Amazon Glacier Update – Third-Party SEC 17a-4(f) Assessment for Vault Lock
Amazon Glacier is designed to store any amount of archival or backup data with high durability. Amazon Glacier is a very cost-effective solution (as low as $0.007 per gigabyte per month) for data that is infrequently accessed, and where a retrieval time of several hours is acceptable.
Earlier this year we introduced a new Amazon Glacier compliance feature called Vault Lock (see my post, Create Write-Once-Read-Many Archive Storage with Amazon Glacier, to learn more). As I wrote at the time, this feature allows you to lock your Amazon Glacier vaults with compliance controls that are designed (per SEC Rule 17a-4(f)) to help meet the requirement that “electronic records must be preserved exclusively in a non-rewritable and non-erasable format.”
That announcement brought Amazon Glacier to the attention of AWS customers in the financial services industry. Large banks, broker-dealers, and securities clearinghouses have all expressed interest in this important new feature.
New Third-Party Assessment Report
Today I am pleased to be able to announce that we have received a third-party assessment report that speaks to Amazon Glacier’s ability to help meet the requirements of SEC 17a-4(f).
This assessment is provided by Cohasset Associates, a highly respected consulting firm with more than 40 years of experience and knowledge related to the legal, technical, and operational issues associated with the records management practices of companies regulated by the US SEC (Securities and Exchange Commission) and the US CFTC (Commodity Futures Trading Commission).
The full assessment (which is actually fairly interesting) provides a detailed look at the logic that Amazon Glacier uses to create immutable policies, along with a step-by-step examination and exposition of the controls that are used to protect Amazon Glacier vaults for compliance use cases once they have been locked (again, more information on this procedure can be found in the blog post that I referenced above).