Cloud Security — Cloud Access Governance Exemplar

Stella Maris Governance LLC Redacted structural exemplar — not a complete client deliverable

Control Objective

Establish and enforce access governance controls for cloud environments processing, storing, or transmitting Controlled Unclassified Information within the Defense Industrial Base. This pack governs how organizations define cloud boundary responsibilities, implement identity controls, and validate access posture across cloud and hybrid infrastructure aligned to FedRAMP and NIST SP 800-53 requirements.

Control Structure

Control ID	Objective	Evidence Required	Framework Mapping
CAG-01	Define and document cloud shared responsibility boundaries for all CUI-processing environments	Shared responsibility matrix, cloud boundary diagram, CUI scope delineation records	NIST 800-53 AC-1 / FedRAMP AC-1
CAG-02	Implement identity federation and single sign-on for cloud administrative access	Identity federation configuration records, SSO implementation documentation, conditional access policy evidence	NIST 800-53 IA-2 / FedRAMP IA-2
CAG-03	Enforce multi-factor authentication for all cloud administrative and CUI-access accounts	MFA enforcement policy, configuration evidence, exception documentation with compensating controls	NIST 800-53 IA-2(1) / FedRAMP IA-2(1)
CAG-04	Establish cloud-specific privileged access management with just-in-time elevation	Privileged access policy, JIT configuration records, elevation approval workflow documentation	NIST 800-53 AC-6 / FedRAMP AC-6
CAG-05	Implement continuous monitoring of cloud access patterns with automated anomaly detection	Monitoring configuration evidence, alert threshold documentation, anomaly response procedure records	NIST 800-53 SI-4 / FedRAMP SI-4

This exemplar displays a representative subset of controls from a structured 10-control pack maintained within the firm's private governance system. Full pack available through advisory engagement.

Evidence Traceability

Control	Evidence Artifact	Storage Location	Review Cadence
CAG-01	Cloud Shared Responsibility Matrix (CSRM-001)	Controlled Governance Repository	Semi-annual review
CAG-02	Identity Federation Architecture Document (IFAD-001)	Controlled Governance Repository	Annual review
CAG-03	MFA Enforcement Policy & Evidence (MFA-001)	Controlled Governance Repository	Quarterly validation
CAG-04	Privileged Access Management Policy (PAM-001)	Controlled Governance Repository	Quarterly validation
CAG-05	Continuous Monitoring Configuration Record (CMCR-001)	Controlled Governance Repository	Monthly review

Implementation Guidance

Cloud access governance begins with a clear shared responsibility delineation documenting which controls are provider-managed, customer-managed, and shared. Organizations should implement identity federation to centralize authentication, enforce MFA across all administrative and CUI-access accounts, and establish just-in-time privileged access with documented approval workflows. Continuous monitoring should capture access patterns with defined anomaly thresholds and automated alerting. Evidence should demonstrate both policy definition and operational enforcement through configuration records and periodic access reviews.

Assessment Alignment

This pack is structured for third-party assessor review. Control objectives map directly to NIST SP 800-53 access control and identification/authentication requirements within the FedRAMP framework. Evidence artifacts are version-controlled and traceable within the firm's controlled governance repository. Assessment preparation includes validation of shared responsibility documentation, MFA enforcement evidence, and continuous monitoring operational records.