Cross-Framework Mapping

CFTC System Safeguards (17 CFR 37, 38, 39, 49)vsFedRAMP Moderate

See exactly how CFTC System Safeguards (17 CFR 37, 38, 39, 49) controls map to FedRAMP Moderate. Pre-computed mappings, identified gaps, and coverage analysis.

133
Controls Mapped
0
Gaps Found
100%
Coverage

A reviewed coverage crosswalk for this pair is available. See which FedRAMP Moderate controls you already evidence.

According to the TheArtOfService Compliance Knowledge Graph:

CFTC System Safeguards (17 CFR 37, 38, 39, 49) maps to FedRAMP Moderate with 100% coverage across 39 directly mapped controls. Analysis of 39 CFTC System Safeguards (17 CFR 37, 38, 39, 49) controls identifies 0 compliance gaps, primarily concentrated in CFTC System Safeguards: Registrant Specific Requirements.

Source: TheArtOfService Knowledge Graph | 39 controls analysed | 686 frameworks | 309K+ cross-framework mappings

Control Mappings

Showing 20 of 133 mapped controls across 5 domains. Sign up to explore all 309K+ mappings across 686 frameworks.

CFTC System Safeguards: Risk Analysis and Oversight Program(20 mappings)

CFTC-SS-1Program of Risk Analysis and Oversight3 targets
CA-7Continuous Monitoring
PL-2System Security and Privacy Plans
RA-3Risk Assessment
CFTC-SS-12Capacity and Performance Planning Category3 targets
AU-4Audit Log Storage Capacity
CM-4Impact Analyses
SC-5Denial-of-Service Protection
CFTC-SS-2Enterprise Risk Management and Governance Category4 targets
CA-2Control Assessments
CA-5Plan of Action and Milestones
CA-7(4)Continuous Monitoring | Risk Monitoring. Ensure risk monitoring is an integral part of the continuous monitoring strategy that includes the following: (a) Effectiveness monitoring; (b) Compliance monitoring; and (c) Change monitoring
RA-3Risk Assessment
CFTC-SS-22Business Continuity and Disaster Recovery Planning Category3 targets
CP-2Contingency Plan
CP-4Contingency Plan Testing
CP-7Alternate Processing Site
CFTC-SS-23Resources Sufficient to Fulfil Obligations3 targets
CP-2(3)Resume Mission and Business Functions
RA-9Criticality Analysis. Identify critical system components and functions by performing a criticality analysis for [Assignment: organization-defined systems, system components, or system services] at [Assignment: organization-defined decision points in the system development life cycle]
SA-2Allocation of Resources
CFTC-SS-3Information Security Category4 targets
AC-1Policy and Procedures
AC-2Account Management
AC-3Access Enforcement
AC-5Separation of Duties

+113 more mappings

Plus AI-powered gap analysis, compliance advisory, PDF exports, and cross-mapping for all 686 frameworks.

Create Free Account →

Free forever, no credit card required

Coverage crosswalk

The CFTC System Safeguards (17 CFR 37, 38, 39, 49) to FedRAMP Moderate crosswalk

The table above lists candidate mappings. A crosswalk answers the narrower question you are probably here for: which FedRAMP Moderate controls your existing CFTC System Safeguards (17 CFR 37, 38, 39, 49) work already satisfies, which are real gaps, and the reasoning behind every claim so you can check it. One pair, $299, one time.

Coverage does not run both ways. CFTC System Safeguards (17 CFR 37, 38, 39, 49) into FedRAMP Moderate lands at 9.9%, while FedRAMP Moderate into CFTC System Safeguards (17 CFR 37, 38, 39, 49) lands at 69.2%, on the same two control sets. That is not a rounding difference. It is the whole reason these are two separate reports: one asks what your CFTC System Safeguards (17 CFR 37, 38, 39, 49) evidence buys you for FedRAMP Moderate, the other asks the reverse.

CFTC System Safeguards (17 CFR 37, 38, 39, 49) into FedRAMP Moderate
9.9%

32 of 323 FedRAMP Moderate controls are evidenced by work you have already done for CFTC System Safeguards (17 CFR 37, 38, 39, 49). 291 are genuine gaps.

30.4%CP - Contingency Planning
28.6%CA - Assessment, Authorization, and Monitoring
23.5%IR - Incident Response
19%SA - System and Services Acquisition
Machine verified. Claude Code on the Max plan, judged in context, signed off 2026-08-19. 82 candidate mappings were examined and 1 were removed by a pass whose job was to argue against them.Mappings were judged by Claude Code rather than read line by line by a practitioner. Every claim shows its reasoning so you can check it. Ask and a practitioner will review this pair.

A sample of what the report says

Evidenced: AC-6 Least Privilege

Expressly requires access to systems and data on a least privilege basis.

Grounded in CFTC-SS-3 Information Security Category. Confidence high, survived the refutation pass.

Gap: AC-1 Policy and Procedures

Develop and disseminate access control policy and procedures; review at least annually (FedRAMP parameter); update following defined events.

Every one of the 32 evidenced controls and 291 gaps in the report carries this much reasoning, so you can check the claim rather than take it on trust.

FedRAMP Moderate into CFTC System Safeguards (17 CFR 37, 38, 39, 49)
69.2%

27 of 39 CFTC System Safeguards (17 CFR 37, 38, 39, 49) controls are evidenced by work you have already done for FedRAMP Moderate. 12 are genuine gaps.

75%CFTC System Safeguards: Business Continuity and Disaster Recovery
80%CFTC System Safeguards: Risk Analysis and Oversight Program
80%CFTC System Safeguards: Cybersecurity Testing
25%CFTC System Safeguards: Notification, Records and Remediation
Machine verified. Claude Code on the Max plan, judged in context, signed off 2026-08-19. 88 candidate mappings were examined and 0 were removed by a pass whose job was to argue against them.Mappings were judged by Claude Code rather than read line by line by a practitioner. Every claim shows its reasoning so you can check it. Ask and a practitioner will review this pair.

A sample of what the report says

Evidenced: 37.1401(a)(1), 38.1051(a)(1), 49.24(b)(1) Enterprise Risk Management and Governance Category

Plan of action and milestones drives remediation of identified deficiencies.

Grounded in CA-5 Plan of Action and Milestones. Confidence high, survived the refutation pass.

Gap: 37.1401(b), 38.1051(b), 39.18(b)(3), 49.24(c) Generally Accepted Standards and Best Practices

In addressing the prescribed categories, follow generally accepted standards and best practices with respect to the development, operation, reliability, security and capacity of automated systems.

Every one of the 27 evidenced controls and 12 gaps in the report carries this much reasoning, so you can check the claim rather than take it on trust.

CFTC System Safeguards (17 CFR 37, 38, 39, 49) to FedRAMP Moderate
$299
per framework pair, one time
  • Every evidenced control, with the reasoning behind it
  • Every gap, with what it requires
  • Its level of review stated plainly, not a bare number

Why this page shows two different percentages. The 100% in the header counts how many CFTC System Safeguards (17 CFR 37, 38, 39, 49) controls carry at least one candidate mapping in the graph, before any review. The crosswalk percentage counts something stricter: how many FedRAMP Moderate controls are actually evidenced, after a pass that argued against each mapping and kept only what survived. They answer different questions and they are not meant to agree.

A crosswalk narrows the work. It does not replace an audit, and your assessor may take a different view on individual controls. Mappings between frameworks are judgements, not text printed in either standard, which is why every claim in the report shows its reasoning. Questions go to support@theartofservice.com.

Stop Paying Consultants to Read Spreadsheets

AI-powered compliance intelligence across 686 frameworks, at a fraction of consulting costs.

$0/forever

Free

  • 686 framework browser
  • Cross-framework mappings (309K+)
  • 824 compliance assessments
  • 3 AI queries & searches per day
Get Started Free
Recommended
$149/month

Professional

  • Unlimited AI Compliance Advisory
  • Unlimited full-text search
  • Framework self-assessment
  • PDF, Excel & CSV exports
Start 7-Day Free Trial →

What are the key differences between CFTC System Safeguards (17 CFR 37, 38, 39, 49) and FedRAMP Moderate?

CFTC System Safeguards (17 CFR 37, 38, 39, 49) has 39 controls across its framework, while FedRAMP Moderate covers 323 controls. Direct mapping analysis identifies 39 overlapping controls (100% coverage). The frameworks diverge most significantly in CFTC System Safeguards: Registrant Specific Requirements, where 0 CFTC System Safeguards (17 CFR 37, 38, 39, 49) controls have no direct FedRAMP Moderate equivalent.

How many controls map between CFTC System Safeguards (17 CFR 37, 38, 39, 49) and FedRAMP Moderate?

Of 39 total CFTC System Safeguards (17 CFR 37, 38, 39, 49) controls, 39 map directly to FedRAMP Moderate controls, representing 100% coverage. The remaining 0 controls represent compliance gaps requiring additional documentation or compensating controls to satisfy both frameworks simultaneously.

What are the compliance gaps when mapping CFTC System Safeguards (17 CFR 37, 38, 39, 49) to FedRAMP Moderate?

0 CFTC System Safeguards (17 CFR 37, 38, 39, 49) controls have no direct equivalent in FedRAMP Moderate. The highest concentration of gaps is in CFTC System Safeguards: Registrant Specific Requirements with 0 unmapped controls. These gaps represent areas where additional controls, policies, or documentation must be created to achieve compliance with both frameworks.

Which control domains have the most gaps between CFTC System Safeguards (17 CFR 37, 38, 39, 49) and FedRAMP Moderate?

The domain with the highest gap count is CFTC System Safeguards: Registrant Specific Requirements (0 gaps). Export the full domain-by-domain gap breakdown via the Professional tier to generate a prioritised remediation roadmap.

This platform provides educational compliance tools, not legal, regulatory, or professional compliance advice. Cross-framework mappings are AI-assisted interpretations and do not reproduce or replace official standards. Framework names and trademarks belong to their respective owners. Consult qualified professionals for your specific compliance requirements. See our Terms of Service.