TheArtOfService
CFTC System Safeguards (17 CFR 37, 38, 39, 49)Azure Security Benchmark

CFTC System Safeguards (17 CFR 37, 38, 39, 49) covers 22.4% of Azure Security Benchmark

19 of the 85 controls in Azure Security Benchmark are already satisfied by evidence you collected for CFTC System Safeguards (17 CFR 37, 38, 39, 49). 66 are genuine gaps. Every claim below was judged against both control sets and then argued against; the ones that did not survive are published further down with the reason each failed.

22.4%
of the target already covered
19
controls evidenced
66
genuine gaps
0
claims rejected in review

This number is directional. It says how much of Azure Security Benchmark your CFTC System Safeguards (17 CFR 37, 38, 39, 49) evidence satisfies. The reverse pair is a different number, often very different, because a security standard has enormous depth for access control and almost none for lawful basis or data subject rights.

46 candidate mappings were examined and 0 were removed. Signed off 2026-08-19, review level machine verified. 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.

Where the gaps are

Coverage is never evenly spread. A source standard usually satisfies one part of a target almost completely and barely touches another, and which part is which is the thing worth knowing before you plan the work.

Posture and Vulnerability Management5 of 7 evidenced, 2 to do
Governance and Strategy5 of 10 evidenced, 5 to do
Backup and Recovery2 of 4 evidenced, 2 to do
Incident Response3 of 7 evidenced, 4 to do
Asset Management1 of 5 evidenced, 4 to do
DevOps Security1 of 7 evidenced, 6 to do
Logging and Threat Detection1 of 7 evidenced, 6 to do
Privileged Access1 of 8 evidenced, 7 to do
Data Protection0 of 8 evidenced, 8 to do
Endpoint Security0 of 3 evidenced, 3 to do
Identity Management0 of 9 evidenced, 9 to do
Network Security0 of 10 evidenced, 10 to do

Theme level, not control level, deliberately. The per-control list of what is evidenced and what is a gap is the report itself, so publishing it here would be publishing the thing being sold.

Claims that held

A sample. Each one names the control whose evidence does the work, the control it satisfies, and why.

37.1401(a)(5), 38.1051(a)(5), 39.18(b)(2)(iv), 49.24(b)(5)ASB v3 AM-1argued against and upheld
Track asset inventory and their risks

Requires inventory of authorised and unauthorised devices and software.

37.1401(c), 38.1051(c), 39.18(c)(1), 49.24(a)(2) and 49.24(d)ASB v3 BR-1argued against and upheld
Ensure regular automated backups

Requires backup facilities and resources sufficient for timely recovery.

37.1401(h), 38.1051(h), 39.18(e)(1)(ii), 49.24(a)(3), 49.24(e)(4) and 49.24(j)ASB v3 BR-4argued against and upheld
Regularly test backup

Requires periodic testing that backup resources meet the recovery requirements.

37.1401(a)(6), 38.1051(a)(6), 39.18(b)(2)(v), 49.24(b)(6)ASB v3 DS-6argued against and upheld
Enforce security of workload throughout DevOps lifecycle

Requires requirements, testing, change approvals and secure coding across development.

37.1401(a)(1), 38.1051(a)(1), 49.24(b)(1)ASB v3 GS-1argued against and upheld
Align organization roles, responsibilities and accountabilities

Requires board and management oversight roles for security and technology risk.

37.1401(a)(2), 38.1051(a)(2), 39.18(b)(2)(i), 49.24(b)(2)ASB v3 GS-2argued against and upheld
Define and implement enterprise segmentation/separation of duties strategy

Expressly requires separation of duties and least privilege across systems and data.

37.1401(a), 38.1051(a), 39.18(b)(1), 49.24(a)(1) and 49.24(b)ASB v3 GS-5argued against and upheld
Define and implement security posture management strategy

Requires a maintained programme of risk analysis and oversight over systems and controls.

37.1401(h)(6), 38.1051(h)(6), 39.18(e)(6), 49.24(j)(6)ASB v3 GS-7argued against and upheld
Define and implement logging, threat detection and incident response strategy

Requires a written incident response plan with reporting, communication and escalation.

Claims that did not hold

Nothing proposed for this pair was rejected in review. That is unusual and worth knowing rather than hiding: it means the candidate set was small and every candidate held.

The full report

Everything above is a sample. The report is every evidenced control and every gap, with the reasoning and the source document behind each one, in a form you can hand to an assessor. $299, emailed immediately.

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