FSISEC08: How do you isolate your software development lifecycle (SDLC) environments (like development, test, and production)?

We recommend that you separate production workloads from non-production workloads. Maintaining resource isolation between software development lifecycle (SDLC) environments reduces the chance of misuse and accidents in production environments. This is an important guidance for all financial institutions, including those that are subject to Payment Card Industry Data Security Standard (PCI DSS). For generative AI workloads, environment isolation extends to model artifacts, prompt catalogs, AI service endpoints, and data isolation for training datasets and inference data.

FSISEC08-BP01 Implement a multi-account strategy

Using multiple AWS accounts to help isolate and manage your business applications and data can help you optimize across most of the AWS Well-Architected Framework pillars, including operational excellence, security, reliability, and cost optimization. We recommend organizing your overall AWS environment with a multi-account strategy. The extent to which you use these best practices depends on your stage of the cloud adoption journey and specific business needs.

We recommend that you isolate production workload environments and data in production accounts housed within production OUs, under your top-level workload-oriented OUs. Apart from production OUs, we recommend that you define one or more non-production OUs that contain accounts and workload environments that are used to develop and test workloads.

For AI systems, establish clear separation between development and production environments while isolating model training and inference environments, maintaining separate prompt catalogs for each environment, and implementing strict controls for cross-environment AI service access.

Having different accounts dedicated to different SDLC environments provides a natural isolation in managing privileges in IAM. AWS Organizations facilitates the management of account hierarchy. Define service control policies (SCPs) to limit the actions a user can perform inside these accounts. For example, you could minimize changes in production to CloudTrail logging, help prevent internet gateways set up in a VPC, or help prevent modifying AWS Config tracking.

To offer a straightforward way to set up and govern an AWS multi-account environment that follows prescriptive best practices, AWS has created AWS Control Tower, which extends the capabilities of AWS Organizations. To help keep your organizations and accounts from drift, or divergence from best practices, AWS Control Tower applies comprehensive controls (sometimes called guardrails). For more detail, see Limitations and quotas in AWS Control Tower.

FSISEC08-BP02 Enforce network isolation

Some financial industry regulators require the implementation of techniques such as Zero Trust or microsegmentation in their regulated entities. In addition to IAM isolation, enforce clear separation of resources between production and non-production environments. Using different accounts helps create the highest form of isolation possible on AWS. However, you may need to reach resources across accounts, especially when accessing shared services such as logging and security services.

VPC Peering connects resources in two VPCs (in the same account or between different accounts) without the need of additional gateways or VPN connections, and it makes the peered network visible to each other. This requires complete network trust between the two VPCs, and better alternatives exist depending on your use case. If the objective is to access only a few services in the other VPC, use AWS PrivateLink, which provides connectivity over an internal network without VPN and limits network exposure. Service publishers also have to specify which IAM principals can consume these endpoints and attach an IAM resources policy specifying what actions are allowed. If more extensive cross-VPC access is needed, separation and private connectivity can be also established with AWS Transit Gateways.

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