TheArtOfService
Cross-Framework Mapping

NIST Cybersecurity Framework 2.0vsCFTC System Safeguards (17 CFR 37, 38, 39, 49)

See exactly how NIST Cybersecurity Framework 2.0 controls map to CFTC System Safeguards (17 CFR 37, 38, 39, 49). Pre-computed mappings, identified gaps, and coverage analysis.

131
Controls Mapped
0
Gaps Found
77%
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:

NIST Cybersecurity Framework 2.0 maps to CFTC System Safeguards (17 CFR 37, 38, 39, 49) with 77% coverage across 82 directly mapped controls. Analysis of 106 NIST Cybersecurity Framework 2.0 controls identifies 24 compliance gaps, primarily concentrated in RS - Respond.

Source: TheArtOfService Knowledge Graph | 106 controls analysed | 686 frameworks | 310K+ cross-framework mappings

Control Mappings

Showing 20 of 131 mapped controls across 7 domains. Sign up to explore all 310K+ mappings across 686 frameworks.

DE - Detect(9 mappings)

NIST-CSF-DE.AE-02Potentially adverse events are analyzed to better understand associated activities
→CFTC-SS-16Security Incident Response Plan and Testing
NIST-CSF-DE.AE-06Information on adverse events is provided to authorized staff and tools
→CFTC-SS-16Security Incident Response Plan and Testing
NIST-CSF-DE.AE-08Incidents are declared when adverse events meet the defined incident criteria
→CFTC-SS-16Security Incident Response Plan and Testing
NIST-CSF-DE.CM-01Networks and network services are monitored to find potentially adverse events
→CFTC-SS-3Information Security Category
NIST-CSF-DE.CM-02The physical environment is monitored to find potentially adverse events
→CFTC-SS-6Physical Security and Environmental Controls Category
NIST-CSF-DE.CM-03Personnel activity and technology usage are monitored to find potentially adverse events
→CFTC-SS-3Information Security Category
NIST-CSF-DE.CM-06External service provider activities and services are monitored to find potentially adverse events
→CFTC-SS-30Outsourcing with Retention of Complete Responsibility
NIST-CSF-DE.CM-09Computing hardware and software, runtime environments, and their data are monitored to find potentially adverse events2 targets
→CFTC-SS-12Capacity and Performance Planning Category
→CFTC-SS-13Vulnerability Testing

GV - Govern(11 mappings)

NIST-CSF-GV.OC-03Legal, regulatory, and contractual requirements regarding cybersecurity - including privacy and civil liberties obligations - are understood and managed4 targets
→CFTC-SS-19Prompt Notification to the Commission
→CFTC-SS-20Production of System Safeguards Books and Records
→CFTC-SS-39Critical Financial Market Designation Obligations
→CFTC-SS-7Generally Accepted Standards and Best Practices
NIST-CSF-GV.OC-04Critical objectives, capabilities, and services that external stakeholders depend on or expect from the organization are understood and communicated
→CFTC-SS-23Resources Sufficient to Fulfil Obligations
NIST-CSF-GV.OC-05Outcomes, capabilities, and services that the organization depends on are understood and communicated2 targets
→CFTC-SS-27Coordination of the Recovery Plan with Members and Market Participants
→CFTC-SS-29Recovery Plan Accounts for Essential Service Providers
NIST-CSF-GV.PO-01Policy for managing cybersecurity risks is established based on organizational context, cybersecurity strategy, and priorities and is communicated and enforced2 targets
→CFTC-SS-1Program of Risk Analysis and Oversight
→CFTC-SS-7Generally Accepted Standards and Best Practices
NIST-CSF-GV.PO-02Policy for managing cybersecurity risks is reviewed, updated, communicated, and enforced to reflect changes in requirements, threats, technology, and organizational mission
→CFTC-SS-32Timely Advance Notice of Material Planned Changes
NIST-CSF-GV.RM-01Risk management objectives are established and agreed to by organizational stakeholders
→CFTC-SS-1Program of Risk Analysis and Oversight

+111 more mappings

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Coverage crosswalk

The NIST Cybersecurity Framework 2.0 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 NIST Cybersecurity Framework 2.0 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. NIST Cybersecurity Framework 2.0 into CFTC System Safeguards (17 CFR 37, 38, 39, 49) lands at 71.8%, while CFTC System Safeguards (17 CFR 37, 38, 39, 49) into NIST Cybersecurity Framework 2.0 lands at 29.2%, 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 NIST Cybersecurity Framework 2.0 evidence buys you for CFTC System Safeguards (17 CFR 37, 38, 39, 49), the other asks the reverse.

NIST Cybersecurity Framework 2.0 into CFTC System Safeguards (17 CFR 37, 38, 39, 49)
71.8%

28 of 39 CFTC System Safeguards (17 CFR 37, 38, 39, 49) controls are evidenced by work you have already done for NIST Cybersecurity Framework 2.0. 11 are genuine gaps.

80%CFTC System Safeguards: Risk Analysis and Oversight Program
80%CFTC System Safeguards: Cybersecurity Testing
58.3%CFTC System Safeguards: Business Continuity and Disaster Recovery
75%CFTC System Safeguards: Notification, Records and Remediation
Machine verified. Claude Code on the Max plan, judged in context, signed off 2026-08-19. 81 candidate mappings were examined and 5 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

Both require risk management objectives established and agreed for the programme.

Grounded in NIST-CSF-GV.RM-01 Risk management objectives are established and agreed to by organizational stakeholders. Confidence high, survived the refutation pass.

Gap: 37.1401(a)(6), 38.1051(a)(6), 39.18(b)(2)(v), 49.24(b)(6) Systems Development and Quality Assurance Category

Address systems development and quality assurance within the program, covering requirements development, pre production and regression testing, change management procedures and approvals, outsourcing and vendor management, and training in...

Every one of the 28 evidenced controls and 11 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) into NIST Cybersecurity Framework 2.0
29.2%

31 of 106 NIST Cybersecurity Framework 2.0 controls are evidenced by work you have already done for CFTC System Safeguards (17 CFR 37, 38, 39, 49). 75 are genuine gaps.

42.9%ID - Identify
40.9%PR - Protect
21.4%GV - Govern
23.1%RS - Respond
Machine verified. Claude Code on the Max plan, judged in context, signed off 2026-08-19. 84 candidate mappings were examined and 6 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: NIST-CSF-DE.AE-08 Incidents are declared when adverse events meet the defined incident criteria

Plan must define and classify what constitutes a security incident.

Grounded in CFTC-SS-16 Security Incident Response Plan and Testing. Confidence high, survived the refutation pass.

Gap: NIST-CSF-DE.AE-02 Potentially adverse events are analyzed to better understand associated activities

Potentially adverse events are analyzed to better understand associated activities. Control from NIST Cybersecurity Framework 2.0 framework, domain: DE - Detect.

Every one of the 31 evidenced controls and 75 gaps in the report carries this much reasoning, so you can check the claim rather than take it on trust.

NIST Cybersecurity Framework 2.0 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 77% in the header counts how many NIST Cybersecurity Framework 2.0 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 NIST Cybersecurity Framework 2.0 comparisons

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

FedRAMP High vs CFTC System Safeguards (17 CFR 37, 38, 39, 49)39 mappingsFedRAMP Moderate vs CFTC System Safeguards (17 CFR 37, 38, 39, 49)39 mappingsNIST SP 800-53 Revision 5.1 HIGH vs CFTC System Safeguards (17 CFR 37, 38, 39, 49)38 mappingsC5 (Germany) vs CFTC System Safeguards (17 CFR 37, 38, 39, 49)38 mappingsNIST SP 800-161 Rev 1 vs CFTC System Safeguards (17 CFR 37, 38, 39, 49)38 mappingsNIST SP 800-53 Rev 5 MODERATE vs CFTC System Safeguards (17 CFR 37, 38, 39, 49)36 mappingsCloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1 vs CFTC System Safeguards (17 CFR 37, 38, 39, 49)36 mappingsNIST SP 800-53 Rev 5 vs CFTC System Safeguards (17 CFR 37, 38, 39, 49)35 mappings

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What are the key differences between NIST Cybersecurity Framework 2.0 and CFTC System Safeguards (17 CFR 37, 38, 39, 49)?

NIST Cybersecurity Framework 2.0 has 106 controls across its framework, while CFTC System Safeguards (17 CFR 37, 38, 39, 49) covers 39 controls. Direct mapping analysis identifies 82 overlapping controls (77% coverage). The frameworks diverge most significantly in RS - Respond, where 7 NIST Cybersecurity Framework 2.0 controls have no direct CFTC System Safeguards (17 CFR 37, 38, 39, 49) equivalent.

How many controls map between NIST Cybersecurity Framework 2.0 and CFTC System Safeguards (17 CFR 37, 38, 39, 49)?

Of 106 total NIST Cybersecurity Framework 2.0 controls, 82 map directly to CFTC System Safeguards (17 CFR 37, 38, 39, 49) controls, representing 77% coverage. The remaining 24 controls represent compliance gaps requiring additional documentation or compensating controls to satisfy both frameworks simultaneously.

What are the compliance gaps when mapping NIST Cybersecurity Framework 2.0 to CFTC System Safeguards (17 CFR 37, 38, 39, 49)?

24 NIST Cybersecurity Framework 2.0 controls have no direct equivalent in CFTC System Safeguards (17 CFR 37, 38, 39, 49). The highest concentration of gaps is in RS - Respond with 7 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 NIST Cybersecurity Framework 2.0 and CFTC System Safeguards (17 CFR 37, 38, 39, 49)?

The domain with the highest gap count is RS - Respond (7 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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