outlined in the "Independent Assessment Process for Assessors Guidelines" and "CSP_controls_matrix_and_high_test_plan_2025."

•Option C: No, even if nothing has changed, an independent assessor needs to perform a full assessment including full testing every year

This is incorrect. A full assessment is not always required; a review of conditions can suffice if no changes are identified, per CSP guidelines.

•Option D: Yes, full reliance can be provided if the CISO of the SWIFT user signs a letter which confirms that nothing has changed

This is incorrect. CISO confirmation does not replace the assessor’s independent review, as mandated by the "Independent Assessment Framework."

Summary of Correct Answer:

An assessor cannot rely fully on a previous report without assessing conditions (B).

References to SWIFT Customer Security Programme Documents:

•Independent Assessment Process for Assessors Guidelines: Requires annual review.

•Independent Assessment Framework: Mandates assessor validation.

•CSP_controls_matrix_and_high_test_plan_2025: Supports conditional reliance.

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