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Uruguay
Regulations
This page provides AWS financial institution customers with information about the legal and regulatory requirements in Uruguay that may apply to their use of AWS services.
The Central Bank of Uruguay (“BCU”) is the regulator of the financial and payment systems in Uruguay. It is responsible for the oversight and control of such systems and the entities operating within those systems, the passing of new regulations, and the enforcement of said regulations. Some of the regulated entities (collectively, the “Financial Institutions”) are:
- Entities operating within the payments system.
- Financial intermediation entities including, without limitation: private commercial banks, the Bank of the Oriental Republic of Uruguay (“BROU”), and the Mortgage Bank of Uruguay (“BHU”).
- Entities that carry out financial activities other than financial intermediation.
- Entities operating within the capital markets, commercial insurance and reinsurance entities, including the State Insurance Bank of Uruguay (“BSE”).
- Pension Savings Fund Administrators.
Financial Institutions in Uruguay may be subject to a number of different legal and regulatory considerations when they use cloud services. Regulations issued by BCU to oversee Financial Institutions include, but are not limited to:
- Compilation of Rules for the Regulation and Control of the Financial System, as amended by BCU’s Circular No. 2419.
- Compilation of Rules of the Securities Market, as amended by BCU’s Circular No. 2420.
- Compilation of Rules for the Control of Pension Funds, as amended by BCU’s Circular No. 2421.
- Compilation of Rules of Insurances and Reinsurances, as amended by BCU’s Circular No. 2422.
- Compilation of Rules of the Payments System.
- Communication 2022/254 Outsourcing of Services applicable to all markets except for entities operating in the payments system. Sets forth requirements in order for services to be deemed authorized by the BCU for outsourcing, including Software-as-a-Service.
While Communication 2022/254 is not strictly applicable to entities operating in the payments system; the requirements provided therein are usually followed by and applied to said entities.
Regulations are changing rapidly in this space, and AWS is working to help customers proactively respond to new rules and guidelines. AWS encourages its Financial Institution customers to obtain appropriate advice on their compliance with all regulatory and legal requirements that are relevant to their business, and local regulations, guidelines and laws.
AWS is committed to offering customers a strong compliance framework and advanced tools and security measures that customers can use to evaluate, meet, and demonstrate compliance with applicable legal and regulatory requirements.
Financial institutions who are using or planning to use AWS services can take the following steps to better understand their compliance needs:
1. Consider the purpose of the workload(s) under consideration and the relevant categories of data in order to anticipate which legal and regulatory requirements may apply.
2. Assess the materiality or criticality of the relevant workload(s) in light of local requirements. For example, FIs must review considerations in relation to the authorization process as provided under the applicable regulations and tacit authorization requirements (Communication 2022/254). Service outsourcing must be informed to the BCU.
3. Review the AWS Shared Responsibility Model and map AWS responsibilities and customer responsibilities according to each AWS service that will be used. Customers can also use AWS Artifact to access AWS’s audit reports and conduct their assessment of the control responsibilities.
Customers that have further questions about how AWS services can enable their security and compliance needs, or that would like more information, can contact their account representative.
Financial Institutions in Uruguay using AWS should also consider applicable privacy regulations, including Law No. 18,331, sections 37-40 of Law No. 19,670 as amended, and Resolution No. 23 - 2021. Also, for specific Financial Institutions, further legal requirements regarding banking secrecy may be applicable; see for example, Decree-Law No. 15,322.
The AWS whitepaper, Using AWS in the Context of Common Privacy and Data Protection Considerations provides useful information to customers using AWS cloud services to store or process personal data.
Customers that have questions about the applicable regulations, and how these may apply to their use of AWS services, can reach out to their account representative.
Resources
General
Guía de Referencia Rápida sobre Seguridad y Conformidad de AWS
Mediante el uso de AWS, se beneficia de la gran cantidad de controles de seguridad que utilizamos, lo que reduce el número de controles de seguridad que necesita mantener. Sus propios programas de certificación y conformidad se fortalecen, al mismo tiempo que se reduce el costo vinculado con el mantenimiento y la ejecución de sus requisitos de control de seguridad específicos.
Marco de seguridad cibernética NIST. Alineación con el NIST CSF en la nube de AWS
Los controles de seguridad 800-53 del Instituto Nacional de Normalización y Tecnología (NIST) pueden aplicarse de forma general a los sistemas de información federales de EE. UU. Los servicios y la infraestructura de la nube de AWS fueron validados por pruebas de terceros realizadas en función de los controles NIST 800-53 revisión 4, además de los requisitos adicionales de FedRAMP.
Payment Card Industry Data Security Standard (PCI DSS) on AWS
This guide provides customers with information to be able to plan for and document the Payment Card Industry Data Security Standard (PCI DSS) compliance of their AWS workloads. This includes the selection of controls that meet specific PCI DSS requirements, planning of evidence gathering to meet assessment testing procedures, and explaining their control implementation to their PCI Qualified Security Assessor (QSA).
Using AWS in the Context of Common Privacy and Data Protection Considerations
This document provides information to assist customers who want to use AWS to store or process content containing personal data, in the context of common privacy and data protection considerations. It will help customers understand the way AWS services operate, including how customers can address security and encrypt their content. The geographic locations where customers can choose to store content and other relevant considerations. The respective roles the customer and AWS each play in managing and securing content stored on AWS services.
AWS Compliance Quick Reference Guide
AWS has many compliance-enabling features that you can use for your regulated workloads in the AWS cloud. These features allow you to achieve a higher level of security at scale. Cloud-based compliance offers a lower cost of entry, easier operations, and improved agility by providing more oversight, security control, and central automation.
The purpose of this paper is to describe how AWS and our customers in the financial services industry achieve operational resilience using AWS services.
Data Classification and Secure Cloud Adoption
This paper provides insight into classification schemes for public and private organizations to leverage when moving data to the cloud. It identifies practices and models currently implemented by global first movers and early adopters, examines how implementation of these schemes can simplify cloud adoption, and recommends practices to harmonize national requirements to internationally recognized standards and frameworks.
AWS Policy Perspectives: Data Residency
This paper addresses: The real and perceived security risks expressed by governments when they demand in-country data residency. Commercial, public sector, and economic impact of in-country data residency policies with a focus on government data. Considerations for governments to evaluate before enforcing requirements that can unintentionally limit public sector digital transformation goals leading to increased cybersecurity risk.
This document is intended to provide information to assist AWS customers with integrating AWS into their existing control framework supporting their IT environment. This document includes a basic approach to evaluating AWS controls and provides information to assist customers with integrating control environments. This document also addresses AWS-specific information around general cloud computing compliance questions.
Guidelines for systematically reviewing and monitoring your AWS resources for security best practices.