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Project 05 - Identity & Access

Cloud IAM Governance & Least-Privilege Program

AWS Multi-Account Environment, Post-Merger

Designed and implemented a least-privilege IAM governance framework across 18 AWS accounts, eliminating 340+ individual IAM users, all standing privileged access, and the top ITGC audit risk finding, within 12 months.

18 AWS accountsZero standing privilege100% JIT adoptionCyberArk PAMNIST SP 800-207
327
IAM users consolidated
0
Standing privileged accounts
100%
JIT adoption
18
AWS accounts governed
0
Root keys remaining active
The Challenge
Problem Statement

A technology company formed through merger inherited two separate AWS environments with divergent IAM architectures and no unified governance model. The combined estate contained over 340 individual IAM users across 18 accounts, numerous long-lived access keys with no rotation policy, pervasively overprivileged roles granting far broader access than any business function required, and no access certification or review process. Multiple accounts retained active root access keys without MFA enforcement. The ITGC audit had identified IAM governance as the single highest-risk finding across the entire estate, with both the audit committee and external auditors requesting a formal remediation plan within 90 days. Root account access keys were active on several accounts with no MFA enforced, the highest-risk IAM configuration possible. There was no access review or certification process; entitlements had never been formally reviewed post-onboarding. No PAM solution was in place, so all administrative access was standing, unmonitored, and ungoverned.

The Approach
How I Solved It

I began with a comprehensive IAM entitlement review across all 18 AWS accounts using AWS IAM Access Analyzer and custom Python scripts to identify dormant users, excessive permissions, unused roles, long-lived access keys, and policy violations, producing a complete risk-graded entitlement inventory as the remediation baseline, and mapped every finding to NIST SP 800-53 access control requirements and the CIS AWS Foundations Benchmark. I designed a role-based access control model aligned to job functions, enforcing least-privilege through AWS Permission Boundaries and Service Control Policies applied at the AWS Organizations level, then implemented AWS IAM Identity Center as the centralized identity broker integrated with Azure AD as the corporate identity provider, replacing all 340+ individual IAM users with federated identities managed through the existing HR-driven joiner-mover-leaver process. I deployed CyberArk Privileged Access Management to enforce just-in-time access for every administrative role, eliminating all standing privileges across all 18 accounts and requiring time-bounded, session-recorded access for every administrative action, and removed all root access keys while enforcing MFA on root accounts, with detective controls via AWS Config and GuardDuty to alert on any root account activity. I built automated access key rotation enforcement through AWS Config Rules with Lambda auto-remediation, disabling keys that exceeded 90 days without rotation and notifying key owners without manual intervention, and established quarterly access review campaigns using SailPoint IIQ integrated with AWS IAM, routing entitlement decisions to role owners and escalating non-responses to managers after five business days. Finally, I documented all IAM policies, RBAC matrices, access review procedures, and PAM governance in a formal IAM Governance Playbook reviewed and approved by the CISO and Legal, giving the program an auditable, durable governance foundation.

Frameworks & Standards
NIST SP 800-207 (Zero Trust)
NIST SP 800-53
CIS AWS Foundations Benchmark
Tools & Platforms
AWS IAM Access Analyzer · AWS IAM Identity Center · CyberArk · SailPoint IIQ · Azure AD · AWS GuardDuty · Terraform · AWS SCPs
Category
IAM Governance · Cloud Security · Access Management
What Was Delivered
Outcomes & Results
Delivered a fully governed, least-privilege IAM environment across 18 AWS accounts, eliminating the highest-risk ITGC audit finding, achieving 100% JIT adoption for all administrative access, and establishing durable access governance processes that scale without linear security team growth
All 327+ individual IAM users successfully migrated to federated identity via IAM Identity Center within 60 days of deployment
Zero standing privileged accounts across all 18 accounts, all administrative access governed through CyberArk JIT with session recording
All root access keys removed and MFA enforced on root accounts across the entire AWS estate
IAM risk area formally cleared from the ITGC audit findings at the next examination cycle
Access key incidents reduced to zero in the 12 months following automated enforcement deployment
Quarterly access review program achieved 98% on-time completion rate in its first two cycles
SCP guardrails prevented 90+ attempts to create non-compliant IAM resources in the six months post-deployment
100% administrative JIT adoption achieved, zero exceptions to standing privilege policy
Key Lesson
Access review quality depends entirely on role owner accountability. Initial access review campaigns saw approximately 40% of entitlement decisions defaulted to “approve” without meaningful review, rubber-stamping existing access. The change that transformed the review from a compliance exercise into genuine governance was introducing automatic revocation for non-responses after a defined window, and reporting completion rates and decision quality to management. When role owners understood that inaction had consequences and that leadership was watching, review quality improved materially.