Documented incidentIncident 2019-07-19Capital OneRegulatory or court record

Capital One cloud breach and an $80 million OCC penalty for weak cloud-migration risk assessment (2019)

The OCC assessed an $80 million civil money penalty against Capital One for failing to establish effective risk assessment processes before migrating significant IT operations to the public cloud and for not correcting…

What happened

  • The OCC assessed an $80 million civil money penalty against Capital One for failing to establish effective risk assessment processes before migrating significant IT operations to the public cloud and for not correcting deficiencies in a timely manner.OCC Assesses $80 Million Civil Money Penalty Against Capital One
  • Misconfigured ModSecurity WAF exploited via SSRF to query IMDSv1; exfiltrated 700 S3 buckets containing 106M credit card applications.Summary combines the linked source with wider public reporting

The failure pattern

Watch the pattern: Known vulnerability left unremediated

Safeguards that address it

CollectSEA's engineering analysis of what would have prevented or contained this failure.

  • Assess cloud risk before migrating, and fix findings on timeComplete risk assessment and network-security control design before moving workloads, then track remediation of deficiencies.
  • Restrict cloud metadata and role permissionsRequire metadata-service protections, least-privilege roles for edge components, and alerting on unusual bulk reads of storage.

Related standards

CollectSEA's mapping through this incident's failure pattern; not an official determination by the standards bodies.

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