Cross-Framework Mapping

NIST SP 800-161 Rev 1vsCFTC System Safeguards (17 CFR 37, 38, 39, 49)

See exactly how NIST SP 800-161 Rev 1 controls map to CFTC System Safeguards (17 CFR 37, 38, 39, 49). Pre-computed mappings, identified gaps, and coverage analysis.

101
Controls Mapped
90
Gaps Found
29%
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 SP 800-161 Rev 1 maps to CFTC System Safeguards (17 CFR 37, 38, 39, 49) with 29% coverage across 55 directly mapped controls. Analysis of 191 NIST SP 800-161 Rev 1 controls identifies 136 compliance gaps, primarily concentrated in C-SCRM Family: Program Management.

Source: TheArtOfService Knowledge Graph | 191 controls analysed | 686 frameworks | 310K+ cross-framework mappings

Control Mappings

Showing 20 of 101 mapped controls across 17 domains. Sign up to explore all 310K+ mappings across 686 frameworks.

C-SCRM Family: Access Control(2 mappings)

161R1-AC-5Separation of Duties
CFTC-SS-18Independence of Testers
161R1-AC-6Least Privilege
CFTC-SS-3Information Security Category

C-SCRM Family: Audit and Accountability(1 mappings)

161R1-AU-6Audit Review, Analysis, and Reporting
CFTC-SS-3Information Security Category

C-SCRM Family: Assessment, Authorization, and Monitoring(14 mappings)

161R1-CA-2Control Assessments7 targets
CFTC-SS-14External Penetration Testing
CFTC-SS-15Controls Testing
CFTC-SS-18Independence of Testers
CFTC-SS-2Enterprise Risk Management and Governance Category
CFTC-SS-31Testing Covers Outsourced Resources and Tester Independence from Providers
CFTC-SS-33Regular Periodic Objective Testing and Review of Automated Systems
CFTC-SS-34Internal Penetration Testing
161R1-CA-3Information Exchange
CFTC-SS-27Coordination of the Recovery Plan with Members and Market Participants
161R1-CA-5Plan of Action and Milestones3 targets
CFTC-SS-2Enterprise Risk Management and Governance Category
CFTC-SS-21Remediation of Vulnerabilities and Deficiencies
CFTC-SS-36Internal Reporting and Review by Senior Management and the Board
161R1-CA-7Continuous Monitoring3 targets
CFTC-SS-1Program of Risk Analysis and Oversight
CFTC-SS-15Controls Testing
CFTC-SS-33Regular Periodic Objective Testing and Review of Automated Systems

C-SCRM Family: Configuration Management(3 mappings)

161R1-CM-2Baseline Configuration
CFTC-SS-4Systems Operations Category
161R1-CM-3Configuration Change Control2 targets
CFTC-SS-32Timely Advance Notice of Material Planned Changes
CFTC-SS-4Systems Operations Category

+81 more mappings

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Coverage crosswalk

The NIST SP 800-161 Rev 1 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 SP 800-161 Rev 1 work already satisfies, which are real gaps, and the reasoning behind every claim so you can check it. One pair, $299, one time.

NIST SP 800-161 Rev 1 into CFTC System Safeguards (17 CFR 37, 38, 39, 49)
48.7%

19 of 39 CFTC System Safeguards (17 CFR 37, 38, 39, 49) controls are evidenced by work you have already done for NIST SP 800-161 Rev 1. 20 are genuine gaps.

58.3%CFTC System Safeguards: Business Continuity and Disaster Recovery
50%CFTC System Safeguards: Cybersecurity Testing
30%CFTC System Safeguards: Risk Analysis and Oversight Program
50%CFTC System Safeguards: Notification, Records and Remediation
Machine verified. Claude Code on the Max plan, judged in context, signed off 2026-08-19. 101 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)(5), 38.1051(a)(5), 39.18(b)(2)(iv), 49.24(b)(5) Systems Operations Category

Establishes the baseline configuration against which later changes are detected.

Grounded in 161R1-CM-2 Baseline Configuration. 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 19 evidenced controls and 20 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 SP 800-161 Rev 1
Not published yet

This direction has not been through crosswalk review and sign off, so no coverage figure is published for it. Reporting an unreviewed number would be worse than reporting none. It can be built to order at the same price as a pair that is already on the shelf.

If the two frameworks turn out to have too little in common for a crosswalk to help you, we say so and refund it rather than send a number worth nothing.

NIST SP 800-161 Rev 1 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 29% in the header counts how many NIST SP 800-161 Rev 1 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.

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What are the key differences between NIST SP 800-161 Rev 1 and CFTC System Safeguards (17 CFR 37, 38, 39, 49)?

NIST SP 800-161 Rev 1 has 191 controls across its framework, while CFTC System Safeguards (17 CFR 37, 38, 39, 49) covers 39 controls. Direct mapping analysis identifies 55 overlapping controls (29% coverage). The frameworks diverge most significantly in C-SCRM Family: Program Management, where 24 NIST SP 800-161 Rev 1 controls have no direct CFTC System Safeguards (17 CFR 37, 38, 39, 49) equivalent.

How many controls map between NIST SP 800-161 Rev 1 and CFTC System Safeguards (17 CFR 37, 38, 39, 49)?

Of 191 total NIST SP 800-161 Rev 1 controls, 55 map directly to CFTC System Safeguards (17 CFR 37, 38, 39, 49) controls, representing 29% coverage. The remaining 136 controls represent compliance gaps requiring additional documentation or compensating controls to satisfy both frameworks simultaneously.

What are the compliance gaps when mapping NIST SP 800-161 Rev 1 to CFTC System Safeguards (17 CFR 37, 38, 39, 49)?

136 NIST SP 800-161 Rev 1 controls have no direct equivalent in CFTC System Safeguards (17 CFR 37, 38, 39, 49). The highest concentration of gaps is in C-SCRM Family: Program Management with 24 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 SP 800-161 Rev 1 and CFTC System Safeguards (17 CFR 37, 38, 39, 49)?

The domain with the highest gap count is C-SCRM Family: Program Management (24 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.