Swift Mandatory and Advisory Security Controls
Swift Mandatory and Advisory Security Controls
AND ADVISORY
SECURITY CONTROLS
Take a Bite Out of the Updated SWIFT Customer Security Controls Framework with
Palo Alto Networks
Successful cyberattacks against multiple financial institutions came to light
in 2016, resulting in multiple instances of fraudulent fund transfers over the
Society for Worldwide Interbank Financial Telecommunications (SWIFT) net-
work. As part of an effort to enhance the cybersecurity of the entire ecosys-
tem, members of SWIFT were required to annually self-attest to an initial set of
mandatory cybersecurity controls by the end of 2017. Furthermore, a number
of advisory security controls were provided as best practices to improve over-
all cyber hygiene across the SWIFT ecosystem. For 2019, SWIFT updated the
Customer Security Controls Framework (CSCF) to include 19 mandatory and 10
advisory controls in recognition of emerging and evolving cyberthreats.
Palo Alto Networks can support your efforts to meet this baseline by contrib-
uting to 86% of the updated SWIFT mandatory and advisory security controls.
In many cases, the capabilities of the Security Operating Platform® exceed the
SWIFT CSCF v2019 controls and can provide even better security outcomes. By
incorporating the SWIFT controls into your cybersecurity program and leveraging
Palo Alto Networks products accordingly, you can put your financial institution’s
cybersecurity posture well on the way to meeting the revised SWIFT CSCF.
Palo Alto Networks | SWIFT Mandatory and Advisory Security Controls | White Paper 1
Introduction
SWIFT announced its Customer Security Programme (CSP) in 2016 after a series of successful attacks that bypassed local secu-
rity measures at several SWIFT member institutions. These attacks occurred across multiple countries and continued well into
2018. The most highly publicized incident, at a bank in Bangladesh, resulted in fraudulent fund transfers of US$81 million initi-
ated through the SWIFT network. Although the SWIFT environment itself has not been compromised in any of these attacks,
SWIFT established the CSP as an industry cooperative to reinforce and safeguard the security of the entire ecosystem. One aim
of this program is to enhance security guidelines and provide audit frameworks for all members of the SWIFT community.
The first version of the SWIFT CSCF, published in early 2017, prescribed 16 mandatory and 11 advisory controls as a security
baseline for the local environments of its member institutions. In recognition of the evolving threat landscape and additional
technology adopted by the financial services industry, SWIFT published the CSCF v2019, which now includes 19 mandatory
and 10 advisory controls. The mandatory controls set a realistic goal for near-term, tangible security gains and risk reduction
to which SWIFT members must self-attest by the end of 2019. In the CSCF v2019, three advisory controls from 2017 have
been promoted to mandatory, and two brand-new advisory controls on virtual machines and application hardening have been
introduced.
Security Controls
In many instances, security and compliance teams have had to go above and beyond the minimum industry regulations to
establish security architectures that effectively address modern and emerging threats and more closely align with their own
institutions’ risk tolerances. The same approach may also apply to the SWIFT mandatory security controls, supplemented with
implementation of the advisory controls or other additional measures deemed necessary by a given financial institution.
Although no single vendor or offering can deliver full compliance with the entire SWIFT CSCF, financial institutions would
be well-served by products and processes that address multiple requirements, ideally in a tightly integrated manner. Today’s
evolving and emerging threats require a multilayered approach to cybersecurity, based on security enforcement points that
natively integrate and share threat information across the entire environment. In other words, if a threat is detected in one
location, such as an endpoint, the ideal approach must work to prevent it everywhere—that is, on the network and in the
cloud.
Palo Alto Networks | SWIFT Mandatory and Advisory Security Controls | White Paper 2
Palo Alto Networks has built a platform that uses consolidated threat intelligence, automation, analytics, machine learning,
and AI to offer comprehensive coverage across the enterprise environment, including the cloud. Key attributes are the ability
to protect consistently everywhere, automate tasks for efficiency, and offer visibility into network data regardless of location.
Benefits of this approach include lowering mean time to respond (MTTR) and mean time to detect (MTTD), reducing risk and
increasing efficiency for your teams.
In the next two sections, we will review the applicability of the Security Operating Platform to the relevant SWIFT mandatory
and advisory controls.
1. Restrict Internet Access & Protect Critical Systems from General IT Environment
1.1 SWIFT Environment Protection: Ensure the protection of the user’s local SWIFT infrastructure from potentially compromised
elements of the general IT environment and external environment.
In short, this calls for effective network segmentation of the local SWIFT infrastructure from the rest of the IT environment.
By compartmentalizing the SWIFT elements, a compromise elsewhere in an institution’s environment would pose minimal risk
to SWIFT operations. Think of this as establishing a Zero Trust network for the local SWIFT infrastructure. Palo Alto Networks
Next-Generation Firewalls may serve as segmentation gateways to safely enable desired applications across zones, into or out
of the local SWIFT environment. Lateral movement by malicious entities or even unauthorized insiders is restricted accordingly.
Member responsibility
Internet SWIFT
network
General IT Local SWIFT
infrastructure infrastructure
1.2 Operating System Privileged Account Control: Restrict and control the allocation and usage of administrator-level
operating system accounts.
The principle of least privilege should be applied to ensure administrator-level access is limited to personnel who need it for their
job functions. Moreover, administrative privileges should be tied to specific system accounts and user IDs. Next-Generation
Firewalls may be deployed as multi-factor authentication (MFA) gateways to require additional credentials from administrative
users. This policy-based approach occurs at the network layer instead of on a per-application or per-server basis to accommodate
even legacy resources that do not support MFA. Consequently, even stolen administrator-level credentials are no longer sufficient
to impersonate valid actors.
Palo Alto Networks | SWIFT Mandatory and Advisory Security Controls | White Paper 3
Where timely software patching is not possible for whatever reason, Traps can effectively prevent exploits and malware from
compromising laptops, PCs, and servers. Traps takes a unique, multi-method approach to preemptively block both known and
unknown threats, even for unpatched or unpatchable systems. Legacy systems that are still active, such as aging ATMs or
servers still running Windows® XP, can be protected from malware and exploits by Traps. In the specific case of any unpatched
local SWIFT components, they can be protected from vulnerabilities with Traps. This can serve as a mitigating control until the
appropriate patches are ultimately applied.
2.3 System Hardening: Reduce the cyber attack surface of SWIFT-related components by performing system hardening.
To complement system hardening, the Next-Generation Firewall can limit data flow to only relevant and desired applications by
virtue of App-ID™ technology, which can recognize traffic by the actual application protocol instead of just the TCP/UDP port
numbers. By establishing security policies with this granular level of control, organizations can further minimize the available attack
surface of even hardened systems.
2.6 Operator Session Confidentiality and Integrity: Protect the confidentiality and integrity of interactive operator sessions
connecting to the local SWIFT infrastructure.
In an ideal scenario, all dedicated operator endpoints would be located in the separate, protected, local SWIFT environment, elimi-
nating the exposure of that traffic flow to the rest of the IT environment. However, this may not be cost-effective or operationally
practical for a number of reasons, including geographic separation.
With the local SWIFT infrastructure segregated as prescribed by Mandatory Control 1.1, that same Next-Generation Firewall can limit
remote operator access to a set of specific administrative users with User-ID™ technology, and then, by virtue of deep visibility with
App-ID, further limit that access to only particular applications. User-ID enables the Next-Generation Firewall to identify all users
on the network and enforce security policy based on user group membership. App-ID is a traffic classification system that identifies
applications based on their behavioral characteristics and relative risk. The Next-Generation Firewall can also enforce policy based on
specific App-IDs. Threat Prevention and WildFire subscriptions add greater protection against intrusion and unknown malware.
You can use GlobalProtect™ network security for endpoints to establish a secure SSL/IPsec VPN connection to the Next-Genera-
tion Firewall to further protect the contents of operator sessions from outside the local SWIFT environment. GlobalProtect collects
device information, such as OS patch level, anti-malware measures, and disk encryption, that enables the firewall to permit access
only when the endpoint is properly configured and secured.
Finally, the integrity of any operator endpoints will benefit from the multiple methods of prevention Traps offers against malware
and exploits. See figure 3 for an overview of protecting operator sessions with the Security Operating Platform.
TR GP
TR
Operator/Admin
TR
General IT WF
infrastructure
Local SWIFT
infrastructure
2.7 Vulnerability Scanning: Identify known vulnerabilities within the local SWIFT environment by implementing a regular vulnerabil-
ity scanning process and act upon results.
The Security Operating Platform is not part of the vulnerability scan itself, but various components help prevent discovery and
exploitation of vulnerabilities during such exercises by ethical or malicious entities. Traps can prevent fingerprint scanning by exploit
kits to restrict attackers’ ability to discover operating system and application information. The Next-Generation Firewall with Threat
Prevention blocks evasive techniques and attempts to exploit vulnerabilities based on system flaws, buffer overflows, illegal code
execution, and other means. WildFire adds further protection against unknown malware.
Should scanning identify vulnerable assets in the environment, Cortex XDR™ by Palo Alto Networks may be used to more closely
monitor the assets for specific behavioral indicators of compromise (BIOC), and then to alert and respond when malicious activities
begin. In addition to preconfigured BIOC rules with content updates, organizations may add local, customized rules as additional
threats are investigated. This additional focus on vulnerable portions of the environment would be appropriate until the vulnerabili-
ties can be permanently addressed.
Palo Alto Networks | SWIFT Mandatory and Advisory Security Controls | White Paper 4
4. Prevent Compromise of Credentials
4.1 Password Policy: Ensure passwords are sufficiently resistant against common password attacks by implementing and
enforcing an effective password policy.
Although the Security Operating Platform cannot enforce specific password policies, our credential theft prevention capability
can stop the submission of corporate login and password information to phishing or other unauthorized websites. This provides
an added measure to protect corporate login credentials from a common theft technique.
4.2 Multi-factor Authentication: Prevent that a compromise of a single authentication factor allows access into SWIFT
systems, by implementing multi-factor authentication.
As mentioned previously, the Next-Generation Firewall provides a centralized, policy-based MFA framework that can be
deployed in front of local SWIFT-related systems. This is achieved by working at the network level in conjunction with authen-
tication and identity management frameworks, such as single sign-on and MFA, and integrating with a number of next-genera-
tion identity and access management (IAM) vendors, including Okta, Ping Identity, and Duo Security. This offers the benefits of
MFA without any modifications to individual SWIFT-related systems.
Local
SWIFT-related
servers
Okta
3
MFA verification
2
MFA challenge
User 1
Policy check
2
MFA challenge
Attackers
with stolen
credentials
Palo Alto Networks | SWIFT Mandatory and Advisory Security Controls | White Paper 5
6. Detect Anomalous Activity to Systems or Transaction Records
6.1 Malware Protection: Ensure that local SWIFT infrastructure is protected against malware.
At a minimum, SWIFT servers and operator workstations should have Traps for protection against malware and exploits. The
Next-Generation Firewalls at the network perimeter and those serving as segmentation gateways internally can run WildFire.
Moreover, the Next-Generation Firewalls can also be enabled with Threat Prevention and URL Filtering subscriptions for
maximum protection against malware.
In the event malware still finds its way into your environment, Cortex XDR accurately detects threats with behavioral analytics
and reveals the root cause to speed up investigations. Tight integration with enforcement points accelerates containment,
enabling you to stop attacks before damage is done.
6.2 Software Integrity: Ensure the software integrity of the SWIFT-related applications.
Deploy Traps to protect SWIFT-related servers and workstations from malware and exploits that may attempt to inject
malicious code for execution.
6.4 Logging and Monitoring: Record security events and detect anomalous actions and operations within the local SWIFT
environment.
The Next-Generation Firewalls at the network perimeter or the internal network have built-in logging and reporting
capabilities. Similarly, Traps log data is available for the endpoint perspective. Local monitoring and analysis are possible on
the Next-Generation Firewall and through Panorama™ network security management, or they may be handled by a security
information and event management (SIEM) product. For even more complete insight into anomalous traffic, Cortex XDR
removes security blind spots by stitching together network, endpoint, and cloud data for behavioral analytics using AI,
which allows you to quickly identify and eliminate threats.
Palo Alto Networks | SWIFT Mandatory and Advisory Security Controls | White Paper 6
Table 1: Mapping of SWIFT Mandatory Controls to Palo Alto Networks Products (continued)
Mandatory Controls Next-Gen Firewall Cortex
1. Restrict Internet Access & Protect Critical Systems from General IT Environment
1.3A Virtualization Platform Protection: Secure virtualisation platform and virtual machines (VM’s) hosting SWIFT related
components to the same level as physical systems.
VM-Series Virtualized Next-Generation Firewalls offer equivalent functionality to our hardware-based Next-Generation
Firewalls and support both private and public cloud deployments. The VM-Series provides the same deep visibility and granular
control found in our hardware Next-Generation Firewalls for any data in the cloud. Traffic flows between applications running
on VMs may also be tightly monitored and controlled using User-ID and App-ID context available in the security policy.
Palo Alto Networks | SWIFT Mandatory and Advisory Security Controls | White Paper 7
Deploy a Next-Generation Firewall at the network perimeter for business-to-business connections to any third-party suppliers.
Include the use of Threat Prevention and WildFire subscriptions to block anomalous activities and malware from third parties.
This same perimeter firewall can also serve as an MFA gateway to challenge third parties for additional credentials before they
are permitted to access any of your institution’s applications or data.
2.9A Transaction Business Controls: Restrict transaction activity to validated and approved counterparties and within the
expected bounds of normal business.
Although some of this involves ensuring appropriate privilege levels within the sanctioned SWIFT-related applications them-
selves, the Next-Generation Firewall, as described in 2.8A, will help reduce the attack surface available to third parties. By
restricting access to a defined set of permissible applications, you give counterparties only the visibility of those resources they
require to conduct their normal business. This enforces the principle of least privilege on your third-party partners.
2.10A Application Hardening: Reduce the attack surface of SWIFT-related components by performing application hardening
on the SWIFT-certified messaging and communication interfaces and related applications
With the visibility offered by App-ID and Content-ID, the Next-Generation Firewall can inspect and limit traffic to expected
application protocols between SWIFT components. More than 3,000 predefined App-IDs exist today, including one for IBM
Websphere MQ, which is used for back-office application communications. If desired, organizations can create custom App-
IDs for SWIFT messaging applications as well. With tight control over the explicit traffic flows to and from the local SWIFT
elements, the attack surface is significantly minimized.
Prisma Cloud
Prisma™ Cloud by Palo Alto Networks dynamically discovers cloud resources and sensitive data across Google Cloud
Platform (GCP™), Amazon Web Services (AWS®), and Microsoft Azure® in addition to detecting risky configurations and
identifying network threats, suspicious user behavior, malware, data leakage, and host vulnerabilities. It eliminates blind
spots across cloud environments and provides continuous protection with a combination of class-leading machine learning
and the most complete collection of rule-based security policies. This provides protection for any workloads that may reside
in your public cloud environment.
Palo Alto Networks | SWIFT Mandatory and Advisory Security Controls | White Paper 8
Table 2: Mapping of SWIFT Advisory Controls to Palo Alto Networks Products and Tools
Advisory Control Next-Gen Firewall (NGFW) Threat Prevention Other
VM-Series,
1.3A Virtualization Platform Protection Threat Prevention, Traps
WildFire, URL Filtering
NGFW,
2.4A Back Office Data Flow Security Threat Prevention, Traps
WildFire, App-ID
NGFW, Threat
2.8A Critical Activity Outsourcing
Prevention, WildFire
NGFW, Threat
2.9A Transaction Business Controls
Prevention, WildFire
Prisma Cloud,
7.3A Penetration Testing
SLR, PPA
Summary
No single vendor or solution can provide full compliance with the SWIFT mandatory and advisory controls. What organizations
require instead is a thorough set of policies, processes, and practices, supported by an essential set of technological counter-
measures to enforce them. The ultimate goal is not merely to complete the annual SWIFT self-attestation, but rather to improve
cybersecurity for the organization, which will benefit the local SWIFT infrastructure as well. In this regard, the Palo Alto Networks
Security Operating Platform is invaluable, delivering:
• Definitive least-privileged access control and other essential security capabilities to effectively segment and protect the
local SWIFT environment for a Zero Trust network.
• Support for 86% of the SWIFT CSCF v2019, addressing all but four controls. Of these, only one relates to technology
(6.3 Database Integrity) while the others pertain to personnel, training, and physical security.
• Capabilities above and beyond the baseline specifications to more thoroughly protect your local SWIFT infrastructure and
the remainder of your organization’s computing environment from the latest unknown malware and advanced threats.
With the power of the Security Operating Platform, financial institutions can be well on their way to complying with or
exceeding the SWIFT mandatory and advisory controls. Beyond merely an exercise in compliance, the prevention philosophy
behind the platform will improve your overall cyber hygiene and provide better security outcomes for your organization. The
result will be a more secure environment for your financial institution—one in which legitimate traffic is known and limited, with
automated security enforcement to detect and address deviations.
For more information about the Security Operating Platform and its component technologies, please visit paloaltonetworks.com.
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