Cross-Framework Mapping

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.

133
Controls Mapped
190
Gaps Found
31%
Coverage

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 | 868 frameworks | 315K+ cross-framework mappings

Control Mappings

Showing 20 of 133 mapped controls across 18 domains. Sign up to explore all 315K+ mappings across 868 frameworks.

AC - Access Control(5 mappings)

AC-1Policy and Procedures
→CFTC-SS-3Information Security Category
AC-2Account Management
→CFTC-SS-3Information Security Category
AC-3Access Enforcement
→CFTC-SS-3Information Security Category
AC-5Separation of Duties
→CFTC-SS-3Information Security Category
AC-6Least Privilege
→CFTC-SS-3Information Security Category

AT - Awareness and Training(3 mappings)

AT-1Policy and Procedures
→CFTC-SS-3Information Security Category
AT-2Literacy Training and Awareness
→CFTC-SS-3Information Security Category
AT-3Role-Based Training
→CFTC-SS-5Systems Development and Quality Assurance Category

AU - Audit and Accountability(5 mappings)

AU-11Audit Record Retention
→CFTC-SS-20Production of System Safeguards Books and Records
AU-12Audit Record Generation
→CFTC-SS-3Information Security Category
AU-2Event Logging
→CFTC-SS-3Information Security Category
AU-4Audit Log Storage Capacity
→CFTC-SS-12Capacity and Performance Planning Category
AU-6Audit Record Review, Analysis, and Reporting
→CFTC-SS-3Information Security Category

CA - Assessment, Authorization, and Monitoring(7 mappings)

CA-2Control Assessments5 targets
→CFTC-SS-15Controls Testing
→CFTC-SS-18Independence of Testers
→CFTC-SS-2Enterprise Risk Management and Governance Category
→CFTC-SS-33Regular Periodic Objective Testing and Review of Automated Systems
→CFTC-SS-38Production of Annual Total Trading Volume
CA-2(1)Independent Assessors2 targets
→CFTC-SS-15Controls Testing
→CFTC-SS-18Independence of Testers

+113 more mappings

Plus AI-powered gap analysis, compliance advisory, PDF exports, and cross-mapping for all 868 frameworks.

Create Free Account →

Free forever, no credit card required

Coverage crosswalk

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.

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.

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.

FedRAMP Moderate to CFTC System Safeguards (17 CFR 37, 38, 39, 49)
$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 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.

Stop Paying Consultants to Read Spreadsheets

Cross-framework mappings across 868 frameworks, at a fraction of consulting costs.

$0/forever

Free

  • ✓ 868 framework browser
  • ✓ Cross-framework mappings (315K+)
  • ✓ 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 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.

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.