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Cloud services do not transfer a financial institution’s accountability for protecting its data. Effective protection depends on knowing which party operates each control, limiting access to data and keys, overseeing providers, and applying the requirements that actually cover the institution and information involved. The right control set depends on the service, its configuration, the data it handles, and the institution’s jurisdiction.
Start by mapping data, services, and responsibility
Before selecting safeguards, identify the cloud services in use, the data they store or process, how that data moves, and which business functions depend on them. Include service dependencies and subcontractors where relevant. Classify data and assets so controls can be chosen according to risk and applicable obligations.
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For each service, document who configures, operates, monitors, and provides evidence for each control: the institution, the cloud provider, or another provider in the chain. Make the shared-responsibility model specific to the service and configuration. A provider’s general certification or assurance report does not by itself establish that the institution’s complete system is covered or correctly configured.
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The FFIEC’s April 30, 2020 cloud computing statement cautions that “management should not assume that effective security and resilience controls exist simply because the technology systems are operating in a cloud computing environment.” It highlights shared responsibilities and management understanding; it does not create new regulatory expectations.
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Apply layered identity and access controls
Set access according to risk for customers, employees, administrators, and third parties. Use least privilege, make users accountable for their activity, review access periodically, and manage account creation, changes, and removal as part of the account lifecycle. Pay particular attention to privileged and remote access, where a compromised account can have broader consequences.
The FFIEC’s August 11, 2021 authentication and access guidance supports risk-based, layered safeguards. It says multi-factor authentication (MFA), or controls of equivalent strength, can mitigate risks more effectively than single-factor authentication. The appropriate measures depend on the access and risk; the guidance does not establish one universal configuration for every cloud service.
For covered EU financial entities, the technical standards under DORA also address logical and physical access procedures, need-to-know access, user accountability, periodic access reviews, and strong authentication in specified remote or privileged-access contexts.
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Choose protections based on data classification, the service architecture, and applicable obligations. DORA’s technical standards address protecting data in use, in transit, and at rest, as well as security for storage media, systems, and endpoints. They also cover cryptographic techniques and policies. These sources do not establish one encryption algorithm or architecture as universally required for all financial data.
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Document who controls encryption keys and who can access them, including provider personnel and subcontractors where applicable. For payment-card scope, encryption alone does not automatically take a service out of scope. The relevant PCI SSC FAQ describes a conditional case: a provider holding only another party’s encrypted cardholder data may be able to treat that data as out of scope if it cannot decrypt it and has no access to the keys or clear-text data. Confirm current PCI DSS scoping guidance against the actual architecture before relying on that conclusion.
Does PCI DSS apply to bank account data?
Not solely because it is bank account data. PCI DSS concerns payment account data and systems or providers that can affect its security. PCI SSC says ordinary bank account, routing, or sort-code numbers alone are not payment-card data under PCI DSS. Its caveat is that a number may be in scope if it also includes a primary account number (PAN) under the standard’s conditions. Other legal, contractual, and security requirements may still apply to bank account data even where PCI DSS does not.
Oversee cloud providers and their subcontractors
Outsourcing a service does not eliminate the institution’s responsibility to understand and oversee the arrangement. Assess providers before engagement, establish written terms, identify which party is responsible for each applicable requirement, and maintain oversight during the relationship. Where relevant, arrangements should address incident cooperation, access to audit evidence, subcontractor visibility, recovery expectations, and practical data return and exit provisions.
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For payment environments, PCI SSC’s third-party guidance calls for due diligence, appropriate written agreements, allocation of applicable requirements between the parties, and monitoring provider PCI DSS status at least annually. A provider’s attestation is not a substitute for determining which requirements remain the customer’s responsibility.
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Include availability, recovery, and exit in protection plans
Protecting financial data means planning for availability and resilience as well as confidentiality. Define how the provider will notify and assist the institution during incidents, what recovery capabilities and evidence are needed, and how critical services will continue if a dependency is unavailable. Ensure the institution can retrieve its data and transition away from the provider under the applicable arrangement.
For covered EU entities, DORA makes ICT third-party risk part of the entity’s ICT risk-management framework and requires risk management and contractual arrangements for ICT services. The specific duties depend on the entity and service, so determine applicability rather than assuming that every financial business has the same obligations.
Compare cloud services on the controls that matter
Evaluate the actual service and configuration, not just a provider’s broad security claims. Use these questions to compare options:
| Evaluation area | What to establish |
|---|---|
| Control ownership | Who configures, operates, monitors, and evidences each control? |
| Data and key access | Who can access plaintext or cryptographic keys, including administrators and subcontractors? |
| Scope and assurance | Does provider assurance cover the precise service and environment in use, and which responsibilities remain with the institution? |
| Resilience and exit | What recovery, incident-cooperation, continuity, data-return, and exit arrangements are available? |
| Jurisdiction and entity scope | Which supervisory expectations, standards, or regulations apply to this institution, service, and data? |
Determine which framework applies
United States: FFIEC and OCC supervisory guidance
The FFIEC issued its cloud computing statement on April 30, 2020. It emphasizes management understanding of shared responsibilities and effective risk management; it expressly says it does not contain new regulatory expectations. OCC Bulletin 2020-46 says the joint statement applies to community banks and describes effective risk management for safe and sound cloud computing. The FFIEC’s August 11, 2021 authentication guidance addresses customers, employees, and third parties accessing financial institution services and systems.
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Payment environments: PCI DSS
PCI DSS is relevant to payment account data and systems or providers that can affect its security, not automatically to every financial record. For outsourced payment services, establish provider duties and continue the customer’s oversight, including annual monitoring of provider PCI DSS status.
European Union: DORA
Regulation (EU) 2022/2554, known as DORA, has applied since January 17, 2025. It covers specified financial entities and establishes duties concerning ICT risk management, digital operational resilience, and ICT third-party risk. Verify whether the particular entity falls within its scope. Commission Delegated Regulation (EU) 2024/1774 details ICT security policies and controls, including access control, data and network security, monitoring, and protections intended to preserve confidentiality, integrity, availability, and authenticity.
These frameworks address different questions and do not substitute for one another. Confirm the current consolidated legal or standards text and the institution’s specific obligations when determining what to implement.
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