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AWS and Azure provide shared cloud infrastructure and managed services; a financial institution selects and configures those services, then builds and operates its workloads on them. That division of work changes by service and architecture. Using either provider does not, by itself, make a bank compliant or transfer the institution’s regulatory accountability.
How does cloud computing work for a financial institution?
Cloud computing lets an institution consume computing capacity, storage, networking, and higher-level managed services from a provider rather than operating every layer itself. The provider operates the underlying cloud infrastructure and service layers. The institution chooses how to use them, configures its environment, and remains responsible for the parts of the workload and controls assigned to it.
This is a shared operating model, not a simple handoff. AWS describes its role as protecting the cloud infrastructure while customers manage responsibilities in the cloud. Microsoft likewise says customers configure security and compliance to meet their needs and risk tolerance. The boundary depends on the specific service and how it is integrated into the institution’s environment.
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What changes when a service is managed?
A provider may operate more of the underlying service layer when an institution chooses a managed service, but the institution still needs to understand which responsibilities remain with it. For each service, teams should identify who operates each relevant control: the provider, the institution, or an internal platform or application team. Avoid treating a provider’s general description of shared responsibility as a substitute for a service-by-service allocation.
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How should an institution move a workload to the cloud?
A sound cloud decision begins with the business workload, its data, and its risks—not with a provider label. The following sequence is a practical way to organize the work; it is not a mandated regulatory process.
- Classify the workload and data. Record the workload’s purpose, the data it handles, and its business importance. Assess whether disruption could affect a critical service.
- Select a service and deployment pattern. Choose services that fit the workload and the institution’s architecture. Confirm the responsibility boundary for each selected service.
- Set identity, network, and policy controls. Establish how users and systems gain access, how the environment is connected, and how configuration requirements will be governed.
- Build and deploy the application. Configure the workload and its data handling in line with institutional requirements, and document which teams operate the controls.
- Monitor access, configuration, and operations. Review whether the environment and its controls continue to match the intended design as the service and business change.
- Test recovery and reassess risk. Evaluate whether the workload can recover from relevant disruption scenarios, then revisit dependencies and controls when the architecture or service changes.
How do AWS and Azure differ for financial workloads?
Neither provider is a universal winner. The useful comparison is how each provider’s services, governance approach, and operating model fit a particular workload and the institution’s existing environment.
| Decision area | AWS guidance | Azure guidance | What the institution should assess |
|---|---|---|---|
| Architecture and workload fit | AWS offers a Financial Services Industry Lens that extends its Well-Architected practices to financial workloads and institution-defined risk and control objectives. | Microsoft’s financial-services guidance uses landing zones and Azure Policy for consistent environment governance. | Fit the chosen architecture to the workload, its risks, and the institution’s established environment; neither framework determines the answer by itself. |
| Responsibility boundary | AWS advises mapping responsibilities according to the service selected. | Microsoft describes customer configuration responsibilities for security and compliance. | Allocate each control to the provider, institution, or internal platform and application teams for the actual service in use. |
| Governance and enablement | The Financial Services Industry Lens offers a framework for considering financial workload design and controls. | Landing-zone concepts distinguish shared platform capabilities, such as identity and connectivity, from workload hosting. Microsoft’s regulated-institution service-enablement guidance describes isolation, explicit baselines, and policy-driven governance as adaptable patterns. | Decide how shared platform services and individual workloads will be governed. Treat guidance as design input, not a compliance checklist. |
| Resilience and dependencies | AWS risk guidance supports ongoing risk prioritization and an enterprise cloud risk plan. | Microsoft’s resilience guidance emphasizes critical services, dependencies, concentration, continuity, and exit planning. | Inventory dependencies and consider disruption, concentration, continuity, recovery, and exit. The guidance does not establish that multi-cloud is automatically safer or required. |
| Cost and operations | AWS architecture and risk guidance treats cost and operational responsibilities as design and governance concerns. | Not stated in the cited Azure guidance for a comparable cost ranking. | Evaluate costs and operating responsibilities for the institution’s own architecture. The cited guidance does not provide a neutral price or cost comparison. |
Can U.S. financial institutions use AWS or Azure?
AWS’s U.S. Financial Services Compliance Center states: “Yes. Financial institutions in the U.S. are permitted to use cloud services, provided that they comply with applicable legal and regulatory requirements, such as those described below.” This is AWS’s guidance, not a statement by a government regulator. Which requirements apply depends on the institution, its activities and jurisdiction, and the particular workload and data.
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Who is responsible for cloud security and compliance?
Responsibility is divided according to the cloud service and architecture. Providers operate cloud infrastructure and may operate parts of selected services; the institution makes workload decisions and configures and operates its own side of the model. Internal platform and application teams may also own controls. Assign responsibilities at the service and workload level rather than assuming every control belongs wholly to the provider or customer.
- Provider: Understand which infrastructure or service controls the provider operates, using service-specific documentation and available compliance materials.
- Institution: Assess workload purpose, data, risks, applicable requirements, and the institution’s own configuration, application, data-handling, and operating procedures.
- Internal teams: Clarify ownership across platform, security, risk, compliance, and application functions so that controls have accountable operators and evidence.
Provider attestations can support evidence gathering about provider-operated controls. They do not resolve the institution’s separate assessment of its own workload, environment, and obligations.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What should cloud risk reviews cover for critical services?
For workloads supporting important financial services, the review should start with the business service and the consequences of its disruption. Microsoft’s resilience guidance emphasizes critical services, dependencies, concentration, continuity, and exit planning; AWS recommends ongoing risk prioritization and an enterprise cloud risk plan.
- Which business service depends on the workload, and what disruption scenarios matter?
- Which internal teams, provider services, and other third parties are dependencies?
- What recovery capability and evidence does the institution need for the workload?
- Could concentration in a provider or critical dependency affect continuity?
- How would the institution maintain or exit the service if the provider or a critical dependency became unavailable?
Revisit these questions as the workload, business need, architecture, or services change. Cloud risk is an ongoing governance concern, not a one-time migration sign-off.
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