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Combined SWIFT CSP and PCI DSS v4.0.1 recertification for a growing payment service provider

October 17, 2026

Client details are anonymized in line with our engagement confidentiality terms.

The situation

A fast-growing payment service provider in the UAE needed SWIFT Customer Security Programme (CSP) independent assessment ahead of its annual attestation deadline, alongside a PCI DSS v4.0.1 recertification due within the same quarter. The organization had grown headcount and infrastructure faster than its control documentation, and the incumbent internal team lacked bandwidth to run both assessments without disrupting live operations.

What we did

  • Ran a combined gap assessment across SWIFT CSP and PCI DSS v4.0.1 control sets, identifying 14 overlapping controls that could be evidenced once and mapped to both frameworks
  • Delivered a sequenced 9-week remediation plan prioritized by residual risk, not control count
  • Provided a SWIFT CSP Assessor-led independent assessment and QSA-led PCI DSS assessment under a single engagement lead
  • Supported management response drafting for the three findings that could not be remediated before the attestation window

The outcome

The client submitted its SWIFT CSP attestation on schedule and achieved PCI DSS v4.0.1 recertification with zero compensating controls required at final assessment — down from an initial gap assessment that identified 11 control deficiencies. The combined-framework approach reduced total assessment effort by approximately 30% compared to running the two programs separately, based on the client’s internal resourcing estimate.

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