Compliance and Risk Teams

Comprehensive Security Framework for SWIFT RMA Directory

CoLedger’s secure RMA directory platform protects correspondent banking relationship topology while maintaining transparency for routing capabilities through member-only access, granular authorization, and comprehensive audit controls

4 Core Security Controls

Essential controls for authentication, authorization, audit logging, and session management

Risk-Based Access

Granular controls that balance security needs with operational requirements

Full Auditability

Complete visibility into access patterns and relationship inquiries

What We Protect vs. What’s Public

CoLedger’s platform balances operational transparency with essential security controls to protect sensitive relationship data while enabling legitimate business discovery

CRITICAL DISTINCTION:

SWIFT BIC codes are public information available through SWIFT directories and other public sources. CoLedger does NOT attempt to hide BIC codes. What we protect is the relationship topology — specifically, which banks have RMA relationships with which other banks.

Public Information

No protection needed - available to enable legitimate business purposes:

SWIFT BIC codes (e.g., REGIUS33, ADCBAEAA) - unmasked
Bank names and headquarters locations
General service offerings and routing capability categories
Supported currencies and geographic coverage
Aggregate network statistics ("47 member banks", "128 countries")

Protected Information

Requires member authentication:

▲ RMA relationship connections: "Bank A has correspondent relationship with Bank B"
▲ Routing paths: "Bank A routes to Country X through correspondents B, C, D"
▲ Network topology: The complete map of who-connects-to-whom
▲ Contact information: Relationship managers (subject to granular access permissions)
▲ Operational procedures: Transaction thresholds, cut-off times (if available)

Platform Security Framework

Core Security & Privacy Controls

CoLedger’s initial platform implements essential security controls to protect member data while enabling efficient RMA discovery. The platform is hosted by an industry-trusted technology provider already serving banks, with enterprise-grade security and compliance certifications.

Enterprise-Grade Infrastructure

The CoLedger platform will be hosted by an industry-trusted technology provider that member banks already use for critical operations. We are in the final stages of selecting our hosting partner, ensuring compliance with banking security standards including FFIEC guidelines, SOC 2 Type II, and GDPR/CCPA requirements.

Data Security

All data transmission via TLS 1.3 or higher. All sensitive data encrypted at rest using AES-256 encryption.

Access Control

Multi-factor authentication, role-based access, and granular data sharing controls ensure proper authorization.

Compliance & Audit

Comprehensive audit logging available upon request meets regulatory requirements and enables forensic investigation.

In addition to the secure data hosting and controls from trusted bank partners, CoLedger has built its platform around security being our core focus. The platform also incorporates these 4 core security controls:

Member-Only Access

RMA directory only accessible to verified, authenticated member banks

Implementation

Requires institutional verification and Bank ID-based authentication before any directory access is granted. Dual-factor authentication (2FA) with 6-digit time-based one-time password (TOTP) required for all users. Non-members cannot view any RMA information.

Key Benefits

Prevents anonymous reconnaissance by attackers
Ensures all directory users are identifiable and vetted
Creates accountability for all access
Establishes trust baseline for all participants

Risks Mitigated

Network Mapping Competitive Intelligence Unauthorized Access

Granular Access Authorization

Each institution controls which other member institutions can view their RMA data

Implementation

Through account settings, member banks select which institutions can see their RMA relationships and contact information. Default setting shares with all members, but can be customized to specific institutions. Preference changes take effect immediately.

Key Benefits

Granular control over data visibility by institution
Instant approval or blocking of specific members
Flexibility to manage competitor access
Maintains relationship privacy preferences dynamically

Risks Mitigated

Competitive Intelligence Strategic Relationship Exposure Correspondent Bank Concerns Unauthorized Disclosure

Comprehensive Audit Trails

Log all platform activity to detect suspicious patterns and ensure compliance

Implementation

All login attempts (successful and failed), search queries, data uploads, and modifications are logged with timestamp and user ID. Audit logs available upon request. Enables forensic investigation and demonstrates due diligence.

Key Benefits

Enables forensic investigation after incidents
Deters malicious insider activity
Identifies compromised accounts quickly
Demonstrates due diligence to regulators and meets compliance standards

Risks Mitigated

Insider Threats Account Compromise Regulatory Non-Compliance Unauthorized Activity

Session Management & Access Controls

Automatic session timeout and role-based access to limit exposure

Implementation

Sessions automatically timeout after 30 minutes of inactivity. Failed login attempt lockout (5 attempts = 15-minute lockout). Role-based access control with Admin, and Standard User roles ensures users only access features appropriate to their function.

Key Benefits

Limits damage from unattended workstations
Prevents credential stuffing attacks
Creates natural checkpoints for access validation
Enforces principle of least privilege

Risks Mitigated

Account Compromise Credential Theft Insider Threats Unauthorized Access

Comprehensive Risk Coverage

Five Major Risk Categories Addressed

Understanding the full spectrum of threats helps us design targeted, effective mitigation strategies

Operational Security & Intelligence Risks

Network Mapping for Attacks

Bad actors can map your entire correspondent banking network topology (who connects to whom) to identify weak links, target less sophisticated banks for social engineering, and impersonate specific banks more convincingly.

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How CoLedger Mitigates This:

Authentication required to view relationship connections prevents attackers from obtaining complete network topology, making relationship mapping incomplete and social engineering attacks less targeted.

Business Email Compromise (BEC) Enhancement

BEC attacks become dramatically more effective when attackers have contact lists with names, email addresses, and phone numbers, allowing them to create highly convincing fake emails referencing real relationships and operational staff.

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How CoLedger Mitigates This:

Member-only access and granular authorization controls prevent bulk contact harvesting. Contact details are only available to authenticated member institutions with proper access permissions, making contact list compilation for BEC attacks extremely difficult.

Insider Threat Amplification

Disgruntled employees can more easily facilitate fraud when they know the complete network map and can provide attackers with exact correspondent relationships to exploit.

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How CoLedger Mitigates This:

Authentication requirements create audit trails and limit the pool of individuals with access to sensitive contact details, reducing insider threat vectors.

Competitive Intelligence Risks

Strategic Relationship Exposure

Competitors can see the markets and countries to which you have direct access and potentially inform clients or use as a competitive differentiator.

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How CoLedger Mitigates This:

Public visibility of basic routing capabilities satisfies business discovery needs while protecting strategic relationship details behind authentication.

Customer Poaching

Competitors can identify your international trade finance capabilities and target your customers, or approach your correspondents directly to establish competing relationships.

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How CoLedger Mitigates This:

Limited public information prevents competitors from fully mapping your service capabilities or identifying specific high-value corridors you prioritize.

Regulatory & Compliance Risks

Sanctions Evasion Schemes

Sophisticated actors can analyze your network to find multi-hop routing paths that obscure origin/destination, identifying correspondents with weaker sanctions screening to design layered transactions.

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How CoLedger Mitigates This:

Member-only access and granular authorization controls prevent bad actors from mapping complete routing chains, making it harder to engineer complex sanctions evasion schemes through your network.

Know Your Customer’s Customer (KYCC) Complications

Public RMA lists might attract high-risk businesses seeking “backdoor” access to certain jurisdictions, creating compliance challenges.

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How CoLedger Mitigates This:

Authentication requirements allow you to control who can identify your correspondent network, reducing unsolicited approaches from high-risk entities.

Reputational & Relationship Risks

Correspondent Bank Concerns

Many correspondent banks prefer confidentiality about their relationships. Public disclosure could violate bilateral confidentiality agreements or cause correspondents to terminate RMAs.

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How CoLedger Mitigates This:

Protected contact details respect correspondent confidentiality preferences while still allowing verified parties to discover routing capabilities.

Association Risk

If one of your correspondents faces a scandal or enforcement action, your public association becomes problematic. You’re publicly linked to every correspondent’s reputation.

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How CoLedger Mitigates This:

Limiting detailed relationship information reduces the visibility of specific associations, providing flexibility if you need to distance yourself from troubled correspondents.

Customer Targeting by Bad Actors

Fraudsters can identify which of your customers are likely doing business in specific countries and target them with scams tailored to their known geographic activity.

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How CoLedger Mitigates This:

Authentication barriers prevent fraudsters from easily mapping your network to your customers’ international activities.

Operational Vulnerability Risks

Message Formatting Attacks

Knowing exact correspondent relationships allows attackers to study legitimate message patterns and reverse-engineer your SWIFT message formatting and routing conventions.

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How CoLedger Mitigates This:

Limited public information makes it harder for attackers to analyze and replicate your specific operational patterns and message formats.

Testing and Probing

Attackers can send small “test” transactions through your known correspondents to probe for weaknesses in compliance screening without revealing their full scheme.

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How CoLedger Mitigates This:

Authentication requirements create friction that deters systematic probing and testing of your correspondent network. Each bank will maintain their own policies and procedures for transaction and risk screening.

Integrated Security Benefits

Comprehensive Protection Across All Risk Categories

CoLedger’s platform security framework provides essential protection that addresses operational, competitive, and regulatory risks while maintaining business functionality for RMA discovery.

Enhanced Security Posture

Member-only access with 2FA and comprehensive audit trails protect against unauthorized access and threats

Dual-factor authentication prevents unauthorized logins
Comprehensive audit logging for forensic investigation
Session management limits credential compromise damage
Role-based access enforces principle of least privilege

Granular Data Control

Each institution selects which members can view their RMA data and contact information

Institution-level control over data visibility
Flexible blocking of competitors or high-risk entities
Default share-with-all setting with customization options
Immediate effect when preferences change

Regulatory Compliance

Banking-grade security standards and comprehensive audit trails demonstrate due diligence

Audit logs available upon request for regulatory compliance
FFIEC, SOC 2 Type II, GDPR/CCPA compliance standards
TLS 1.3 encryption and AES-256 at rest
Demonstrates sophisticated risk management to examiners

Trusted Infrastructure

Platform hosted by industry-trusted provider already serving member banks

Hosted by technology provider banks already trust
Enterprise-grade security and compliance certifications
Regular security assessments and penetration testing
Maintains bank-grade operational standards

Platform Architecture

Authentication

Bank ID-based login
Dual-factor authentication (2FA)
TOTOP for second factor
Session timeout: 30 minutes
Failed login lockout protection

Access Control

Granular data sharing preferences
Institution-level permissions
Role-based access (Admin/User/Read-Only)
Immediate preference updates

Audit & Compliance

Comprehensive activity logging
Audit logs available upon request
TLS 1.3 encryption in transit
AES-256 encryption at rest

Key Takeaways

Business Value Preserved

Public routing information enables legitimate business discovery and relationship development. Banks can still identify potential correspondents for their needs.

Compliance Enhanced

Authentication requirements demonstrate sophisticated risk management and create defensible audit trails for regulatory review.

Risk Significantly Reduced

Protected contact details prevent the most damaging attack vectors including BEC, social engineering, and systematic network exploitation.

Relationships Protected

Respects correspondent confidentiality preferences while providing flexibility to manage reputational and de-risking events privately.

Secure, Trusted, Compliant RMA Directory

CoLedger’s initial platform combines member-only access with dual-factor authentication, granular data sharing controls, comprehensive audit trails, and enterprise-grade infrastructure to create a secure RMA directory. Hosted by an industry-trusted technology provider already serving member banks, the platform balances security with usability while maintaining the compliance standards required by financial institutions.