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An Overview of the FFIEC Architecture, Infrastructure, and Operations Booklet

By Adam Reynolds | Monday, July 26, 2021 - Leave a Comment

Our Lead Non-Technical Auditor takes a look at the new AIO Guidance…

Architecture, Infrastructure, and Operations (AIO) is the latest booklet released by the Federal Financial Institutions Examination Council (FFIEC) in their line of  IT Examination Handbooks. It is an update to their 2004 Operations booklet and, as the name implies, expands into the areas of architecture and infrastructure to encompass the ever-expanding role of IT in supporting all areas of an organization. Briefly stated, architecture is the high-level design of hardware and software infrastructure necessary to provide and maintain ongoing operations. That is, architecture is the design, infrastructure is the tools (physical items, products, and services), and operations are the processes. This short article aims to give an overview of the items examiners will be reviewing related to architecture, infrastructure, and operations as defined in the new booklet.

Architecture is meant to support the strategic and business objectives of the institution while also protecting the institution from threats to confidentiality, integrity, and availability. IT architecture should be designed and implemented with these goals in mind. To assess an institution’s standing related to AIO, examiners will look to ensure all information and technology assets (both software and hardware, including telecommunications) are identified (by network diagrams, data flow diagrams, etc.). Documentation of the architecture plan, including policies, standards, and procedures will be reviewed as well to ensure appropriate design objectives are met. These objectives include processes to address change management, IT asset end of life, prevent and detect unknown or unapproved technology (defined as shadow IT), and data identification and management.

picture of author in checkered shirt smiling

Adam Reynolds, Lead Non-Technical Auditor

Infrastructure is led by architecture and followed by operations, it is the physical elements, products, and services necessary for operations. Examiners will review policies, standards, and procedures to ensure facilities, technology, data, and personnel are sufficiently safeguarded (including maintenance and environmental controls of facilities). This will include processes to identify, track, and monitor infrastructure components, contractual arrangements addressing infrastructure, if applicable, as well as sufficient resources with infrastructure knowledge, skills, and expertise. Infrastructure also includes network configuration management and change control processes as well as security and monitoring practices to analyze data traffic and detect anomalous activity on the network. Software planning to address scalability, interoperability, and portability, as well as software controls (including controls over open-source software) will also be reviewed to ensure they meet the needs defined in the booklet. For more complex institutions, controls to address the unique risks associated with mainframes, as well as security controls for the use of application programming interfaces, are included in the examination procedures.

Operations focuses on the processes used to support the institution. Examiners will look to see that effective controls over operating centers (both logical and physical) are in place, and appropriate authorization boundaries are documented. Authorization boundaries are a new concept introduced in this booklet and is defined as “All components of an information system to be authorized for operation by an authorizing official, and excludes separately authorized systems, to which the information system is connected.” This is useful in increasingly disjointed environments such as VPNs and segmented networks to provide visibility across the whole environment. This section also focuses on the human aspect of operations, including identity and access management methods used to identify and authenticate users. Personnel controls such as hiring and retention practices, as well as methods of maintaining appropriate skillsets will be reviewed as well. Finally, the booklet reviews appropriate controls for allowing the use of personally owned devices.

The new booklet expands on the old Operations booklet to include architecture and infrastructure, as well as defining new concepts such as data governance, shadow IT, and authorization boundaries. While many of the concepts in the booklet are not new, such as cloud computing and third-party management, the booklet provides updated guidance to reflect the ever-increasing usage of cloud computing and integration of third-party management throughout an institution’s IT environment. The guidance is a welcome update to address new concepts and revisit old ones as IT infrastructure expands into almost all areas of an institution to support operations and should be designed and guided by proper AIO design as defined in the new booklet.

Original article by Adam Reynold CISSP. Founder and Managing Partner, infotex

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