CCC Key Management Controls
Controls for Key Management technologies, as defined by the FINOS Common Cloud Controls project.
- ID
- CCC.KeyMgmt.CN
- Version
- v2026.06-rc3
- Gemara version
- v1.2.0
- Author
- FINOS Common Cloud Controls
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.KeyMgmt.CN01 Alert on Key-version Changes
Objective
Generate near-real-time alerts when a KMS key version is disabled or scheduled for deletion, enabling rapid investigation and recovery.
Assessment requirements
When a key version is scheduled for deletion or disabled, an alert MUST be generated within five minutes.
Applicability: tlp-amber, tlp-red
Guidelines
- NIST-CSF
- RS.AN-1 — Notifications from detection systems are investigated
- NIST_800_53
- IR-5 — Incident Monitoring
Threats
- CCC.KeyMgmt.Threats
- CCC.KeyMgmt.TH01 — Deletion or disabling of key versions
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.KeyMgmt.CN02 Limit Decrypt Permissions
Objective
Restrict the Decrypt operation to authorised principals only, applying the principle of least privilege to protect sensitive data.
Assessment requirements
When IAM roles and key policies are reviewed, Decrypt permission MUST be granted exclusively to documented authorised principals.
Applicability: tlp-green
Guidelines
- NIST-CSF
- PR.AC-4 — Access to assets is managed
- NIST_800_53
- AC-6 — Least Privilege
Threats
- CCC.KeyMgmt.Threats
- CCC.KeyMgmt.TH02 — Unrestricted use of a KMS key to decrypt data
Encryption
The Encryption group covers entries related to protecting data confidentiality and integrity through cryptographic mechanisms. This includes encryption in transit and at rest, key management, and certificate lifecycle management.
CCC.KeyMgmt.CN03 Enforce Automatic Rotation
Objective
Ensure symmetric keys rotate automatically within policy intervals to reduce exposure of key material.
Assessment requirements
When rotation settings are examined, rotation MUST be enabled with an interval not exceeding 365 days.
Applicability: tlp-green
Guidelines
- NIST-CSF
- PR.DS-1 — Data at rest is protected
- NIST_800_53
- SC-12 — Cryptographic Key Establishment and Management
Threats
- CCC.KeyMgmt.Threats
- CCC.KeyMgmt.TH03 — Key rotation is disabled or delayed
CCC.KeyMgmt.CN04 Validate Imported Keys
Objective
Accept only externally generated keys that meet approved cryptographic strength and provenance requirements.
Assessment requirements
When a key import request is processed, the key MUST use an approved algorithm (RSA-2048+, EC-P256+) and originate from a certified HSM.
Applicability: tlp-green
Guidelines
- NIST-CSF
- PR.DS-1 — Data at rest is protected
- NIST_800_53
- SC-28 — Protection of Information at Rest
Threats
- CCC.KeyMgmt.Threats
- CCC.KeyMgmt.TH04 — Weak or compromised key material