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How we architected a FedRAMP Moderate boundary on AWS GovCloud for an AI SaaS

Draw the boundary first. Then write Terraform. A federal customer was ready to procure. The architecture was not. This is a redacted write-up of a real engagement: a FedRAMP Moderate authorization boundary built on AWS GovCloud for an AI SaaS vendor selling into federal buyers, against a customer-driven timeline tied to a fiscal year. The context The client ran production on commercial AWS with a strong engineering culture, modern Terraform practice, and zero prior federal experience. A federal customer had committed to procurement contingent on a FedRAMP Moderate path, with an aggressive deadline. The internal team understood the application deeply and had read enough FedRAMP material to know they were in trouble. The architecture decisions that worked beautifully for commercial customers each failed boundary review: shared accounts with the commercial environment a hosted vector store outside the cloud OpenAI behind the application an observability stack running outside the cloud account The remediation list grew faster than the team could keep up with, and the timeline did not move. They reached out for boundary architecture help. Not policy writing, not 3PAO selection. Engineering work to redesign the cloud footprint so the boundary could be drawn cleanly and the assessment could proceed. The approach: boundary before Terraform The most common FedRAMP failure pattern is to start with the existing environment and try to bend it to fit the boundary. We do not do that. The first deliverable was a boundary diagram drawn from scratch, before any IaC was touched, identifying every service inside, outside, and at the edge of the authorization boundary. From the boundary, every other architectural decision derived. The Terraform module library was written against the boundary, not the existing accounts. Identity federation, network architecture, KMS topology, and logging all followed. ┌─────────────────────────── FedRAMP Moderate Boundary (AWS GovCloud) ────────────────

2026-06-04 原文 →