When it comes to financial services moving securely to the cloud, there are several important considerations. Secure cloud usage first starts with secure use of the cloud by the financial services industry, including secure configurations, resiliency, and using pipelines that ensure consistent guardrails for developers, infrastructure teams, and security teams. This is layered on top of a secure foundation from cloud service providers. Additionally, there are compliance and regulatory requirements that must be met in order to demonstrate the effectiveness of the security measures in place.
Key areas to consider:
When migrating to the cloud, every organization must think about how they’ll govern the process. This includes applying appropriate policies and oversight, as well as implementing technical controls. It is crucial to approach this from a threat-driven perspective, considering the various threat actors that may try to compromise security practices and policies.
Cloud Governance is Key
For financial services, cloud governance is essential. Cloud governance is a set of policies and procedures that help organizations manage their cloud computing resources effectively. It is important to establish a clear cloud governance structure before moving to the cloud, as it helps ensure that cloud resources are used securely and efficiently. This requires an organizational, operational, and technological approach to assist financial services in leveraging the cloud.
There are three lines of governance that are important for cloud governance:
When implementing an organizational, operational, and technological approach to cloud governance, you should consider the following:
What to Consider With Cloud Adoption
As you move to adopt the above, it’s important to take an “everything as code” approach, in order to scale the operations and ensure repeatability in deploying, recovering applications, and ensuring controls are working effectively.
Financial services is a highly regulated industry, and cloud adoption brings increased scrutiny from regulatory and compliance partners. To address this, a cloud-native approach should be taken to mitigate risk and alleviate concerns. This requires collaboration among different teams, including frontline, technology, business, security, tech controls, operational risk management, and audit teams. By working together, a secure and compliant framework can be established.
Trusted third parties may also be involved in the implementation process. It is important to consider how their work will be verified and how their expertise can support the project. This may involve testing and verification of audit and compliance solutions.
From an executive perspective, it is crucial to communicate the cloud strategy and its benefits to the business. This includes demonstrating how security and compliance controls are continuously monitored and maintained. The cloud offers opportunities to showcase compliance and risk through data analysis. Gradual improvements should be made to the control environment over time, fostering a culture of quick learning and adaptation.
In summary, financial services moving to the cloud must address security, compliance, and governance considerations. Collaboration among various teams is essential, as is the involvement of trusted third parties. Executives should effectively communicate the cloud strategy and ensure continuous compliance and risk monitoring. As with all organizational change management, culture is an important aspect to keeping the team motivated and being able to fail fast. This culture has to be demonstrated by leadership and all teams working collaboratively to achieve the mission.