Welcome!

Government Cloud Authors: William Schmarzo, Yeshim Deniz, Kevin Jackson, Carmen Gonzalez, Elizabeth White

Related Topics: @CloudExpo, Java IoT, Microservices Expo, Containers Expo Blog, Machine Learning , Agile Computing, Cloud Security, Government Cloud

@CloudExpo: Blog Post

FFIEC's Recognition of Cloud Security Advantages

How credit unions, smaller banks can now use outsourcing for compliance using security-as-a-service

Last month the Federal Financial Institutions Examination Council (FFIEC) shared an opinion on the viability and security of cloud computing. In the four-page statement, the interagency body empowered to prescribe uniform principles, standards, stated that cloud computing is “another form of outsourcing with the same basic risk characteristics and risk management requirements as traditional forms of outsourcing.”

What they are offering is a back-handed endorsement of cloud computing with the caveat that if you perform your due diligence and the solution passes the security smell test, there is no reason why a financial institution cannot enjoy the full scope of cloud based benefits.

Like most other industries on the planet, banks, credit unions, investment brokerages, hedge funds, title and mortgage companies, credit card enterprises outsource certain parts of their business for a variety of reasons. In some cases, it is a skill that is outside their core competencies like the physical transference of currency (armored cars). For others it incorporates economic and efficiency factors like reducing and controlling costs, expanding operational capacity, and employing best-of-breed philosophies. Regardless of the reasoning, outsourcing is an integral part of international business standards.

“Outsourcing to a cloud service provider can be advantageous to financial institutions because of potential benefits such as cost reduction, flexibility, scalability, improved load balancing, and speed.” FFIEC Information Technology Subcommittee July 10, 2012

This is especially good news for credit unions and other smaller finance-centric enterprise organizations on the hook for compliance, heightened data and asset protection and access control   just like their multi-national brethren. In that the FFIEC has labeled cloud computing as an acceptable practice, I want to focus on three specific callouts that directly affect how and why security managed from the cloud (aka cloud-based security) fits with the strategic technology goals of any financial institution.

  • Legal and Regulatory Considerations All financial institutions operate under the heavy scrutiny of federal, state, local and industrial standards. It demands a certain degree of transparency (as well as privacy), a certain reliance on reporting and auditing, and heavy emphasis on compliance with various requirements. Although a serious and very complex issue, the ability to depend on several factors managed from the cloud, eases some of the burden. Regardless of where sensitive financial, personal and transactional data and is stored security-as-a-service typically provides the best-of-breed oversight institutions demand. Strictly from a security management perspective, understanding who and how and when any endpoint is attempting to access or ping a network asset at any time day or night is not only good practice, but a strict edict of laws like PCI and Sarbanes Oxley. But taken one step further, the ability to look beyond the obvious brute force attacks, the ability to instantly analyze traffic from a variety of silos and the ability inform, escalate and report any anomalies bases on strict interpretation of the law, creates. The cloud fits this stratagem simply by providing the additional expertise, faster and more accurate auditing and more “bang for the buck.

”I recall what a Network Apps Manager from Texas Capital Bank stated in a recent conference: "We get audited. We get audited a lot! In the span of a typical year we are audited by 6 different external and regulatory compliance groups." I get dizzy just thinking of the constant drain on resources it takes to keep up with it all. Not to put a fine point on it, but just consider the manpower, reporting and computing  relief an organization can experience simply by outsourcing Identity Management to provision and de-provision users , customers and vendors...not to mention the additional control from SaaS Single Sign On.

  • Holistic InfoSec All Financial institutions are typically at the center of many hacking attacks. The rule of thumb with cloud-based (or really any security strategy), is don’t worry about the attacks you can see coming. Most of the truly devastating breaches come from more insidious sources that are quiet and subtle. It is these types of assaults that look for cracks in a multitude of small, seemingly insignificant corners. This is why any strategy must contain a holistic approach. One that looks at and ties together the various and varied silos of information. This situational context approach identifies issues that might not raise red flags in one silo, but when correlated with other data points might require reporting, escalation and instant remediation.

And it’s no secret that global hackers have set their sites on American financial institutions but if you are running a credit union in Watertown, MN, do you need to fear nation-state cyber-terrorism? Probably not as much as Citibank, but shoring up your network perimeter is a must. Solutions like SIEM and Log Management have an excellent track record managed from the cloud. Other considerations such as careless third party users and employees, password mismanagement, poor vetting of third-party security protocols, access controls, must be addressed to achieve a true holistic approach strategy.  But for that credit union in Watertown or the title company in Carpenteria, CA there is limited budget to apply such an enterprise strategy. And that’s where cloud security comes in as a huge benefit. Security-as-a-service is typically a cash flow positive endeavor. This means there is no capital expenditures (it’s all OpEx) and there is no ROI lag time in terms of buying an expensive server or waiting 6 months to develop and deploy and appropriate program. Zero day deployment and pay-as-you-go scalability provide immediate return and immediate coverage.

  • Data segregation and recoverability: The nature of this issue is the overall security of data regardless of where and how it is stored. There are many whose lack of trust in the cloud prevents them from seeing that just because data is sitting on a server outside their four walls, means it is any less secure. By using the advice of the FFIEC, applying risk assessments against any outsourced solution, . It’s the same for any investment. If you do poor research on a electronic lock company, there are catastrophic risks involved. Many cloud providers invest a great deal in their security features. And of course, a company the sells security-as-a-service, must be as or more bulletproof than any on premises alternative in its ability to maintain data security, IT integrity and guaranteed continued service.

Now this isn’t aimed so much at Bank of America or Goldman Sachs, but rather “Main Street” institutions who don’t have a spare $100K waiting to spend on on-premise servers, $1 million to develop and deploy a holistic security strategy and another $150K for dedicated analysts to monitor activity around the clock. Cloud-based security provides more functionality, greater scope, and greater manageability than a typical local institution can afford to do in house. Through multi-tenancy, economies of scope and leveraged enterprise best-of-breed expertise and capabilities, every financial institution can benefit from top-class security…as long as they do their homework!

As with any business decision, whether to migrate certain aspects of enterprise operation to the cloud, depends on several factors. Does it promote your strategic and tactical plans/goals? Have you done your homework and made sure both the vendor and the solution are a good (and trustworthy) fit? Does it provide ROI in a reasonable/expected time frame? Does the reward outpace the risk? Is the risk manageable? I could go on. But the argument is no longer be should I utilize the cloud. The better question is in what situations and how do cloud based solutions create benefit and advantages for my company?

If you wish to learn more about the application of holistic security, read the white paper: Applying Security Holistically from the Cloud: A Paradigm Shift Applying Situational Awareness in SIEM Deployments.

Kevin Nikkhoo

CloudAccess.com

More Stories By Kevin Nikkhoo

With more than 32 years of experience in information technology, and an extensive and successful entrepreneurial background, Kevin Nikkhoo is the CEO of the dynamic security-as-a-service startup Cloud Access. CloudAccess is at the forefront of the latest evolution of IT asset protection--the cloud.

Kevin holds a Bachelor of Science in Computer Engineering from McGill University, Master of Computer Engineering at California State University, Los Angeles, and an MBA from the University of Southern California with emphasis in entrepreneurial studies.

Comments (0)

Share your thoughts on this story.

Add your comment
You must be signed in to add a comment. Sign-in | Register

In accordance with our Comment Policy, we encourage comments that are on topic, relevant and to-the-point. We will remove comments that include profanity, personal attacks, racial slurs, threats of violence, or other inappropriate material that violates our Terms and Conditions, and will block users who make repeated violations. We ask all readers to expect diversity of opinion and to treat one another with dignity and respect.


@ThingsExpo Stories
A strange thing is happening along the way to the Internet of Things, namely far too many devices to work with and manage. It has become clear that we'll need much higher efficiency user experiences that can allow us to more easily and scalably work with the thousands of devices that will soon be in each of our lives. Enter the conversational interface revolution, combining bots we can literally talk with, gesture to, and even direct with our thoughts, with embedded artificial intelligence, whic...
New competitors, disruptive technologies, and growing expectations are pushing every business to both adopt and deliver new digital services. This ‘Digital Transformation’ demands rapid delivery and continuous iteration of new competitive services via multiple channels, which in turn demands new service delivery techniques – including DevOps. In this power panel at @DevOpsSummit 20th Cloud Expo, moderated by DevOps Conference Co-Chair Andi Mann, panelists will examine how DevOps helps to meet th...
Every successful software product evolves from an idea to an enterprise system. Notably, the same way is passed by the product owner's company. In his session at 20th Cloud Expo, Oleg Lola, CEO of MobiDev, will provide a generalized overview of the evolution of a software product, the product owner, the needs that arise at various stages of this process, and the value brought by a software development partner to the product owner as a response to these needs.
SYS-CON Events announced today that A&I Solutions has been named “Bronze Sponsor” of SYS-CON's 20th International Cloud Expo®, which will take place on June 6-8, 2017, at the Javits Center in New York City, NY. Founded in 1999, A&I Solutions is a leading information technology (IT) software and services provider focusing on best-in-class enterprise solutions. By partnering with industry leaders in technology, A&I assures customers high performance levels across all IT environments including: mai...
SYS-CON Events announced today that Tappest will exhibit MooseFS at SYS-CON's 20th International Cloud Expo®, which will take place on June 6-8, 2017, at the Javits Center in New York City, NY. MooseFS is a breakthrough concept in the storage industry. It allows you to secure stored data with either duplication or erasure coding using any server. The newest – 4.0 version of the software enables users to maintain the redundancy level with even 50% less hard drive space required. The software func...
Most technology leaders, contemporary and from the hardware era, are reshaping their businesses to do software in the hope of capturing value in IoT. Although IoT is relatively new in the market, it has already gone through many promotional terms such as IoE, IoX, SDX, Edge/Fog, Mist Compute, etc. Ultimately, irrespective of the name, it is about deriving value from independent software assets participating in an ecosystem as one comprehensive solution.
SYS-CON Events announced today that EARP will exhibit at SYS-CON's 20th International Cloud Expo®, which will take place on June 6-8, 2017, at the Javits Center in New York City, NY. "We are a software house, so we perfectly understand challenges that other software houses face in their projects. We can augment a team, that will work with the same standards and processes as our partners' internal teams. Our teams will deliver the same quality within the required time and budget just as our partn...
SYS-CON Events announced today that delaPlex will exhibit at SYS-CON's @ThingsExpo, which will take place on June 6-8, 2017, at the Javits Center in New York City, NY. delaPlex pioneered Software Development as a Service (SDaaS), which provides scalable resources to build, test, and deploy software. It’s a fast and more reliable way to develop a new product or expand your in-house team.
In his keynote at @ThingsExpo, Chris Matthieu, Director of IoT Engineering at Citrix and co-founder and CTO of Octoblu, focused on building an IoT platform and company. He provided a behind-the-scenes look at Octoblu’s platform, business, and pivots along the way (including the Citrix acquisition of Octoblu).
SYS-CON Events announced today that Outscale, a global pure play Infrastructure as a Service provider and strategic partner of Dassault Systèmes, will exhibit at SYS-CON's 20th International Cloud Expo®, which will take place on June 6-8, 2017, at the Javits Center in New York City, NY. Founded in 2010, Outscale simplifies infrastructure complexities and boosts the business agility of its customers. Outscale delivers a secure, reliable and industrial strength solution for its customers, which in...
SYS-CON Events announced today that Outscale will exhibit at SYS-CON's 20th International Cloud Expo®, which will take place on June 6-8, 2017, at the Javits Center in New York City, NY. Outscale's technology makes an automated and adaptable Cloud available to businesses, supporting them in the most complex IT projects while controlling their operational aspects. You boost your IT infrastructure's reactivity, with request responses that only take a few seconds.
SYS-CON Events announced today that Systena America will exhibit at SYS-CON's 20th International Cloud Expo®, which will take place on June 6-8, 2017, at the Javits Center in New York City, NY. Systena Group has been in business for various software development and verification in Japan, US, ASEAN, and China by utilizing the knowledge we gained from all types of device development for various industries including smartphones (Android/iOS), wireless communication, security technology and IoT serv...
DevOps at Cloud Expo – being held October 31 - November 2, 2017, at the Santa Clara Convention Center in Santa Clara, CA – announces that its Call for Papers is open. Born out of proven success in agile development, cloud computing, and process automation, DevOps is a macro trend you cannot afford to miss. From showcase success stories from early adopters and web-scale businesses, DevOps is expanding to organizations of all sizes, including the world's largest enterprises – and delivering real r...
Five years ago development was seen as a dead-end career, now it’s anything but – with an explosion in mobile and IoT initiatives increasing the demand for skilled engineers. But apart from having a ready supply of great coders, what constitutes true ‘DevOps Royalty’? It’ll be the ability to craft resilient architectures, supportability, security everywhere across the software lifecycle. In his keynote at @DevOpsSummit at 20th Cloud Expo, Jeffrey Scheaffer, GM and SVP, Continuous Delivery Busine...
In order to meet the rapidly changing demands of today’s customers, companies are continually forced to redefine their business strategies in order to meet these needs, stay relevant and continue to see profitable growth. IoT deployment and development is integral in this transformation, and today businesses are increasingly seeing the value of investing their resources into IoT deployments. These technologies are able increase ROI through projects such as connecting supply chains or enabling sm...
SYS-CON Events announced today that CollabNet, a global leader in enterprise software development, release automation and DevOps solutions, will be a Bronze Sponsor of SYS-CON's 20th International Cloud Expo®, taking place from June 6-8, 2017, at the Javits Center in New York City, NY. CollabNet offers a broad range of solutions with the mission of helping modern organizations deliver quality software at speed. The company’s latest innovation, the DevOps Lifecycle Manager (DLM), supports Value S...
SYS-CON Events announced today that Peak 10, Inc., a national IT infrastructure and cloud services provider, will exhibit at SYS-CON's 20th International Cloud Expo®, which will take place on June 6-8, 2017, at the Javits Center in New York City, NY. Peak 10 provides reliable, tailored data center and network services, cloud and managed services. Its solutions are designed to scale and adapt to customers’ changing business needs, enabling them to lower costs, improve performance and focus intern...
Everywhere we turn in our industry we can find strong opinions about the direction, type and nature of cloud’s impact on computing and business. Another word that is used in every context in our industry is “hybrid.” In his session at 20th Cloud Expo, Alvaro Gonzalez, Director of Technical, Partner and Field Marketing at Peak 10, will use a combination of a few conceptual props and some research recently commissioned by Peak 10 to offer a real-world consideration of how the various categories of...
SYS-CON Events announced today that Super Micro Computer, Inc., a global leader in compute, storage and networking technologies, will exhibit at SYS-CON's 20th International Cloud Expo®, which will take place on June 6-8, 2017, at the Javits Center in New York City, NY. Supermicro (NASDAQ: SMCI), the leading innovator in high-performance, high-efficiency server technology, is a premier provider of advanced server Building Block Solutions® for Data Center, Cloud Computing, Enterprise IT, Hadoop/...
With major technology companies and startups seriously embracing Cloud strategies, now is the perfect time to attend @CloudExpo | @ThingsExpo, June 6-8, 2017, at the Javits Center in New York City, NY and October 31 - November 2, 2017, Santa Clara Convention Center, CA. Learn what is going on, contribute to the discussions, and ensure that your enterprise is on the right path to Digital Transformation.