The use ofCloud Computingby FinancialInstitutionsCBa louFo n dru kinm g4 JUNE 2020TECHNICAL PAPERwww.ebf.eu1
CONTENTSAbbreviationsChapters31 Introduction42 Overview of cloud services62.1 Cloud composition62.2 Different cloud service models72.3 Industry experience with cloud83 Why European banks use cloud services94 Understanding of cloud computing134.1 Cloud-specific considerations under a risk-based approach144.2 Categorizing the associated control demand of a cloud offering144.3 Different roles of banks and Cloud Service Providers184.4 Careful consideration of cloud migration205 Conclusion24GlossaryAnnex26Annex 1Use case: IoT29Use case: Online Collaboration31Annex 2Annex 3-5 Data Use cases preliminary remarks33Annex 3Use case: Data Lake Processing34Annex 4Use case: Data Discovery Lab35Annex 5Use case: Data analysis and regulatory reporting36Annex 6Use case: Transformational Technologies37Annex 7Use Case: Early Warning System (EWS)382
ABBREVIATIONSADActive directoryADFSActive Directory Federation ServicesAIArtificial intelligenceBARE METALBase IT infrastructure enabling cloud computingCAPEXCapital ExpenditureCOBITControl Objectives for Information and Related Technologies(by the Systems Audit and Control Association)CSCCloud Service CustomerCSPCloud Service ProviderFIFinancial InstitutionGDPRGeneral Data Protection RegulationIoTInternet of thingsITILSet of detailed practices for IT service management(formerly Information Technology Infrastructure Library)MLMachine learningNCANational Competent AuthorityOPEXOperational ExpenditureSDLCSolution Delivery LifecycleSLAService Level AgreementsVSIVirtual Server Infrastructure3
CHAPTERONE1 IntroductionOver the recent years, cloud computing hasbecome a significant technological enabler forinnovative service development. Cloud allowsindustries to tap into new service models, utilisingits technological advancement for new and betterservices to customers, improving productivity,cost-efficiency and flexibility of internal businessprocesses. Ultimately, cloud computing can providea foundation for the digital transformation of theindustry in question.The financial sector is in the process of adoptingcloud computing to take advantage of theaforementioned benefits. New opportunities forservice delivery to customers, serving their needsand expectations, are as relevant as improvingsecurity, reducing costs and improving flexibilityin the conduct of business. Cloud can also opennew markets and enable mature financial servicesinstitutions to find new ways of competing withFinTech market entrants.The cloud security framework matured fast andheavily. Nowadays, cloud computing seems to beas well-placed as (if not better than)other traditional IT paradigms when it comes tosafeguarding integrity and availability. Cloudservices embody redundancy, high availabilityand resiliency thanks to their distributed nature.Public cloud gives the ability to scale at a moresignificant level than financial institutions would beable to achieve on their own. Resilience, speed andsecurity are the building blocks of cloudofferings and the core business of any CloudService Provider (CSPs). In most cases, CSPs havestronger security than most individual companiescan maintain and manage on-site. Moreover, thebig cloud providers have large teams of securityengineers and, given that cloud is (one of) theircore businesses, they are continuously investing inmeeting the strictest and newest security standardsthat constantly adapt to managing evolving threatvectors and threat actors.However, cloud adoption by the financial industryhas to consider the highly regulated nature ofthe sector and pay special attention to stabilityand safety. European banks operate within aframework of financial rules aimed at ensuringproper governance and control of risks (internalgovernance guidelines), especially in thosesituations where third parties are involved in theoperation of ICT systems1. These rules set1EBA Guidelines on ICT and security risk management (under ecurity-risk-management.4
This paper aims to support financial institutionsand competent authorities’ understanding ofthe advantages and particularities of cloudcomputing in areas such as security, riskmitigation and regulatory compliance.Significant features of cloud technology infinancial services require special attention andconsideration. Looking at the fast-evolving cloudservice environment as well as the close interactionof European banks with their supervisors in differentMember States, a harmonised approach to theconsiderations presented by national competentauthorities (NCAs) will be essential. Cloudcomputing’s potential for agility and flexibility goesbeyond the framework of a single jurisdiction.A fragmented understanding of cloud by NCAsregarding key considerations can severelyhamper the systematic approach of Europeanbanks to cloud, whether they rely on one ormultiple providers in a multi-cloud environment.By contrast, a harmonious understanding of cloudacross European borders will foster the adoptionof public/hybrid cloud and multi- cloud use byEuropean banks in a more unified way.Ultimately, banks would be able to provide moreinnovative services to their customers across Europe,allowing FIs to focus on their core businesses,while leveraging the specialty of CSPs to providesecure, scalable, reliable, and fast networks andcomputing.This paper aims to support the necessaryunderstanding of cloud use by financial institutions.Mindful of the complexity of both the technologyitself and banks careful implementation of it withintheir business processes, not all relevant aspectsof cloud can be addressed comprehensively inthis single document. Instead, additional technicalpapers of the EBF Cloud Banking Forum will target,at a later stage, specific issues of relevance. Thisis the reason why issues such as cybersecurity,though highly important for the adoption of cloudtechnology across all industry sectors, will not bedeveloped in detail in the following chapters.“ Cloud solutionsoffer banksthe flexibility totailor the scalingup of capacityto meet theiractivity levels“the framework for supervisory engagement withEuropean banks throughout the entire life of thecloud relationship in the EU’s financial sector.Mindful of possible risks triggered by cloudtechnology, thorough assessments are conductedon the potential impact of cloud on financialinstitutions’ operational risk, to be assessedagainst the operational risk posture of the currentIT environment. Hence, understanding of thetechnology and its implications for operationalprocesses is critical.5
CHAPTERTWO2 Overview ofcloud servicesIn order to gain a deeper understanding ofthe advantages and specifics of cloud computing,it is necessary first to take a look at existing cloudcompositions and service models.2.1 Cloud compositionCloud computing deployment can bedistinguished according to three categories:Public Cloud is a cloud computing environmentwhere cloud solutions are located outside thebank’s perimeter. Therefore, within a public cloudsetup, not all controls will be operated by theinstitution itself. This does not change accountabilityof Cloud Service Customers (CSCs) according tothe applicable legal framework. Logical accesscontrol functions are provided to the companyusing publicly hosted cloud services (e.g. throughauthentication mechanisms), any other companycan subscribe to the same services, available overthe internet.Computing resources are used solely by the onesingle organisation, either physically in thecompany’s on-site data centre(s) (“on-premises”)or externally with the third-party provider(“hosted private cloud”).A hybrid cloud solution is an integrated cloudservice, using both private and public cloudsto perform distinct functions within the sameorganisation. Hybrid cloud adoption reflects amacro trend common to all financial institutionsand is viewed as a key enabler for next generationtechnologies, free movement of data andintegration into the ecosystem.Hybrid Cloud for the purpose of this paper isdefined as a cloud computing environment thatuses a combination of private cloud (where mostfinancial institutions started their cloud journey) andpublic cloud services that may include third partyservice offerings such as Platform as a Service(Paas), Infrastructure as a Service (IaaS) andSaaS (Software as a Service). These platformsare connected through automation andorchestration tools.Private cloud solutions are located inside thebanks’ own perimeter and therefore leverage all theestablished controls of the respective bank.6
2.2 Different cloud service modelsservice models which will further evolve in thefuture.Cloud services know multiple facets of servicedesign, each with effects on the role of CSP andCSCs. It is important to recognise that cloud’spotential is not limited to the simple external datastorage, but rather consists of fast-developingWhen looking at these cloud solutions – especiallyfrom a risk-based approach – distinctions mustbe made between different models, triggered bytechnological differences.TABLE 1Infrastructure as a Service(IaaS)Platform as a Service(PaaS)Container as a Service(CaaS)Software as a Service(SaaS)Supplies customers with ITinfrastructure, provided andmanaged over the internet ona pay-as-you-use basis,e.g. servers and storage.The two common models ofdelivery for IaaS are ‘baremetal’ and Virtual ServerInfrastructure (VSI). In the caseof bare metal the financialinstitution or their designeemanages the servers,storage, virtualisation, OS,middleware, runtime, dataand applications. In the VSImodel the financialinstitution manages the OS,middleware, runtime, dataand applications.Supplies customers with anon-demand environmentfor developing, testing,delivering and managingsoftware applications overthe internet. The financialinstitution manages its dataand applications.Offering for containerbased virtualisation inwhich CSPs offer a completeframework to customers fordeploying and managingcontainers, applicationsand clusters. CaaS offers acompletely enabled containerdeployment service withsecurity and governancecontrol for IT management.Allows customers to connectto and use cloud-basedapplication over the interneton a subscription basis e.g. anonline collaboration tool. Theentire stack is managed bythe service provider.Within the CSP market, many engagement models deploy these services to market, for example captive models,fixed-term contracts, open models, pay per use. Considering these different cloud service models, please takenote of the following overview for IT functions in a hybrid cloud environment (example).FIGURE 2Hybrid CloudCI/CD ToolchainEnterprise GUIApplicationDataPS g ServerStorageNetworkPublicHybridPrivate7
2.3 Industry experience with cloudAccording to Eurostat, cloud computing usageby EU enterprises grew rapidly over the last fewyears. While in 2014 it still stood at 19%, in 2016the number increased to 21%2. In 2018, 26% ofEU enterprises with at least 10 persons employedpurchased cloud computing services3.Today, the use of cloud – though innovative andconstantly evolving at a technological level – isgenerally known to European enterprises. SaaSmodels have been adopted over the recent years,familiarising enterprises with subscriptions tosoftware hosted at CSP facilities.FIGURE 3Use of cloud computing services and high level dependence on the cloud, 2018 (% of enterprises)706050403020Use cloud computingbosnia and rkNetherlandsIrelandUnited aBulgaria0EU-2810High levelFIGURE 4Use of cloud computing services in enterprises, by purpose, 2014, 2016 and 2018 (% of enterprises using the cloud)80706965 666862605353485041403444393832 31302927212023 2117100E-mailStorage offilesSource: Eurostat (online data code: isoc cicce use)OfficeSoftware2018Hosting theenterprise’sdatabase(s)2016Financial or CRMaccounting ower forenterprise’sown software20142Eurostat, -e03f9f713235.Ibid.38
CHAPTERTHREE3 Why Europeanbanks use cloudservicesBanks require intensive use of technology foroperation. Traditionally this has been solved byon-premises systems, deployed locally on thecompany’s own computer infrastructure. However,the progress of technology has accelerateddramatically, requiring banks to embrace thisdevelopment in the financial market. They do soconsciously and strategically.Cloud has become a key technology to developnew financial services and to innovate, tocollaborate with third parties and to compete inthe digital context. The market dictates the speedof change. Flexibility and time to market areimperative for banks and cloud computing is thetechnology with the greatest potential to meet bothneeds. Banks need cloud technology to competewith other non-regulated players entering themarketplace on a level playing field. Innovative,fast-evolving cloud technologies allow banks totake advantage of the best-suited technology forcustomers and business processes at each moment.Nowadays customers demand immediacy andpersonalisation. This can require banks to rely onthird parties that provide new – sometimestailor-made – general-purpose services.Cloud also creates opportunities for increasingspecialisation. Banks can dedicate their top talentto business problems while leveraging CSPs fornon-core capabilities like management ofinfrastructure.Recent mergers and acquisitions in the marketreflect strategic considerations of market playersin terms of promising IT tools for future businessoperation. Market developments show that themajority of IT tools needed to serve customers’needs will run ‘cloud first strategies’ in the future.Consequently, slowing down a financial institution’spath to cloud adoption might limit the institution’scompetitiveness compared to FinTechs and BigTechs in particular. Today, banks face an overalltrend in the IT industry, that can be expected tofurther increase over time.A driver for this trend is the opportunity to use cloudfor access to transformational technologies. Thispossibility complements the general benefit of cloudto access vast and increasing volumes of data ina cloud-ecosystem. Transformation technologiesare fundamentally and rapidly changing the waywe think about business today. They are drivinga shift of investment from legacy technology and9
business strategy to investment in more innovativebusiness models, supported by the new innovativetechnologies, and they are essential to undertakingsto remain competitive, viable and potentiallymore secure. For example, Distributed LedgerTechnology promises to transform the speed,efficiency and trust of transaction processing.Analytics and “Big Data” technologies promise toprovide many benefits, including advanced insightsinto complex data sets, driving new businessopportunities, reducing fraud and significantlyimproving cyber security intelligence. Likewise, AIenables increasingly complex interactions betweenentities, e.g. helping end users with problemsolving. These transformation technologies maybe rapidly integrated into businesses as part ofincreasingly complex and dynamic ecosystems,which are often more transparent and resilient thantheir legacy counterparts. They support increasedconnectivity demands from clients and stakeholderswho increasingly expect rapid access to data andservices.These cloud business relationships and operationalcooperation with CSPs help to introduce innovativeservice solutions, providing hitherto unknownpotential for banks’ business processes.One of the big challenges in banking IT is to dealwith peaks in computing demand. They may becaused by the typical day cycle (day trading, nightprocessing) or by extraordinary events (e.g. majorfinancial market news, price changes, marketingevents). Banks dedicate themselves to the provisionsof stable, reliable and trusted services for theircustomers. Financial stability is a prerogative.The migration from on-premises IT solutions to cloud is a conscious and careful journey for banks. It starts fromand evolves the existing IT structures and services of banks. Gradually, private cloud solutions can be built,transformed into cloud model combinations and finally embraced in a diverse environment. This journey is nota disruption, but an evolution:FIGURE 5Managed cloud addresses the managementof IT by a third party (specialist), regardingIT as a commodity rather than a businessEmbraceTransformBuildTraditionalManaged CloudPublic CloudPrivate Cloud10
Cloud adoption by European banks along this journey is being driven by several factors: the need forincreased agility/flexibility, reduced infrastructure, more transparent cost and security improvements.TABLE 6Traditional IT on-premisesCloud-based ITFlexibilityVery limited – flexible to grow,but costly and slowerVery largeTime to marketLongAlmost instantaneousCost managementNot possible once the investmentis doneDynamic, allowing for forecastingImpact on Capital ratioHighLike any other profit & losses expenseSecuritySolutions for existing services,based on inhouse-resources andexternal supportDedicated CSP cloud securityofferings as part of their corebusiness. Allows for in-built servicesecurity solutions and dynamiclarge-scale inclusion of leadingtech (e.g. artificial intelligence).Looking at IT capabilities, and guaranteeing stableoperations of the financial system require sparecapacity to be available in case of need. Havingthis capacity available in the banks’ inheritedmodel creates a significant cost footprint andnecessity to maintain infrastructure that may (only)be needed on rare but significant occasions.Cloud computing provides for an excellenttechnical solution to computing demand peaks.It allows service providers to make resourcesavailable via an accessible network where multipleclients can share the same resources.An example of improved agility can be the move ofselected front-end systems, such as broker-dealersystems, by some financial institutions into the cloud.This allows them to scale up a moment’s notice,while interfacing, either to their own trusted in-houseback-end system or to innovative cloud-basedservices, e.g. using distributed ledger technologysuch as trade settlement and accounting. Inaddition, non-core banking functions such asHuman Resources and customer relationshipmanagement could leverage state of the art cloudservice offerings.Clearly, this requires security considerations.A major concern from a risk and complianceperspective is the network perimeter. CSPs canoffer advanced capabilities to individual financialinstitutions in this area, considering their focus ofbusiness and experience in the market.In a rapidly changing environment, leaneroperating models and a focus on business valueare crucial for financial institutions to succeed.Cloud services are not only a technological trendwhich providing ICT solutions with a never-seenbefore agility/flexibility. They can also have a11
significant and positive impact on the financialinstitutions balance sheets. Traditional on-premisesIT infrastructure and developments require anupfront Capital Expenditure (CAPEX), incurredby a business to create future benefits such as theacquisition of assets, which, necessarily, have tobe designed according to the maximum workload.The system will not be available until the end ofthe project, and usually requires large paymentsin advance. In contrast, cloud-based technologyallows financial institutions to add new resources orremove them instantly, as required.This allows IT resources to scale up and downaccording to the business’ needs and facilitatesflexibility by a pay-per-use model. Therefore, IToperations can move from CAPEX to OperationalExpenditure (OPEX), incurred for the day to dayfunctioning of a business. CAPEX and OPEX aretreated very differently for tax and accountingpurposes. OPEX allows a formerly fixed cost to betransformed into a variable state. This helps toimprove competitiveness, to increase reaction timesof institutions to relevant developments and tofocus on use case implementation more effectively.Ultimately, it creates business value.More specifically, this ‘CAPEX to OPEX’transformation provides an added value tofinancial institutions in terms of capital ratio.Today, the current prudential treatment of softwarediscourages the investment that financial institutionsmake in software assets due to the obligationto deduct them fully from Common Equity Tier 1capital4. There is a need to raise additional CET1funds to offset deductions. Using cloud servicesprovided by CSPs can ease this tension, leadingthereby to a reduction of required capital whendeploying new services.TABLE 7Traditional approach to financial servicesThe target state for financial servicesOn-premises and communitySupports banks’ need to:Hybrid CloudSupports new generation of banking services:5seamlessly connect with people,organisations, systems and processesacross the globe.rapidly process, and reliably and safelystore and retrieve large and variablevolumes of data.adapt to the changing needs of clientsthrough offering trusted, high quality andcompetitive services.share common innovative technologieswith other financial services to customersand to create new markets.45emerging ecosystems for financial services.reduced time to market, increasedagility and scalability by enabling morerapid adjustment of IT services to supportbusiness operations.conversion of fixed-asset product-basedoverheads to variable service-based assets(CAPEX to OPEX).“Immersion” of banking services intoclient systems becomes more feasible,clients can get the business services theyneed on demand triggered by the ability tosimultaneously use common "services".Amendments introduced in the final text of the CRD/ CRR Review (published 7 June) allows to exempt certain investments in software assets from this deduction.However, this exemption only applies to those software assets that meet certain conditions (as specified by the EBA in regulatory technical standards to be developed) and onlyapplies two years after the entry into force of the Regulation, see Article 36 (1) (b), Article 36 (4).See “The NIST Definition of Cloud Computing”, Special Publication 800-145, Sep 2011: ecialpublication800-145.pdf12
CHAPTERFOUR4 Understanding ofFour important basics regarding data ownershipand management shall be postulated upfront,unaffected by raising cloud adaption:The views of cloud computing by regulators,technologists and service users are different.Although not conflicting, they need to be balancedto enable the most effective use of cloud technologyin financial services.ONEBanks continue to own their data.cloud computingTo attain a higher level of maturity, a mutualunderstanding and agreement needs to be fosteredthrough coordination and communication betweenregulators, technologists and service users. Thespecifics of cloud technology and its controldemand need to be understood and reflectedupon carefully.“All cloud computingrisks need to beevaluated prior toany planned cloudmigrationTWOBanks will choose the geographic location(s) inwhich to manage their data.THREEBanks can download or delete their datawhenever they need to.FOURBanks should consider the sensitivity of their dataand decide how to protect it or make it available,i.e. by using suitable cryptographic services forencryption and authentication.Based on these statements, this paper aims topresent different cloud service models, elaborate onthe necessary risk-based approach, help thecategorisation of the control demands in a cloudenvironment, show the banks’ respective awarenessand highlight their careful migration to cloud.13“
4.1 Cloud-specific considerationsunder a risk-based approachAs required by the applicable regulation, bothbanks and NCAs assess the cloud computingadoption – regarding a specific use case – with arisk-based approach.However, this makes a common understandingof cloud computing risks and available controlsfundamental. As any transformation of complexservices may suggest, the journey to a wellcontrolled cloud adoption requires carefulassessment and mitigation of potential risks.A common understanding enables:a common “language” or framework forunderstanding, assessing and communicatingrelevant and beneficial cloud computingprinciples and control objectives.a consistent means to prioritise the mostsignificant risk management activities relatedto cloud adoption and use.a unified position between the EBA/NCAsand banks, to send clear signals to cloudservice providers and technology innovatorsabout specific financial services requirements.Key risk areas for cloud computing must beunderstood in the context of cloud computing’stechnological features and service design.Operational risks relate both to the adoption ofcloud computing and to the operation of cloudservices. As in any other service relationship, allcloud computing risks need to be evaluated prior toany planned cloud migration, and managed,when performing operations in the cloud. Therefore,the already existing IT control processes of banks,based on standards such as COBIT or ITIL, need tobe reviewed in light of cloud specifics.Factors that must be taken into considerationare:the cloud service models (e.g. SaaS, PaaSand IaaS), aligned to traditional computingcontrol areas, where the level of risk relates tothe cloud service model selected. In thesemodels, risk management and the operationof IT activities are shared between cloudservice providers and cloud service customers.The “balance” of responsibility for IT controlmanagement shifts from cloud service providerto service user as we move from the top of thestack, e.g. SaaS, to the bottom of the stack, e.g.IaaS.The cloud deployment model (e.g. internal,public, and hybrid), where routineaccountability remains primarily with CSCswho selected the model for their business, andwhere their data subject needs to be supportiveand informed about data management,data location and network management.The specific characteristics of cloud computing(e.g. self-service, accessibility across networks,resource pooling, rapid elasticity, meteredservices), where governance controls arenecessary to provide timely managementinformation and escalation/response in casedefined thresholds are breached.4.2 Categorising the associatedcontrol demand of a cloudofferingThe risk of the different cloud service models needsto be identified, assessed and managed by banks.This requires understanding of how risk in cloudservices can be distinguished and rated, creatingthe respective control demand.14
European banks are well aware of the attentionthat such control demand deserves. Operationaland financial stability are core concerns prior andduring the usage of cloud services. Consequently,the selection of services and their migration to cloudare conducted consciously.Cloud operates on the shared ‘responsibility’model. This means that depending on how thefinancial institution is consuming cloud both theCSP and financial institution must understand theirareas of responsibility with regard to the controllandscape.This is not to be misunderstood for the concept ofaccountability. Accountability remains fixed withthe financial institution regardless of what servicesare being obtained from the cloud. ‘Responsibility’for the purpose of this paper should be understoodas a term allowing for clear definitions of who isoperating specific controls (the CSP or financialinstitution) and what level of visibility the financialinstitution has into how those controls work. Thereare several ways this can be accomplished byhaving a well-defined approach with the CSP.Different from other IT paradigms, cloud computinginherits technological dimensions and features thatcan have a positive effect on the control demand.In order to be fully aware of the evolving servicecharacteristics, five major dimensions need to beconsidered regarding the control demand of aparticular cloud offering.The layer of abstraction sourced,e.g. the selected cloud service model anduse case. In general, in IaaS the CSC is usingan IT infrastructure deployed and managedby the CSP, but all processes and activitiesimplemented on this infrastructure remainunder the full control of the institution (e.g.workload distribution, Solution DeliveryLifecycle, application changes).Going up the stack, the implication of thepartner in the activity will increase. Using PaaS,workload distribution will be controlledby the partner. With SaaS, the applicationmanagement, including changes (content andtiming) will not be handled by the institutionanymore. However, not all services are equal,and, for instance, there are IaaS services likeGrid IaaS where some additional componentswill be managed by the CSP, while in otherSaaS implementation processes, such as theidentity and access control, these can remainunder control of the CSC. Ultimately, aspecific control assessment will be neededfor each cloud service. It is important to notethat IT general controls remain relevantregardless of where they are operated.Ownership of the control frameworkThe framework includes relevant networkperimeter control, access management andinternal enforcement of rules. Using avisual: the network perimeter can becompared to a city wall. The wall itself andeverything inside follows internal rules. Accessis granted at the gate under control of the “citycouncil”
2 Abbreviations 3 Chapters 1 Introduction 4 2 Overview of cloud services 6 2.1 Cloud composition 6 2.2 Different cloud service models 7 2.3 Industry experience with cloud 8 3 Why European banks use cloud services 9 4 Understanding of cloud computing 13 4.1 Cloud-specific considerations under a risk-based approach 14
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Subclause 1.1 to 1.3 excerpted from ANSI A300 (Part 1) – Pruning 1 ANSI A300 standards 1.1 Scope ANSI A300 standards present performance stan-dards for the care and management of trees, shrubs, and other woody plants. 1.2 Purpose ANSI A300 performance standards are intended for use by federal, state, municipal and private entities