October 11, 2023 at 11:55AM
Moving financial services to the cloud requires careful consideration of security, compliance, and governance. It is important to establish secure use of the cloud and comply with regulations. Cloud governance, including three lines of governance, is crucial. Implementing infrastructure, application, and data pipelines, as well as change management and monitoring, are key. Collaboration among teams and involving trusted third parties is essential. Executives should effectively communicate the cloud strategy and prioritize continuous compliance and risk monitoring. A culture of quick learning and adaptation is important for success.
From the meeting notes, it is clear that there are several important considerations when it comes to financial services moving securely to the cloud. These include:
1. Secure use of the cloud by the financial services industry, including secure configurations, resiliency, and consistent guardrails for developers, infrastructure teams, and security teams.
2. Compliance and regulatory requirements that must be met to demonstrate the effectiveness of the security measures in place.
3. Business objectives and risk appetite.
4. Oversight and governance of the cloud program.
5. Threat and compliance-driven security controls.
6. Continuous monitoring and drift detection.
7. Talent and culture.
It is crucial for organizations to think about how they will govern the cloud migration process. This involves applying appropriate policies, oversight, and technical controls from a threat-driven perspective. Cloud governance is key for financial services, and it includes establishing clear policies and procedures to effectively manage cloud resources. There are three lines of governance important for cloud governance: the first line responsible for day-to-day management, the second line responsible for oversight, and the third line responsible for providing independent assurance.
When implementing an organizational, operational, and technological approach to cloud governance, the following aspects should be considered:
1. Infrastructure, application, and data pipelines for deploying, managing, and securing cloud resources.
2. Change management processes.
3. Policy revisions and updates.
4. Monitoring of cloud resources for security.
5. Asset inventories to track cloud resources.
6. Taking an “everything as code” approach for scalability and repeatability.
Financial services being a highly regulated industry, a cloud-native approach should be taken to mitigate risk and alleviate concerns. This requires collaboration among various teams, including frontline, technology, business, security, tech controls, operational risk management, and audit teams. Trusted third parties may also be involved, and their work should be verified and their expertise utilized.
From an executive perspective, it is important to effectively communicate the cloud strategy and its benefits to the business. This includes demonstrating how security and compliance controls are continuously monitored and maintained. 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, involvement of trusted third parties, effective communication, and continuous compliance and risk monitoring are crucial. Culture plays an important role in successful organizational change management.