ISO 27001 For Financial Services
- Kamalika Majumder | DevOps & ISO 27001 Consultant
- 2 days ago
- 4 min read
In one of my client projects, a leading Southeast Asian unicorn sought to launch a financial services application in Indonesia. To achieve this, they needed to certify their infrastructure with ISO 27001 compliance. On paper, this required them to:
"Ensure business continuity and disaster recovery plans include considerations for maintaining information security during disruptions. This includes regular testing of recovery processes, maintaining backups, and ensuring critical systems can be restored quickly."
In practice, their data-centers had to prove the defined RTO (Recovery Time Objective) of 4 hours and RPO (Recovery Point Objective) of 15 minutes through a Disaster Recovery (DR) drill.
Disaster Recovery (DR) plays a vital role in achieving and maintaining ISO/IEC 27001 certification, which outlines a framework for establishing, implementing, and maintaining an information security management system (ISMS).
While the ISO 27001 standard doesn't mandate specific recovery tools or processes, a well-structured DR plan is instrumental in meeting its requirements.
ISO 27001:2022 introduces several new controls that enhance cybersecurity resilience, especially for financial services applications hosted on the cloud. These changes reflect the growing complexity of cloud environments, increased regulatory scrutiny, and the evolving cyber threat landscape.
Key New Controls in ISO 27001:2022 For Financial Services
The 2022 revision of ISO 27001 incorporates 11 new controls within Annex A, grouped into four key themes:
Organisational Controls
Threat Intelligence (5.7): Financial institutions must implement proactive threat intelligence mechanisms to anticipate, detect, and respond to evolving cyber threats.
Information Security for Cloud Services (5.23): Emphasizes the need for clear security responsibilities when using cloud services, particularly in shared responsibility models with cloud service providers (CSPs).
ICT Readiness for Business Continuity (5.30): Ensures that financial services applications hosted on the cloud can maintain availability and recover from disruptions efficiently.
Technological Controls
Configuration Management (8.9): Calls for the enforcement of standardized security configurations across cloud infrastructure, reducing misconfiguration risks.
Information Deletion (8.10): Ensures that financial institutions properly manage data lifecycle policies, including secure deletion when data is no longer needed.
Data Masking (8.11): Critical for protecting sensitive financial data in cloud-hosted applications, particularly for compliance with data privacy regulations like GDPR and PCI DSS.
Data Leakage Prevention (8.12): Financial organizations must deploy advanced DLP mechanisms to prevent unauthorized data exfiltration.
Monitoring Activities (8.16): Strengthens security monitoring capabilities through SIEM, endpoint detection, and response tools.
Web Filtering (8.23): Helps prevent unauthorized access to malicious websites that could compromise cloud-hosted applications.
Secure Coding (8.28): Ensures that application security is built-in from the development phase, mitigating vulnerabilities in cloud-based financial applications.
Physical Controls
Physical Security Monitoring (7.4): Ensures financial institutions monitor their cloud datacenter environments for physical threats such as unauthorised access or tampering.
Translating These Controls for Cloud-Based Financial Services
Financial services institutions operating in cloud environments must align their security strategies with these new controls. Here’s how they can implement them effectively:
1. Enhancing Threat Intelligence and Incident Response
By leveraging AI-driven security analytics and threat intelligence platforms, banks can proactively detect and respond to cyber threats in real time. Integrating SIEM with cloud-native security tools, such as AWS GuardDuty or Microsoft Defender, helps meet control 5.7.
2. Shared Responsibility Model for Cloud Security
Control 5.23 mandates a well-defined security responsibility framework. Financial firms should adopt a Cloud Security Posture Management (CSPM) solution to continuously assess compliance with cloud security best practices.
3. Ensuring Business Continuity in Cloud-Based Applications
Control 5.30 requires robust disaster recovery (DR) and high availability (HA) mechanisms. Implementing multi-region deployments, automated failover strategies, and backup solutions ensures compliance with this requirement.
4. Securing Cloud Configurations and Preventing Data Exposure
Misconfigurations are a major risk for cloud-hosted financial applications. Compliance with control 8.9 can be achieved using Infrastructure as Code (IaC) tools like Terraform, combined with automated security scanning solutions.
Data masking (8.11) and DLP (8.12) must be enforced using encryption at rest and in transit, tokenisation, and cloud-native security controls such as AWS Macie or Google DLP API.
5. Strengthening Cloud Security Monitoring and Web Protection
For compliance with control 8.16, financial institutions should implement continuous monitoring solutions, including Security Operations Center (SOC) capabilities.
Control 8.23 requires web filtering mechanisms to prevent financial fraud and phishing attacks. Secure Web Gateway (SWG) solutions can be integrated to enforce web filtering policies.
Conclusion:
Fault tolerant Infrastructure and Platform inline with RTO/RPO guidelines
Secure and Seamless connectivity across intranet and internet.
The system is protected, both logically and physically, against unauthorized access.
Automated , modular and highly available environment on demand.
Centralised Role based access controlled authentication and authorisation for all systems and services.
Scheduled assessment of disaster recovery and rollback process
The new ISO 27001:2022 controls provide a stronger cybersecurity framework for financial services applications in cloud environments. By aligning security strategies with these controls, financial institutions can enhance resilience, ensure compliance, and mitigate emerging risks in an evolving threat landscape.
Need to get ISO 27001 or SOC2 Compliant, but not sure where to start!
Thanks & Regards
Kamalika Majumder
