How financial institutions can approve AWS services for highly confidential data

November 19, 2021: We made minor updates to this post, such as updating the number of services in scope for SOC compliance from 124 to 141.

January 18, 2021: We made minor updates to this post, such as updating the number of services in scope for SOC compliance from 122 to 124.

July 21, 2020: The number of services in scope for SOC compliance was updated from 116 to 122. Also, more than 55 AWS services now have support for VPC Endpoints, instead of 45.

As a Principal Solutions Architect within the Worldwide Financial Services industry group, one of the most frequently asked questions I receive is whether a particular AWS service is financial-services-ready. In a regulated industry like financial services, moving to the cloud isn’t a simple lift-and-shift exercise. Instead, financial institutions use a formal service-by-service assessment process to demonstrate how cloud services can help address their regulatory obligations. When this service approval process is not well defined, it can delay efforts to migrate data to the cloud.

In this post, I will provide a framework consisting of five key considerations that financial institutions should focus on to help streamline the approval of cloud services for their most confidential data. I will also outline the key AWS capabilities that can help financial services organizations during this process.

Here are the five key considerations:

1. Achieving compliance
2. Data protection
3. Isolation of compute environments
4. Automating audits with APIs
5. Operational access and security

For many of the business and technology leaders that I work with, agility and the ability to innovate quickly are the top drivers for their cloud programs. Financial services institutions migrate to the cloud to help develop personalized digital experiences, break down data silos, develop new products, drive down margins for existing products, and proactively address global risk and compliance requirements. AWS customers who use a wide range of AWS services achieve greater agility as they move through the stages of cloud adoption. Using a wide range of services enables organizations to offload undifferentiated heavy lifting to AWS and focus on their core business and customers.

My goal is to guide financial services institutions as they move their company’s highly confidential data to the cloud — in both production environments and mission-critical workloads. The following considerations will help financial services organizations determine cloud service readiness and to achieve success in the cloud.

1. Achieving compliance

For financial institutions that use a service approval process, the first step is to establish that the underlying components of the cloud service provider’s (CSP’s) services can meet baseline compliance needs. A key prerequisite to gaining this confidence is to understand the AWS shared responsibility model. Shared responsibility means that the secure functioning of an application on AWS requires action on the part of both the customer and AWS as the CSP. AWS customers are responsible for their security in the cloud. They control and manage the security of their content, applications, systems, and networks. AWS manages security of the cloud, providing and maintaining proper operations of services and features, protecting AWS infrastructure and services, maintaining operational excellence, and meeting relevant legal and regulatory requirements.

In order to establish confidence in the AWS side of the shared responsibility model, customers can regularly review the AWS System and Organization Controls 2 (SOC 2) Type II report prepared by an independent, third-party auditor. The AWS SOC 2 report contains confidential information that can be obtained by customers under an AWS non-disclosure agreement (NDA) through AWS Artifact, a self-service portal for on-demand access to AWS compliance reports. Sign in to AWS Artifact in the AWS Management Console, or learn more at Getting Started with AWS Artifact.

Key takeaway: Currently, 141 AWS services are in scope for SOC compliance, which will help organizations streamline their service approval process. For more information about which services are in scope, see AWS Services in Scope by Compliance Program.

2. Data protection

Financial institutions use comprehensive data loss prevention strategies to protect confidential information. Customers using AWS data services can employ encryption to mitigate the risk of disclosure, alteration of sensitive information, or unauthorized access. The AWS Key Management Service (AWS KMS) allows customers to manage the lifecycle of encryption keys and control how they are used by their applications and AWS services. Allowing encryption keys to be generated and maintained in the FIPS 140-2 validated hardware security modules (HSMs) in AWS KMS is the best practice and most cost-effective option.

For AWS customers who want added flexibility for key generation and storage, AWS KMS allows them to either import their own key material into AWS KMS and keep a copy in their on-premises HSM, or generate and store keys in dedicated AWS CloudHSM instances under their control. For each of these key material generation and storage options, AWS customers can control all the permissions to use keys from any of their applications or AWS services. In addition, every use of a key or modification to its policy is logged to AWS CloudTrail for auditing purposes. This level of control and audit over key management is one of the tools organizations can use to address regulatory requirements for using encryption as a data privacy mechanism.

All AWS services offer encryption features, and most AWS services that financial institutions use integrate with AWS KMS to give organizations control over their encryption keys used to protect their data in the service. AWS offers customer-controlled key management features in twice as many services as any other CSP.

Financial institutions also encrypt data in transit to ensure that it is accessed only by the intended recipient. Encryption in transit must be considered in several areas, including API calls to AWS service endpoints, encryption of data in transit between AWS service components, and encryption in transit within applications. The first two considerations fall within the AWS scope of the shared responsibility model, whereas the latter is the responsibility of the customer.

All AWS services offer Transport Layer Security (TLS) 1.2 encrypted endpoints that can be used for all API calls. Some AWS services also offer FIPS 140-2 endpoints in selected AWS Regions. These FIPS 140-2 endpoints use a cryptographic library that has been validated under the Federal Information Processing Standards (FIPS) 140-2 standard. For financial institutions that operate workloads on behalf of the US government, using FIPS 140-2 endpoints helps them to meet their compliance requirements.

To simplify configuring encryption in transit within an application, which falls under the customer’s responsibility, customers can use the AWS Certificate Manager (ACM) service. ACM enables easy provisioning, management, and deployment of x.509 certificates used for TLS to critical application endpoints hosted in AWS. These integrations provide automatic certificate and private key deployment and automated rotation for Amazon CloudFront, Elastic Load Balancing, Amazon API Gateway, AWS CloudFormation, and AWS Elastic Beanstalk. ACM offers both publicly-trusted and private certificate options to meet the trust model requirements of an application. Organizations may also import their existing public or private certificates to ACM to make use of existing public key infrastructure (PKI) investments.

Key takeaway: AWS KMS allows organizations to manage the lifecycle of encryption keys and control how encryption keys are used for over 90 services. For more information, see AWS Services Integrated with AWS KMS. AWS ACM simplifies the deployment and management of PKI as compared to self-managing in an on-premises environment.

3. Isolation of compute environments

Financial institutions have strict requirements for isolation of compute resources and network traffic control for workloads with highly confidential data. One of the core competencies of AWS as a CSP is to protect and isolate customers’ workloads from each other. Amazon Virtual Private Cloud (Amazon VPC) allows customers to control their AWS environment and keep it separate from other customers’ environments. Amazon VPC enables customers to create a logically separate network enclave within the Amazon Elastic Compute Cloud (Amazon EC2) network to house compute and storage resources. Customers control the private environment, including IP addresses, subnets, network access control lists, security groups, operating system firewalls, route tables, virtual private networks (VPNs), and internet gateways.

Amazon VPC provides robust logical isolation of customers’ resources. For example, every packet flow on the network is individually authorized to validate the correct source and destination before it is transmitted and delivered. It is not possible for information to pass between multiple tenants without specifically being authorized by both the transmitting and receiving customers. If a packet is being routed to a destination without a rule that matches it, the packet is dropped. AWS has also developed the AWS Nitro System, a purpose-built hypervisor with associated custom hardware components that allocates central processing unit (CPU) resources for each instance and is designed to protect the security of customers’ data, even from operators of production infrastructure.

For more information about the isolation model for multi-tenant compute services, such as AWS Lambda, see the Security Overview of AWS Lambda whitepaper. When Lambda executes a function on a customer’s behalf, it manages both provisioning and the resources necessary to run code. When a Lambda function is invoked, the data plane allocates an execution environment to that function or chooses an existing execution environment that has already been set up for that function, then runs the function code in that environment. Each function runs in one or more dedicated execution environments that are used for the lifetime of the function and are then destroyed. Execution environments run on hardware-virtualized lightweight micro-virtual machines (microVMs). A microVM is dedicated to an AWS account, but can be reused by execution environments across functions within an account. Execution environments are never shared across functions, and microVMs are never shared across AWS accounts. AWS continues to innovate in the area of hypervisor security, and resource isolation enables our financial services customers to run even the most sensitive workloads in the AWS Cloud with confidence.

Most financial institutions require that traffic stay private whenever possible and not leave the AWS network unless specifically required (for example, in internet-facing workloads). To keep traffic private, customers can use Amazon VPC to carve out an isolated and private portion of the cloud for their organizational needs. A VPC allows customers to define their own virtual networking environments with segmentation based on application tiers.

To connect to regional AWS services outside of the VPC, organizations may use VPC endpoints, which allow private connectivity between resources in the VPC and supported AWS services. Endpoints are managed virtual devices that are highly available, redundant, and scalable. Endpoints enable private connection between a customer’s VPC and AWS services using private IP addresses. With VPC endpoints, Amazon EC2 instances running in private subnets of a VPC have private access to regional resources without requiring an internet gateway, NAT device, VPN connection, or AWS Direct Connect connection. Furthermore, when customers create an endpoint, they can attach a policy that controls the use of the endpoint to access only specific AWS resources, such as specific Amazon Simple Storage Service (Amazon S3) buckets within their AWS account. Similarly, by using resource-based policies, customers can restrict access to their resources to only allow access from VPC endpoints. For example, by using bucket policies, customers can restrict access to a given Amazon S3 bucket only through the endpoint. This ensures that traffic remains private and only flows through the endpoint without traversing public address space.

Key takeaway: To help customers keep traffic private, more than 90 AWS services have support for VPC Endpoints.

4. Automating audits with APIs

Visibility into user activities and resource configuration changes is a critical component of IT governance, security, and compliance. On-premises logging solutions require installing agents, setting up configuration files and log servers, and building and maintaining data stores to store the data. This complexity may result in poor visibility and fragmented monitoring stacks, which in turn takes longer to troubleshoot and resolve issues. CloudTrail provides a simple, centralized solution to record AWS API calls and resource changes in the cloud that helps alleviate this burden.

CloudTrail provides a history of activity in a customer’s AWS account to help them meet compliance requirements for their internal policies and regulatory standards. CloudTrail helps identify who or what took which action, what resources were acted upon, when the event occurred, and other details to help customers analyze and respond to activity in their AWS account. CloudTrail management events provide insights into the management (control plane) operations performed on resources in an AWS account. For example, customers can log administrative actions, such as creation, deletion, and modification of Amazon EC2 instances. For each event, they receive details such as the AWS account, IAM user role, and IP address of the user that initiated the action as well as time of the action and which resources were affected.

CloudTrail data events provide insights into the resource (data plane) operations performed on or within the resource itself. Data events are often high-volume activities and include operations, such as Amazon S3 object-level APIs, and AWS Lambda function Invoke APIs. For example, customers can log API actions on Amazon S3 objects and receive detailed information, such as the AWS account, IAM user role, IP address of the caller, time of the API call, and other details. Customers can also record activity of their Lambda functions and receive details about Lambda function executions, such as the IAM user or service that made the Invoke API call, when the call was made, and which function was executed.

To help customers simplify continuous compliance and auditing, AWS uniquely offers the AWS Config service to help them assess, audit, and evaluate the configurations of AWS resources. AWS Config continuously monitors and records AWS resource configurations, and allows customers to automate the evaluation of recorded configurations against internal guidelines. With AWS Config, customers can review changes in configurations and relationships between AWS resources and dive into detailed resource configuration histories.

Key takeaway: Over 200 AWS services are integrated with CloudTrail, which helps customers ensure compliance with their internal policies and regulatory standards by providing a history of activity within their AWS account. For more information about how to use CloudTrail with specific AWS services, see AWS Service Topics for CloudTrail in the CloudTrail user guide. For more information on how to enable AWS Config in an environment, see Getting Started with AWS Config.

5. Operational access and security

In our discussions with financial institutions, they’ve told AWS that they are required to have a clear understanding of access to their data. This includes knowing what controls are in place to ensure that unauthorized access does not occur. AWS has implemented layered controls that use preventative and detective measures to ensure that only authorized individuals have access to production environments where customer content resides. For more information about access and security controls, see the AWS SOC 2 report in AWS Artifact.

One of the foundational design principles of AWS security is to keep people away from data to minimize risk. As a result, AWS created an entirely new virtualization platform called the AWS Nitro System. This highly innovative system combines new hardware and software that dramatically increases both performance and security. The AWS Nitro System enables enhanced security with a minimized attack surface because virtualization and security functions are offloaded from the main system board where customer workloads run to dedicated hardware and software. Additionally, the locked-down security model of the AWS Nitro System prohibits all administrative access, including that of Amazon employees, which eliminates the possibility of human error and tampering.

Key takeaway: Review third-party auditor reports (including SOC 2 Type II) available in AWS Artifact, and learn more about the AWS Nitro System.

Conclusion

AWS can help simplify and expedite the service approval process for financial services institutions to move to the cloud. When organizations take advantage of a wide range of AWS services, it helps maximize their agility by making use of the existing security and compliance measures built into AWS services so they can focus on their core business and customers.

After organizations have completed the service approval process and determined which cloud services can be used as part of their architecture, the AWS Well-Architected Framework can then be implemented to help build and operate secure, resilient, performant, and cost-effective architectures on AWS.

AWS also has a dedicated team of financial services professionals to help customers navigate a complex regulatory landscape, as well as other resources to guide them in their migration to the cloud – no matter where they are in the process. For more information, see the AWS Financial Services page, or fill out this AWS Financial Services Contact form.

Additional resources

• AWS Security Documentation
  The security documentation repository shows how to configure AWS services to help meet security and compliance objectives. Cloud security at AWS is the highest priority. AWS customers benefit from a data center and network architecture that are built to meet the requirements of the most security-sensitive organizations.
• AWS Compliance Center
  The AWS Compliance Center is an interactive tool that provides customers with country-specific requirements and any special considerations for cloud use in the geographies in which they operate. The AWS Compliance Center has quick links to AWS resources to help with navigating cloud adoption in specific countries, and includes details about the compliance programs that are applicable in these jurisdictions. The AWS Compliance Center covers many countries, and more countries continue to be added as they update their regulatory requirements related to technology use.
• AWS Well-Architected Framework and AWS Well-Architected Tool
  The AWS Well-Architected Framework helps customers understand the pros and cons of decisions they make while building systems on AWS. The AWS Well-Architected Tool helps customers review the state of their workloads and compares them to the latest AWS architectural best practices. For more information about the AWS Well-Architected Framework and security, see the Security Pillar – AWS Well-Architected Framework whitepaper. For best practices for financial services, please see the Financial Services Industry Lens – AWS Well-Architected Framework.

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