FedRAMP ModeratevsCFTC System Safeguards (17 CFR 37, 38, 39, 49)
See exactly how FedRAMP Moderate controls map to CFTC System Safeguards (17 CFR 37, 38, 39, 49). Pre-computed mappings, identified gaps, and coverage analysis.
A reviewed coverage crosswalk for this pair is available. See which CFTC System Safeguards (17 CFR 37, 38, 39, 49) controls you already evidence.
According to the TheArtOfService Compliance Knowledge Graph:
FedRAMP Moderate maps to CFTC System Safeguards (17 CFR 37, 38, 39, 49) with 31% coverage across 99 directly mapped controls. Analysis of 323 FedRAMP Moderate controls identifies 224 compliance gaps, primarily concentrated in AC - Access Control.
Source: TheArtOfService Knowledge Graph | 323 controls analysed | 686 frameworks | 309K+ cross-framework mappings
Control Mappings
Showing 20 of 133 mapped controls across 18 domains. Sign up to explore all 309K+ mappings across 686 frameworks.
AC - Access Control(5 mappings)
AT - Awareness and Training(3 mappings)
AU - Audit and Accountability(5 mappings)
CA - Assessment, Authorization, and Monitoring(7 mappings)
+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
The FedRAMP Moderate to CFTC System Safeguards (17 CFR 37, 38, 39, 49) crosswalk
The table above lists candidate mappings. A crosswalk answers the narrower question you are probably here for: which CFTC System Safeguards (17 CFR 37, 38, 39, 49) controls your existing FedRAMP Moderate 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. FedRAMP Moderate into CFTC System Safeguards (17 CFR 37, 38, 39, 49) lands at 69.2%, while CFTC System Safeguards (17 CFR 37, 38, 39, 49) into FedRAMP Moderate lands at 9.9%, 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 FedRAMP Moderate evidence buys you for CFTC System Safeguards (17 CFR 37, 38, 39, 49), the other asks the reverse.
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.
A sample of what the report says
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.
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.
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.
A sample of what the report says
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.
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.
- 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 31% in the header counts how many FedRAMP Moderate controls carry at least one candidate mapping in the graph, before any review. The crosswalk percentage counts something stricter: how many CFTC System Safeguards (17 CFR 37, 38, 39, 49) 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 FedRAMP Moderate comparisons
Other CFTC System Safeguards (17 CFR 37, 38, 39, 49) comparisons
Stop Paying Consultants to Read Spreadsheets
AI-powered compliance intelligence across 686 frameworks, at a fraction of consulting costs.
Free
- ✓ 686 framework browser
- ✓ Cross-framework mappings (309K+)
- ✓ 824 compliance assessments
- ✓ 3 AI queries & searches per day
Professional
- ✓ Unlimited AI Compliance Advisory
- ✓ Unlimited full-text search
- ✓ Framework self-assessment
- ✓ PDF, Excel & CSV exports
What are the key differences between FedRAMP Moderate and CFTC System Safeguards (17 CFR 37, 38, 39, 49)?
FedRAMP Moderate has 323 controls across its framework, while CFTC System Safeguards (17 CFR 37, 38, 39, 49) covers 39 controls. Direct mapping analysis identifies 99 overlapping controls (31% coverage). The frameworks diverge most significantly in AC - Access Control, where 38 FedRAMP Moderate controls have no direct CFTC System Safeguards (17 CFR 37, 38, 39, 49) equivalent.
How many controls map between FedRAMP Moderate and CFTC System Safeguards (17 CFR 37, 38, 39, 49)?
Of 323 total FedRAMP Moderate controls, 99 map directly to CFTC System Safeguards (17 CFR 37, 38, 39, 49) controls, representing 31% coverage. The remaining 224 controls represent compliance gaps requiring additional documentation or compensating controls to satisfy both frameworks simultaneously.
What are the compliance gaps when mapping FedRAMP Moderate to CFTC System Safeguards (17 CFR 37, 38, 39, 49)?
224 FedRAMP Moderate controls have no direct equivalent in CFTC System Safeguards (17 CFR 37, 38, 39, 49). The highest concentration of gaps is in AC - Access Control with 38 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 FedRAMP Moderate and CFTC System Safeguards (17 CFR 37, 38, 39, 49)?
The domain with the highest gap count is AC - Access Control (38 gaps). Export the full domain-by-domain gap breakdown via the Professional tier to generate a prioritised remediation roadmap.
Related Resources
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.