Az Policy Advertizer

2.7

CIS_Azure_1.1.0_2.7

CIS Microsoft Azure Foundations Benchmark recommendation 2.7

2 Security Center

Ensure ASC Default policy setting "Monitor Network Security Groups" is not "Disabled"

Shared

The customer is responsible for implementing this recommendation.

Enable Network security group recommendations for virtual machines.

2.8

CIS_Azure_1.1.0_2.8

CIS Microsoft Azure Foundations Benchmark recommendation 2.8

2 Security Center

Ensure ASC Default policy setting "Monitor Web Application Firewall" is not "Disabled"

Shared

The customer is responsible for implementing this recommendation.

Enable Web application firewall recommendations for virtual machines.

2.9

CIS_Azure_1.1.0_2.9

CIS Microsoft Azure Foundations Benchmark recommendation 2.9

2 Security Center

Ensure ASC Default policy setting "Enable Next Generation Firewall(NGFW) Monitoring" is not "Disabled"

Shared

The customer is responsible for implementing this recommendation.

Enable next generation firewall recommendations for virtual machines.

3.8

CIS_Azure_1.1.0_3.8

CIS Microsoft Azure Foundations Benchmark recommendation 3.8

3 Storage Accounts

Ensure 'Trusted Microsoft Services' is enabled for Storage Account access

Shared

The customer is responsible for implementing this recommendation.

Some Microsoft services that interact with storage accounts operate from networks that can't be granted access through network rules. To help this type of service work as intended, allow the set of trusted Microsoft services to bypass the network rules. These services will then use strong authentication to access the storage account. If the Allow trusted Microsoft services exception is enabled, the following services: Azure Backup, Azure Site Recovery, Azure DevTest Labs, Azure Event Grid, Azure Event Hubs, Azure Networking, Azure Monitor and Azure SQL Data Warehouse (when registered in the subscription), are granted access to the storage account.

6.3

CIS_Azure_1.1.0_6.3

CIS Microsoft Azure Foundations Benchmark recommendation 6.3

6 Networking

Ensure no SQL Databases allow ingress 0.0.0.0/0 (ANY IP)

Shared

The customer is responsible for implementing this recommendation.

Ensure that no SQL Databases allow ingress from 0.0.0.0/0 (ANY IP).

CIS_Azure_1.3.0

3.7

CIS_Azure_1.3.0_3.7

CIS Microsoft Azure Foundations Benchmark recommendation 3.7

3 Storage Accounts

Ensure 'Trusted Microsoft Services' is enabled for Storage Account access

Shared

The customer is responsible for implementing this recommendation.

CIS_Azure_1.3.0

4.3.8

CIS_Azure_1.3.0_4.3.8

CIS Microsoft Azure Foundations Benchmark recommendation 4.3.8

4 Database Services

Ensure 'Allow access to Azure services' for PostgreSQL Database Server is disabled

Shared

The customer is responsible for implementing this recommendation.

Disable access from Azure services to PostgreSQL Database Server

CIS_Azure_1.3.0

6.3

CIS_Azure_1.3.0_6.3

CIS Microsoft Azure Foundations Benchmark recommendation 6.3

6 Networking

Ensure no SQL Databases allow ingress 0.0.0.0/0 (ANY IP)

Shared

The customer is responsible for implementing this recommendation.

Ensure that no SQL Databases allow ingress from 0.0.0.0/0 (ANY IP).

CIS_Azure_1.4.0

3.7

CIS_Azure_1.4.0_3.7

CIS Microsoft Azure Foundations Benchmark recommendation 3.7

3 Storage Accounts

Ensure 'Trusted Microsoft Services' are Enabled for Storage Account Access

Shared

The customer is responsible for implementing this recommendation.

CIS_Azure_1.4.0

4.3.7

CIS_Azure_1.4.0_4.3.7

CIS Microsoft Azure Foundations Benchmark recommendation 4.3.7

4 Database Services

Ensure 'Allow access to Azure services' for PostgreSQL Database Server is disabled

Shared

The customer is responsible for implementing this recommendation.

Disable access from Azure services to PostgreSQL Database Server

CIS_Azure_1.4.0

6.3

CIS_Azure_1.4.0_6.3

CIS Microsoft Azure Foundations Benchmark recommendation 6.3

6 Networking

Ensure no SQL Databases allow ingress 0.0.0.0/0 (ANY IP)

Shared

The customer is responsible for implementing this recommendation.

Ensure that no SQL Databases allow ingress from 0.0.0.0/0 (ANY IP).

CIS_Azure_2.0.0

3.9

CIS_Azure_2.0.0_3.9

CIS Microsoft Azure Foundations Benchmark recommendation 3.9

Ensure 'Allow Azure services on the trusted services list to access this storage account' is Enabled for Storage Account Access

Shared

This creates authentication credentials for services that need access to storage resources so that services will no longer need to communicate via network request. There may be a temporary loss of communication as you set each Storage Account. It is recommended to not do this on mission-critical resources during business hours.

Some Azure services that interact with storage accounts operate from networks that can't be granted access through network rules. To help this type of service work as intended, allow the set of trusted Azure services to bypass the network rules. These services will then use strong authentication to access the storage account. If the Allow trusted Azure services exception is enabled, the following services are granted access to the storage account: Azure Backup, Azure Site Recovery, Azure DevTest Labs, Azure Event Grid, Azure Event Hubs, Azure Networking, Azure Monitor, and Azure SQL Data Warehouse (when registered in the subscription). Turning on firewall rules for storage account will block access to incoming requests for data, including from other Azure services. We can re-enable this functionality by enabling `"Trusted Azure Services"` through networking exceptions.

CIS_Azure_2.0.0

4.1.2

CIS_Azure_2.0.0_4.1.2

CIS Microsoft Azure Foundations Benchmark recommendation 4.1.2

4.1

Ensure no Azure SQL Databases allow ingress from 0.0.0.0/0 (ANY IP)

Shared

Disabling `Allow Azure services and resources to access this server` will break all connections to SQL server and Hosted Databases unless custom IP specific rules are added in Firewall Policy.

Ensure that no SQL Databases allow ingress from 0.0.0.0/0 (ANY IP). Azure SQL Server includes a firewall to block access to unauthorized connections. More granular IP addresses can be defined by referencing the range of addresses available from specific datacenters. By default, for a SQL server, a Firewall exists with StartIp of 0.0.0.0 and EndIP of 0.0.0.0 allowing access to all the Azure services. Additionally, a custom rule can be set up with StartIp of 0.0.0.0 and EndIP of 255.255.255.255 allowing access from ANY IP over the Internet. In order to reduce the potential attack surface for a SQL server, firewall rules should be defined with more granular IP addresses by referencing the range of addresses available from specific datacenters.

CIS_Azure_2.0.0

4.3.7

CIS_Azure_2.0.0_4.3.7

CIS Microsoft Azure Foundations Benchmark recommendation 4.3.7

4.3

Ensure 'Allow access to Azure services' for PostgreSQL Database Server is disabled

Shared

n/a

Disable access from Azure services to PostgreSQL Database Server. If access from Azure services is enabled, the server's firewall will accept connections from all Azure resources, including resources not in your subscription. This is usually not a desired configuration. Instead, set up firewall rules to allow access from specific network ranges or VNET rules to allow access from specific virtual networks.

FedRAMP_High_R4

AC-4

FedRAMP_High_R4_AC-4

FedRAMP High AC-4

Access Control

Information Flow Enforcement

Shared

n/a

The information system enforces approved authorizations for controlling the flow of information within the system and between interconnected systems based on [Assignment: organization-defined information flow control policies]. Supplemental Guidance: Information flow control regulates where information is allowed to travel within an information system and between information systems (as opposed to who is allowed to access the information) and without explicit regard to subsequent accesses to that information. Flow control restrictions include, for example, keeping export-controlled information from being transmitted in the clear to the Internet, blocking outside traffic that claims to be from within the organization, restricting web requests to the Internet that are not from the internal web proxy server, and limiting information transfers between organizations based on data structures and content. Transferring information between information systems representing different security domains with different security policies introduces risk that such transfers violate one or more domain security policies. In such situations, information owners/stewards provide guidance at designated policy enforcement points between interconnected systems. Organizations consider mandating specific architectural solutions when required to enforce specific security policies. Enforcement includes, for example: (i) prohibiting information transfers between interconnected systems (i.e., allowing access only); (ii) employing hardware mechanisms to enforce one-way information flows; and (iii) implementing trustworthy regarding mechanisms to reassign security attributes and security labels. Organizations commonly employ information flow control policies and enforcement mechanisms to control the flow of information between designated sources and destinations (e.g., networks, individuals, and devices) within information systems and between interconnected systems. Flow control is based on the characteristics of the information and/or the information path. Enforcement occurs, for example, in boundary protection devices (e.g., gateways, routers, guards, encrypted tunnels, firewalls) that employ rule sets or establish configuration settings that restrict information system services, provide a packet-filtering capability based on header information, or message- filtering capability based on message content (e.g., implementing key word searches or using document characteristics). Organizations also consider the trustworthiness of filtering/inspection mechanisms (i.e., hardware, firmware, and software components) that are critical to information flow enforcement. Control enhancements 3 through 22 primarily address cross-domain solution needs which focus on more advanced filtering techniques, in-depth analysis, and stronger flow enforcement mechanisms implemented in cross-domain products, for example, high-assurance guards. Such capabilities are generally not available in commercial off-the-shelf information technology products. Related controls: AC-3, AC-17, AC-19, AC-21, CM-6, CM-7, SA-8, SC-2, SC-5, SC-7, SC-18. References: None.

FedRAMP_High_R4

AC-4(21)

FedRAMP_High_R4_AC-4(21)

FedRAMP High AC-4 (21)

Access Control

Physical / Logical Separation Of Information Flows

Shared

n/a

The information system separates information flows logically or physically using [Assignment: organization-defined mechanisms and/or techniques] to accomplish [Assignment: organization- defined required separations by types of information]. Supplemental Guidance: Enforcing the separation of information flows by type can enhance protection by ensuring that information is not commingled while in transit and by enabling flow control by transmission paths perhaps not otherwise achievable. Types of separable information include, for example, inbound and outbound communications traffic, service requests and responses, and information of differing security categories.

FedRAMP_Moderate_R4

AC-4

FedRAMP_Moderate_R4_AC-4

FedRAMP Moderate AC-4

Access Control

Information Flow Enforcement

Shared

n/a

FedRAMP_Moderate_R4_AC-4(21)

FedRAMP_Moderate_R4

AC-4(21)

FedRAMP Moderate AC-4 (21)

Access Control

Physical / Logical Separation Of Information Flows

Shared

n/a

hipaa-0307.09q2Organizational.12-09.q

0307.09q2Organizational.12-09.q

0307.09q2Organizational.12-09.q

03 Portable Media Security

0307.09q2Organizational.12-09.q 09.07 Media Handling

Shared

n/a

Data transfers outside of controlled areas are approved and records of the transfers are maintained.

hipaa-0811.01n2Organizational.6-01.n

0811.01n2Organizational.6-01.n

0811.01n2Organizational.6-01.n

08 Network Protection

0811.01n2Organizational.6-01.n 01.04 Network Access Control

Shared

n/a

Exceptions to the traffic flow policy are documented with a supporting mission/business need, duration of the exception, and reviewed at least annually; traffic flow policy exceptions are removed when no longer supported by an explicit mission/business need.

hipaa-0817.01w2System.123-01.w

0817.01w2System.123-01.w

0817.01w2System.123-01.w

08 Network Protection

0817.01w2System.123-01.w 01.06 Application and Information Access Control

Shared

n/a

Unless the risk is identified and accepted by the data owner, sensitive systems are isolated (physically or logically) from non-sensitive applications/systems.

hipaa-0822.09m2Organizational.4-09.m

0822.09m2Organizational.4-09.m

0822.09m2Organizational.4-09.m

08 Network Protection

0822.09m2Organizational.4-09.m 09.06 Network Security Management

Shared

n/a

Firewalls restrict inbound and outbound traffic to the minimum necessary.

hipaa-0859.09m1Organizational.78-09.m

0859.09m1Organizational.78-09.m

0859.09m1Organizational.78-09.m

08 Network Protection

0859.09m1Organizational.78-09.m 09.06 Network Security Management

Shared

n/a

The organization ensures the security of information in networks, availability of network services and information services using the network, and the protection of connected services from unauthorized access.

hipaa-0928.09v1Organizational.45-09.v

0928.09v1Organizational.45-09.v

0928.09v1Organizational.45-09.v

09 Transmission Protection

0928.09v1Organizational.45-09.v 09.08 Exchange of Information

Shared

n/a

Stronger controls are implemented to protect certain electronic messages, and electronic messages are protected throughout the duration of its end-to-end transport path, using cryptographic mechanisms unless protected by alternative measures.

hipaa-0929.09v1Organizational.6-09.v

0929.09v1Organizational.6-09.v

0929.09v1Organizational.6-09.v

09 Transmission Protection

0929.09v1Organizational.6-09.v 09.08 Exchange of Information

Shared

n/a

The organization never sends unencrypted sensitive information by end-user messaging technologies (e.g., email, instant messaging, and chat).

hipaa-0944.09y1Organizational.2-09.y

0944.09y1Organizational.2-09.y

0944.09y1Organizational.2-09.y

09 Transmission Protection

0944.09y1Organizational.2-09.y 09.09 Electronic Commerce Services

Shared

n/a

Security is maintained through all aspects of the transaction.

hipaa-1131.01v2System.2-01.v

1131.01v2System.2-01.v

1131.01v2System.2-01.v

11 Access Control

1131.01v2System.2-01.v 01.06 Application and Information Access Control

Shared

n/a

Outputs from application systems handling covered information are limited to the minimum necessary and sent only to authorized terminals/locations.

hipaa-1150.01c2System.10-01.c

1150.01c2System.10-01.c

1150.01c2System.10-01.c

11 Access Control

1150.01c2System.10-01.c 01.02 Authorized Access to Information Systems

Shared

n/a

The access control system for the system components storing, processing or transmitting covered information is set with a default "deny-all" setting.

A.13.1.1

ISO27001-2013_A.13.1.1

ISO 27001:2013 A.13.1.1

Communications Security

Network controls

Shared

n/a

Networks shall be managed and controlled to protect information in systems and applications.

A.13.1.2

ISO27001-2013_A.13.1.2

ISO 27001:2013 A.13.1.2

Communications Security

Security of network services

Shared

n/a

Security mechanisms, service levels and management requirements of all network services shall be identified and included in network services agreements, whether these services are provided in-house or outsourced.

A.13.1.3

ISO27001-2013_A.13.1.3

ISO 27001:2013 A.13.1.3

Communications Security

Segregation of networks

Shared

n/a

Groups of information services, users, and information systems shall be segregated on networks.

A.13.2.1

ISO27001-2013_A.13.2.1

ISO 27001:2013 A.13.2.1

Communications Security

Information transfer policies and procedures

Shared

n/a

Formal transfer policies, procedures and controls shall be in place to protect the transfer of information through the use of all types of communication facilities.

A.13.2.3

ISO27001-2013_A.13.2.3

ISO 27001:2013 A.13.2.3

Communications Security

Electronic messaging

Shared

n/a

Information involved in electronic messaging shall be appropriately protected.

A.14.1.2

ISO27001-2013_A.14.1.2

ISO 27001:2013 A.14.1.2

System Acquisition, Development And Maintenance

Securing application services on public networks

Shared

n/a

Information involved in application services passing over public networks shall be protected from fraudulent activity, contract dispute and unauthorized disclosure and modification.

A.14.1.3

ISO27001-2013_A.14.1.3

ISO 27001:2013 A.14.1.3

System Acquisition, Development And Maintenance

Protecting application services transactions

Shared

n/a

Information involved in application service transactions shall be protected to prevent incomplete transmission, mis-routing, unauthorized message alteration, unauthorized disclosure, unauthorized message duplication or replay.

A.8.2.3

ISO27001-2013_A.8.2.3

ISO 27001:2013 A.8.2.3

Asset Management

Handling of assets

Shared

n/a

Procedures for handling assets shall be developed and implemented in accordance with the information classification scheme adopted by the organization.

NIST_SP_800-171_R2_3

.1.3

NIST_SP_800-171_R2_3.1.3

NIST SP 800-171 R2 3.1.3

Access Control

Control the flow of CUI in accordance with approved authorizations.

Shared

Microsoft and the customer share responsibilities for implementing this requirement.

Information flow control regulates where information can travel within a system and between systems (versus who can access the information) and without explicit regard to subsequent accesses to that information. Flow control restrictions include the following: keeping export-controlled information from being transmitted in the clear to the Internet; blocking outside traffic that claims to be from within the organization; restricting requests to the Internet that are not from the internal web proxy server; and limiting information transfers between organizations based on data structures and content. Organizations commonly use information flow control policies and enforcement mechanisms to control the flow of information between designated sources and destinations (e.g., networks, individuals, and devices) within systems and between interconnected systems. Flow control is based on characteristics of the information or the information path. Enforcement occurs in boundary protection devices (e.g., gateways, routers, guards, encrypted tunnels, firewalls) that employ rule sets or establish configuration settings that restrict system services, provide a packet-filtering capability based on header information, or message-filtering capability based on message content (e.g., implementing key word searches or using document characteristics). Organizations also consider the trustworthiness of filtering and inspection mechanisms (i.e., hardware, firmware, and software components) that are critical to information flow enforcement. Transferring information between systems representing different security domains with different security policies introduces risk that such transfers violate one or more domain security policies. In such situations, information owners or stewards provide guidance at designated policy enforcement points between interconnected systems. Organizations consider mandating specific architectural solutions when required to enforce specific security policies. Enforcement includes: prohibiting information transfers between interconnected systems (i.e., allowing access only); employing hardware mechanisms to enforce one-way information flows; and implementing trustworthy regrading mechanisms to reassign security attributes and security labels.

NIST_SP_800-53_R4

AC-4

NIST_SP_800-53_R4_AC-4

NIST SP 800-53 Rev. 4 AC-4

Access Control

Information Flow Enforcement

Shared

n/a

NIST_SP_800-53_R4_AC-4(21)

NIST_SP_800-53_R4

AC-4(21)

NIST SP 800-53 Rev. 4 AC-4 (21)

Access Control

Physical / Logical Separation Of Information Flows

Shared

n/a

NIST_SP_800-53_R5

AC-4

NIST_SP_800-53_R5_AC-4

NIST SP 800-53 Rev. 5 AC-4

Access Control

Information Flow Enforcement

Shared

n/a

Enforce approved authorizations for controlling the flow of information within the system and between connected systems based on [Assignment: organization-defined information flow control policies].

NIST_SP_800-53_R5_AC-4(21)

NIST_SP_800-53_R5

AC-4(21)

NIST SP 800-53 Rev. 5 AC-4 (21)

Access Control

Physical or Logical Separation of Information Flows

Shared

n/a

Separate information flows logically or physically using [Assignment: organization-defined mechanisms and/or techniques] to accomplish [Assignment: organization-defined required separations by types of information].

1.4.1

PCI_DSS_v4.0_1.4.1

PCI DSS v4.0 1.4.1

Requirement 01: Install and Maintain Network Security Controls

Network connections between trusted and untrusted networks are controlled

Shared

n/a

NSCs are implemented between trusted and untrusted networks.

1.4.2

PCI_DSS_v4.0_1.4.2

PCI DSS v4.0 1.4.2

Requirement 01: Install and Maintain Network Security Controls

Network connections between trusted and untrusted networks are controlled

Shared

n/a

Inbound traffic from untrusted networks to trusted networks is restricted to: • Communications with system components that are authorized to provide publicly accessible services, protocols, and ports. • Stateful responses to communications initiated by system components in a trusted network. • All other traffic is denied.

1.4.3

PCI_DSS_v4.0_1.4.3

PCI DSS v4.0 1.4.3

Requirement 01: Install and Maintain Network Security Controls

Network connections between trusted and untrusted networks are controlled

Shared

n/a

Anti-spoofing measures are implemented to detect and block forged source IP addresses from entering the trusted network.

1.4.4

PCI_DSS_v4.0_1.4.4

PCI DSS v4.0 1.4.4

Requirement 01: Install and Maintain Network Security Controls

Network connections between trusted and untrusted networks are controlled

Shared

n/a

System components that store cardholder data are not directly accessible from untrusted networks.

SOC_2

CC6.1

SOC_2_CC6.1

SOC 2 Type 2 CC6.1

Logical and Physical Access Controls

Logical access security software, infrastructure, and architectures

Shared

The customer is responsible for implementing this recommendation.

The following points of focus, specifically related to all engagements using the trust services criteria, highlight important characteristics relating to this criterion: • Identifies and Manages the Inventory of Information Assets — The entity identifies, Page 29 TSP Ref. # TRUST SERVICES CRITERIA AND POINTS OF FOCUS inventories, classifies, and manages information assets. • Restricts Logical Access — Logical access to information assets, including hardware, data (at-rest, during processing, or in transmission), software, administrative authorities, mobile devices, output, and offline system components is restricted through the use of access control software and rule sets. • Identifies and Authenticates Users — Persons, infrastructure, and software are identified and authenticated prior to accessing information assets, whether locally or remotely. • Considers Network Segmentation — Network segmentation permits unrelated portions of the entity's information system to be isolated from each other. • Manages Points of Access — Points of access by outside entities and the types of data that flow through the points of access are identified, inventoried, and managed. The types of individuals and systems using each point of access are identified, documented, and managed. • Restricts Access to Information Assets — Combinations of data classification, separate data structures, port restrictions, access protocol restrictions, user identification, and digital certificates are used to establish access-control rules for information assets. • Manages Identification and Authentication — Identification and authentication requirements are established, documented, and managed for individuals and systems accessing entity information, infrastructure, and software. • Manages Credentials for Infrastructure and Software — New internal and external infrastructure and software are registered, authorized, and documented prior to being granted access credentials and implemented on the network or access point. Credentials are removed and access is disabled when access is no longer required or the infrastructure and software are no longer in use. • Uses Encryption to Protect Data — The entity uses encryption to supplement other measures used to protect data at rest, when such protections are deemed appropriate based on assessed risk. • Protects Encryption Keys — Processes are in place to protect encryption keys during generation, storage, use, and destruction

SOC_2

CC6.6

SOC_2_CC6.6

SOC 2 Type 2 CC6.6

Logical and Physical Access Controls

Security measures against threats outside system boundaries

Shared

The customer is responsible for implementing this recommendation.

• Restricts Access — The types of activities that can occur through a communication channel (for example, FTP site, router port) are restricted. • Protects Identification and Authentication Credentials — Identification and authentication credentials are protected during transmission outside its system boundaries. • Requires Additional Authentication or Credentials — Additional authentication information or credentials are required when accessing the system from outside its boundaries. • Implements Boundary Protection Systems — Boundary protection systems (for example, firewalls, demilitarized zones, and intrusion detection systems) are implemented to protect external access points from attempts and unauthorized access and are monitored to detect such attempts

SOC_2

CC6.7

SOC_2_CC6.7

SOC 2 Type 2 CC6.7

Logical and Physical Access Controls

Restrict the movement of information to authorized users

Shared

The customer is responsible for implementing this recommendation.

• Restricts the Ability to Perform Transmission — Data loss prevention processes and technologies are used to restrict ability to authorize and execute transmission, movement, and removal of information. • Uses Encryption Technologies or Secure Communication Channels to Protect Data — Encryption technologies or secured communication channels are used to protect transmission of data and other communications beyond connectivity access points. • Protects Removal Media — Encryption technologies and physical asset protections are used for removable media (such as USB drives and backup tapes), as appropriate. • Protects Mobile Devices — Processes are in place to protect mobile devices (such as laptops, smart phones, and tablets) that serve as information assets

SWIFT_CSCF_v2022

1.5A

SWIFT_CSCF_v2022_1.5A

SWIFT CSCF v2022 1.5A

1. Restrict Internet Access & Protect Critical Systems from General IT Environment

Ensure the protection of the customer’s connectivity infrastructure from external environment and potentially compromised elements of the general IT environment.

Shared

n/a

A separated secure zone safeguards the customer's infrastructure used for external connectivity from external environments and compromises or attacks on the broader enterprise environment.

SWIFT_CSCF_v2022

2.1

SWIFT_CSCF_v2022_2.1

SWIFT CSCF v2022 2.1

2. Reduce Attack Surface and Vulnerabilities

Ensure the confidentiality, integrity, and authenticity of application data flows between local SWIFT-related components.

Shared

n/a

Confidentiality, integrity, and authentication mechanisms are implemented to protect SWIFT-related component-to-component or system-to-system data flows.

SWIFT_CSCF_v2022

2.9

SWIFT_CSCF_v2022_2.9

SWIFT CSCF v2022 2.9

2. Reduce Attack Surface and Vulnerabilities

Ensure outbound transaction activity within the expected bounds of normal business.

Shared

n/a

Implement transaction detection, prevention, and validation controls to ensure outbound transaction activity within the expected bounds of normal business.