Ensuring compliance with relevant standards, regulations, legal obligations, and contractual requirements is critical for any organization undergoing an audit. The Cloud Controls Matrix (CCM) Control A&A-04 Requirements Compliance specifies key steps to verify adherence to all applicable mandates. By proactively identifying and tracking pertinent requirements, organizations can ensure their audit processes are thorough and complete.
Where did this come from?
This control comes from the CSA Cloud Controls Matrix v4.0.10 - 2023-09-26. You can download the full CCM document here. The CCM provides a comprehensive set of cloud security controls aligned to industry standards and regulations. Additional details on AWS compliance programs can be found in the AWS Compliance documentation.
Who should care?
- CISOs and security leaders responsible for ensuring regulatory compliance
- Compliance managers tasked with preparing for and supporting audits
- Internal auditors who need to verify the organization's adherence to requirements
- DevSecOps teams implementing security controls and collecting audit evidence
What is the risk?
Failure to comply with relevant standards and regulations can lead to:
- Failed audits resulting in loss of certifications
- Regulatory fines and penalties for non-compliance
- Reputational damage and loss of customer trust
- Breach of contractual obligations and potential legal action
The A&A-04 control helps mitigate these risks by ensuring a comprehensive and up-to-date view of compliance requirements. However, it does not guarantee compliance on its own - organizations must put in the work to meet the identified standards.
What's the care factor?
Compliance is a critical priority for most organizations, especially those in regulated industries or dealing with sensitive data. Failed audits or non-compliance penalties can be costly and damaging. Security leaders should prioritize implementing this control to avoid blind spots and audit failures.
However, in organizations with limited regulatory obligations, a lighter-weight approach may be appropriate. The level of effort put into this control should be commensurate with compliance risk.
When is it relevant?
This control is most relevant for organizations that:
- Operate in heavily regulated industries like finance or healthcare
- Handle sensitive personal data subject to privacy regulations
- Regularly undergo compliance audits for certifications like ISO 27001 or SOC 2
- Have contractual security/compliance obligations to enterprise customers
It may be less critical for smaller organizations with minimal sensitive data or regulatory requirements. However, most organizations have some level of compliance needs.
What are the trade offs?
Implementing this control requires ongoing effort to:
- Research and track evolving regulatory requirements across regions
- Map controls to multiple overlapping standards and frameworks
- Coordinate input from legal, privacy, infosec and other stakeholders
- Maintain accurate, up-to-date repository of requirements over time
This takes significant time and coordination. Organizations must balance the level of thoroughness with the effort required. Tools can help manage the complexity.
How to make it happen?
- Assign an owner for compliance requirements tracking, typically from Compliance or InfoSec
- Determine scope - regulatory jurisdictions, industry regs, certs, customer contracts in scope
- Research all potentially applicable requirements - leverage external advisors if needed
- Analyze applicability of requirements to the organization based on scope
- Map applicable requirements to a master compliance controls framework
- Implement a compliance requirements repository (spreadsheet or GRC tool)
- Enter applicable requirements into repository with ownership, deadlines, evidence needs
- Integrate compliance requirements repository into audit planning processes
- Regularly review and update repository as regulations, scope, or obligations change
What are some gotchas?
- Complex, overlapping global regulatory landscape requires significant research
- Determining which requirements are in scope is key - don't waste effort on non-applicable regs
- Needs involvement of multiple stakeholders - legal, privacy, infosec, product, eng, etc.
- Keeping requirements up to date with regulatory changes takes ongoing effort
- Implementing compliance controls may require changes to architectures and processes
What are the alternatives?
Some potential alternative approaches:
- Rely on external auditors to identify requirements rather than tracking internally
- Do ad-hoc research on requirements only prior to each audit rather than ongoing tracking
- Use a "good enough" approach to meet most major requirements vs granular analysis
- Implement a subset of a standard framework like ISO 27001 vs tracking individual regs
However, these approaches increase the risk of missing key requirements and audit failures. The A&A-04 approach of proactive, comprehensive tracking is the most robust.
