Cross-Framework Mapping

CFTC System Safeguards (17 CFR 37, 38, 39, 49)vsPCI DSS 4.0

Name: CFTC System Safeguards (17 CFR 37, 38, 39, 49) to PCI DSS 4.0 Control Mapping Dataset
Creator: TheArtOfService

See exactly how CFTC System Safeguards (17 CFR 37, 38, 39, 49) controls map to PCI DSS 4.0. Pre-computed mappings, identified gaps, and coverage analysis.

Controls Mapped

Gaps Found

67%

Coverage

A reviewed coverage crosswalk for this pair is available. See which PCI DSS 4.0 controls you already evidence.

According to the TheArtOfService Compliance Knowledge Graph:

CFTC System Safeguards (17 CFR 37, 38, 39, 49) maps to PCI DSS 4.0 with 67% coverage across 26 directly mapped controls. Analysis of 39 CFTC System Safeguards (17 CFR 37, 38, 39, 49) controls identifies 13 compliance gaps, primarily concentrated in CFTC System Safeguards: Business Continuity and Disaster Recovery.

Source: TheArtOfService Knowledge Graph | 39 controls analysed | 686 frameworks | 310K+ cross-framework mappings

Control Mappings

Showing 20 of 82 mapped controls across 5 domains. Sign up to explore all 310K+ mappings across 686 frameworks.

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

CFTC-SS-1Program of Risk Analysis and Oversight2 targets

→12.1.1An overall information security policy is: • Established. • Published. • Maintained. • Disseminated to all relevant personnel, as well as to relevant vendors and business partners

→12.3.1Targeted risk analysis documented for requirements that specify one

CFTC-SS-2Enterprise Risk Management and Governance Category4 targets

→12.1.1An overall information security policy is: • Established. • Published. • Maintained. • Disseminated to all relevant personnel, as well as to relevant vendors and business partners

→12.1.3Information security roles and responsibilities defined and acknowledged

→12.3.1Targeted risk analysis documented for requirements that specify one

→12.4.1Executive management responsibility for the PCI DSS compliance program (service providers)

CFTC-SS-3Information Security Category13 targets

→10.2.1Audit logs enabled on system components

→10.4.1Daily log review for critical systems

→12.6.1Formal security awareness program implemented

→12.6.3Security awareness training delivered

→12.7.1Personnel screening

→7.2.1An access control model is defined and includes granting access as follows: • Appropriate access depending on the entity's business and access needs. • Access to system components and data resources that is based

→7.2.2Access is assigned to users, including privileged users, based on: • Job classification and function. • Least privileges necessary to perform job responsibilities

→8.2.1All users are assigned a unique ID before access to system components or cardholder data is allowed

→8.3.1All user access to system components for users and administrators is authenticated via at least one of the following authentication factors: • Something you know, such as a password or passphrase. • Something you

→9.4.1Media with cardholder data physically secured

→9.4.7Electronic media destruction

→pci-dss-4-0::5.2.1An anti-malware solution(s) is deployed on all system components, except for those system components identified in periodic evaluations per Requirement 5.2.3 that concludes the system components are not at risk from malware

→pci-dss-4-0::7.3.1An access control system(s) is in place that restricts access based on a user's need to know and covers all system components

CFTC-SS-4Systems Operations Category

→10.7.2Critical security control failure detection (all entities)

+62 more mappings

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Coverage crosswalk

The CFTC System Safeguards (17 CFR 37, 38, 39, 49) to PCI DSS 4.0 crosswalk

The table above lists candidate mappings. A crosswalk answers the narrower question you are probably here for: which PCI DSS 4.0 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 PCI DSS 4.0 lands at 9.2%, while PCI DSS 4.0 into CFTC System Safeguards (17 CFR 37, 38, 39, 49) lands at 30.8%, 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 PCI DSS 4.0, the other asks the reverse.

CFTC System Safeguards (17 CFR 37, 38, 39, 49) into PCI DSS 4.0

9.2%

23 of 249 PCI DSS 4.0 controls are evidenced by work you have already done for CFTC System Safeguards (17 CFR 37, 38, 39, 49). 226 are genuine gaps.

21.6%Req 12: Information Security Policies

28.6%Req 11: Test Security Regularly

26.3%Req 6: Secure Systems and Software

11.5%Req 9: Restrict Physical Access

Machine verified. Claude Code on the Max plan, judged in context, signed off 2026-08-19. 51 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: 11.1.1 Testing policy documented

Requires regular periodic objective testing and review covering all required test types.

Grounded in CFTC-SS-33 Regular Periodic Objective Testing and Review of Automated Systems. Confidence high, survived the refutation pass.

Gap: 1.1.1 NSC policies and procedures documented

All security policies and operational procedures for Requirement 1 are documented, kept current, in use, and known to affected parties.

Every one of the 23 evidenced controls and 226 gaps in the report carries this much reasoning, so you can check the claim rather than take it on trust.

PCI DSS 4.0 into CFTC System Safeguards (17 CFR 37, 38, 39, 49)

30.8%

12 of 39 CFTC System Safeguards (17 CFR 37, 38, 39, 49) controls are evidenced by work you have already done for PCI DSS 4.0. 27 are genuine gaps.

60%CFTC System Safeguards: Cybersecurity Testing

40%CFTC System Safeguards: Risk Analysis and Oversight Program

8.3%CFTC System Safeguards: Business Continuity and Disaster Recovery

25%CFTC System Safeguards: Notification, Records and Remediation

Machine verified. Claude Code on the Max plan, judged in context, signed off 2026-08-19. 60 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)(2), 38.1051(a)(2), 39.18(b)(2)(i), 49.24(b)(2) Information Security Category

Access assigned by job classification and least privilege is the least privilege element.

Grounded in 7.2.2 Access is assigned to users, including privileged users, based on: • Job classification and function. • Least privileges necessary to perform job responsibilities. Confidence high, survived the refutation pass.

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

Address enterprise risk management and governance within the program, covering assessment, mitigation and monitoring of security and technology risk, security and technology capital planning and investment, board and management oversight,...

Every one of the 12 evidenced controls and 27 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 PCI DSS 4.0

$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 67% 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 PCI DSS 4.0 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.

Related Comparisons

Other CFTC System Safeguards (17 CFR 37, 38, 39, 49) comparisons

Other PCI DSS 4.0 comparisons

SOC 2 vs PCI DSS 4.0247 mappings ISO 27002:2022 vs PCI DSS 4.0247 mappings NIST SP 800-53 Rev 5 vs PCI DSS 4.0246 mappings ISO 27001:2022 vs PCI DSS 4.0246 mappings FedRAMP Moderate vs PCI DSS 4.0245 mappings FedRAMP High vs PCI DSS 4.0245 mappings NIST SP 800-53 Revision 5.1 HIGH vs PCI DSS 4.0240 mappings Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1 vs PCI DSS 4.0240 mappings

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What are the key differences between CFTC System Safeguards (17 CFR 37, 38, 39, 49) and PCI DSS 4.0?

CFTC System Safeguards (17 CFR 37, 38, 39, 49) has 39 controls across its framework, while PCI DSS 4.0 covers 249 controls. Direct mapping analysis identifies 26 overlapping controls (67% coverage). The frameworks diverge most significantly in CFTC System Safeguards: Business Continuity and Disaster Recovery, where 8 CFTC System Safeguards (17 CFR 37, 38, 39, 49) controls have no direct PCI DSS 4.0 equivalent.

How many controls map between CFTC System Safeguards (17 CFR 37, 38, 39, 49) and PCI DSS 4.0?

Of 39 total CFTC System Safeguards (17 CFR 37, 38, 39, 49) controls, 26 map directly to PCI DSS 4.0 controls, representing 67% coverage. The remaining 13 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 PCI DSS 4.0?

13 CFTC System Safeguards (17 CFR 37, 38, 39, 49) controls have no direct equivalent in PCI DSS 4.0. The highest concentration of gaps is in CFTC System Safeguards: Business Continuity and Disaster Recovery with 8 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 PCI DSS 4.0?

The domain with the highest gap count is CFTC System Safeguards: Business Continuity and Disaster Recovery (8 gaps). Export the full domain-by-domain gap breakdown via the Professional tier to generate a prioritised remediation roadmap.

Related Resources

How to Map Controls Across Frameworks|Multi-Framework Compliance Guide|Compliance Glossary

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