CCC Identity and Access Management Controls
Controls for Identity and Access Management technologies, as defined by the FINOS Common Cloud Controls project.
- ID
- CCC.IAM.CN
- Version
- v2026.06-rc3
- Gemara version
- v1.2.0
- Author
- FINOS Common Cloud Controls
Access Control
The Access Control group covers entries related to authentication, authorization, and trust perimeter enforcement. This includes multi-factor authentication, least privilege access, network access rules, and prevention of unauthorized access or reconnaissance.
CCC.IAM.CN01 Restrict IAM User Credentials Creation
Objective
Prevent non-administrative principals from creating new long-lived credentials like access keys or generating temporary session tokens. This blocks a common privilege escalation and persistence vector.
Assessment requirements
When an identity policy for a non-administrative principal is evaluated, it MUST NOT grant permissions for creating credentials or generating temporary session tokens.
Applicability: tlp-clear, tlp-green, tlp-amber, tlp-red
When a non-administrative principal attempts to create new credentials or a temporary session token, the service MUST deny the action.
Applicability: tlp-clear, tlp-green, tlp-amber, tlp-red
Guidelines
- NIST-CSF
- PR.AA-05
- NIST_800_53
- AC-2
- AC-3
- AC-5
- AC-6
Threats
- CCC.IAM.Threats
- CCC.IAM.TH03 — Additional Cloud Credentials Creation
CCC.IAM.CN02 Restrict IAM Policies Modification
Objective
Ensure that only designated administrative accounts have the ability to create, modify, or attach policies that define permissions for other identities.
Assessment requirements
When an identity policy for a non-administrative principal is evaluated, it MUST NOT grant permissions for creating, updating, or attaching policies.
Applicability: tlp-clear, tlp-green, tlp-amber, tlp-red
When a non-administrative principal attempts to create, update, or attach policies, the service MUST deny the action.
Applicability: tlp-clear, tlp-green, tlp-amber, tlp-red
Guidelines
- NIST-CSF
- PR.AA-05
- NIST_800_53
- AC-2
- AC-3
- AC-5
- AC-6
Threats
- CCC.IAM.Threats
- CCC.IAM.TH06 — IAM Policies Modification
CCC.IAM.CN03 Restrict Role Assumption / Delegation
Objective
Limit which principals can assume a role or impersonate a service identity to only those required. This prevents unintended cross-account or public access by securing the "who can act as this identity" boundary.
Assessment requirements
When a policy is created or updated that grants a principal permission to assume a role or impersonate a service identity, the principal MUST NOT contain a wildcard or be public/anonymous.
Applicability: tlp-green, tlp-amber, tlp-red
When an external or unauthenticated principal tries to assume a role or impersonate a service identity, the service MUST deny the action.
Applicability: tlp-green, tlp-amber, tlp-red
Guidelines
- NIST-CSF
- PR.AC-3
- PR.AC-4
- NIST_800_53
- AC-2
- AC-3
- AC-6
Threats
- CCC.IAM.Threats
- CCC.IAM.TH02 — Overly-Permissive Identity Trust Policy
CCC.IAM.CN04 Restrict Wildcard Usage in IAM Policies
Objective
Limit the use of wildcard permissions in IAM policies to prevent overly broad access from being granted by default.
Assessment requirements
When an IAM policy is created or updated, it MUST NOT contain allow statements with wildcard permissions, unless the statement is restricted by a condition.
Applicability: tlp-green, tlp-amber, tlp-red
Guidelines
- NIST-CSF
- PR.AC-6
- NIST_800_53
- AC-2
- AC-3
- AC-6
Threats
- CCC.IAM.Threats
- CCC.IAM.TH01 — Valid Cloud Credentials Abuse
- CCC.IAM.TH02 — Overly-Permissive IAM Policy
CCC.IAM.CN05 Strong Password Policies for IAM Users
Objective
Ensure that the password policies for IAM users have strong configurations.
Assessment requirements
When a new cloud account is provisioned, a password policy MUST be configured for IAM users following the minimum PCI DSS v4.0.1 configurations.
Applicability: tlp-clear, tlp-green, tlp-amber, tlp-red
Guidelines
- NIST-CSF
- PR.AA-05
- NIST_800_53
- IA-5
- PCI-DSS
- 8.3.9
- 8.6.3
Threats
- CCC.IAM.Threats
- CCC.IAM.TH01 — Valid Cloud Credentials Abuse
CCC.IAM.CN06 Maximum Age for Long-Term Static Credentials
Objective
Ensure that long-lived static credentials like access keys are programmatically rotated within a defined time period to limit the window of opportunity if compromised.
Assessment requirements
When a static credential such as an access key has existed for 90 days or more, it MUST be rotated.
Applicability: tlp-clear, tlp-green, tlp-amber, tlp-red
Guidelines
- NIST-CSF
- PR.AA-01
- NIST_800_53
- AC-2
Threats
- CCC.IAM.Threats
- CCC.IAM.TH09 — Long-Lived Static Credentials
- CCC.IAM.TH01 — Valid Cloud Credentials Abuse
CCC.IAM.CN07 Automate Identity De-provisioning
Objective
Ensure that when an identity is terminated in the central Identity Provider (IdP), ts corresponding access to cloud resources is revoked automatically.
Assessment requirements
When a user account is disabled or deleted in the organization's IdP, the corresponding cloud identity and its access policies MUST be disabled or deleted within 24 hours.
Applicability: tlp-clear, tlp-green, tlp-amber, tlp-red
Guidelines
- NIST-CSF
- PR.AA-01
- NIST_800_53
- AC-2
Threats
- CCC.IAM.Threats
- CCC.IAM.TH10 — Orphaned Federated Identity Retains Access
- CCC.IAM.TH01 — Valid Cloud Credentials Abuse
CCC.IAM.CN08 Maximum Age for Unused Credentials
Objective
Ensure that unused IAM credentals are removed to reduce exposure in the event of potential compromise.
Assessment requirements
When an IAM user has credentials, such as passwords or access keys, that have not been used for 90 days or more, the unused credentials MUST be removed or deactivated.
Applicability: tlp-clear, tlp-green, tlp-amber, tlp-red
Guidelines
- NIST-CSF
- PR.AA-01
- NIST_800_53
- AC-2
Threats
- CCC.IAM.Threats
- CCC.IAM.TH11 — Unused Credentials
- CCC.IAM.TH01 — Valid Cloud Credentials Abuse
CCC.IAM.CN09 Enforce Federated Single Sign-On (SSO) for Human Users
Objective
Ensure that all human users must authenticate through a central, federated Identity Provider (IdP) to access the cloud environment. This eliminates cloud-native user accounts with long-lived passwords, centralizes authentication controls, and simplifies lifecycle management.
Assessment requirements
When a human user accesses the cloud environment, they MUST authenticate through the organization's federated IdP via a standard protocol (e.g., SAML, OIDC).
Applicability: tlp-clear, tlp-green, tlp-amber, tlp-red
Guidelines
- NIST-CSF
- PR.AA-01
- NIST_800_53
- IA-2
Threats
- CCC.IAM.Threats
- CCC.IAM.TH01 — Valid Cloud Credentials Abuse
- CCC.IAM.TH09 — Long-Lived Static Credentials
Observability
The Observability group covers entries related to logging, monitoring, metrics, alerting, and event publication. This includes audit trail integrity, enumeration detection, and protection against tampering or unauthorized access to operational telemetry.
CCC.IAM.CN10 Alert On Anomalous Behaviour
Objective
Ensure that logs and associated alerts are generated when anomalous API requests are made by a single identity, such as API requests commonly associated with privilege escalation tactics, originating from an external or malicious IP address or performed by a previously dormant identity, which may indicate that credentals may be compromised, as well as for password brute-force attempts and account lockouts.
Assessment requirements
When suspicious API requests are detected, real time alerts MUST be generated to notify security personnel.
Applicability: tlp-red
When suspicious API requests are detected, the associated events MUST be logged, including the source details, time, and nature of the activity.
Applicability: tlp-green, tlp-amber, tlp-red
Guidelines
- NIST-CSF
- DE.CM-03
- DE.CM-06
- DE.CM-09
- NIST_800_53
- SI-4
- SI-5
- AC-2
Threats
- CCC.IAM.Threats
- CCC.IAM.TH01 — Valid Cloud Credentials Abuse
CCC.IAM.CN11 Enable Continuous IAM Access and Usage Analysis
Objective
Enable and configure the cloud provider's native access and usage analysis services to continuously monitor for external access paths and internal unused access.
Assessment requirements
When a cloud account or organization is provisioned, the native automated access and usage analysis services MUST be enabled to continuously monitor for external or public access to resources, and unused access.
Applicability: tlp-clear, tlp-green, tlp-amber, tlp-red
Guidelines
- NIST-CSF
- ID.RA-01
- ID.IM-01
- NIST_800_53
- AC-2
- CA-7
- RA-5
Threats
- CCC.IAM.Threats
- CCC.IAM.TH02 — Overly-Permissive Identity Trust Policy
- CCC.IAM.TH10 — Orphaned Federated Identity Retains Access
- CCC.IAM.TH11 — Unused Credentials