How OCC Built a Governed Cloud Foundation and Then Stress-Tested It

This article details how the Options Clearing Corporation (OCC), a systemically important financial market utility, partnered with AWS to build a governed cloud foundation and validate its resilience through structured testing.

• OCC became first SIFMU to receive SEC approval for cloud infrastructure adoption in 2022
• Manual governance across 50+ accounts created compliance gaps, configuration drift, and audit risks
• AWS Control Tower automated account provisioning with standardized baselines and security controls
• Account Factory for Terraform (AFT) kept governance layer consistent with Terraform IaC toolchain
• 2,041 active controls now enforced consistently across entire AWS estate
• Account provisioning reduced from 3-4 months to days with eliminated manual errors
• AWS Fault Injection Service program ran 350+ experiments across 34 failure categories
• Approximately 50% of experiments surfaced failures, each leading to specific remediations
• Break-glass roles eliminated manual credential rotation across all accounts
• Compliance evidence now generates programmatically, reducing audit preparation effort
• Resilience testing established as permanent, automated operational discipline

OCC now operates a governed cloud environment validated under real failure conditions, providing a replicable model for regulated industries building multi-account cloud foundations.