CFTC System Safeguards (17 CFR 37, 38, 39, 49)
CFTC System Safeguards: Cybersecurity Testing

CFTC System Safeguards (17 CFR 37, 38, 39, 49) CFTC-SS-18: Independence of Testers

Perform the required testing either by engaging independent contractors or by using employees who are not responsible for the development or operation of the systems or capabilities being tested, and engage independent contractors where the rules require it.

Maintained by Gerard BlokdykVerified against the published standard Control text last updated

What else in your programme already covers this

This control maps to 23 controls across 14 other frameworks. If you already hold one of them, the evidence you collected for it is the starting point here rather than new work.

FedRAMP High · 3 controls

  • CA-2 Control Assessments
  • CA-2(1) Independent Assessors
  • CA-8(1) Penetration Testing | Independent Penetration Testing Agent or Team (CA-8(1))

FedRAMP Moderate · 3 controls

  • CA-2 Control Assessments
  • CA-2(1) Independent Assessors
  • CA-8(1) Penetration Testing | Independent Penetration Testing Agent or Team (CA-8(1))

PCI DSS 4.0 · 3 controls

  • 11.3.2 11.3.2 Quarterly ASV external vulnerability scans
  • 11.4.1 11.4.1 Penetration testing methodology defined and implemented
  • 6.2.3.1 6.2.3.1 Manual code review independence and approval
  • NIST-CSF-ID.IM-02 Improvements are identified from security tests and exercises, including those done in coordination with suppliers and relevant third parties
  • NIST-CSF-ID.RA-09 The authenticity and integrity of hardware and software are assessed prior to acquisition and use

NIST SP 800-161 Rev 1 · 2 controls

  • CPS230-49 Internal Audit Review of Proposed Critical Operation Outsourcing

C5 (Germany) · 1 control

DORA · 1 control

  • DORA-Art.27 Requirements for testers for the carrying out of TLPT

ISO 22301:2019 · 1 control

  • 9.2 Internal audit

ISO 27001:2022 · 1 control

  • 5.35 Independent review of information security

ISO 27002:2022 · 1 control

  • 5.35 Independent review of information security

SOC 2 · 1 control

  • SOC2-CC4.1 CC4.1 Ongoing and separate evaluations of control (COSO principle 16)

Every mapping shown was judged rather than inferred from wording similarity, and the ones that failed review are published too. See the coverage reports and what was rejected.

Other controls in CFTC System Safeguards: Cybersecurity Testing

You are reading one control. How much of CFTC System Safeguards (17 CFR 37, 38, 39, 49) have you already done?

CFTC System Safeguards (17 CFR 37, 38, 39, 49) CFTC-SS-18 is one control. If you already hold one of the frameworks below, a reviewed crosswalk already says how much of CFTC System Safeguards (17 CFR 37, 38, 39, 49) your existing evidence covers. Hold NIST Cybersecurity Framework 2.0 and 28 of 39 CFTC System Safeguards (17 CFR 37, 38, 39, 49) controls already carry evidence.

Each report names every control your existing framework evidences, every one it does not, the reasoning behind each claim, and the claims that were argued against and rejected. 5 were rejected on the NIST Cybersecurity Framework 2.0 pair alone.

Query this from an agent

The graph holds this control, the 23 it maps to, and the evidence behind each claim, over MCP and REST.