TheArtOfService
CFTC System Safeguards (17 CFR 37, 38, 39, 49)CIS Controls v8

CFTC System Safeguards (17 CFR 37, 38, 39, 49) covers 17% of CIS Controls v8

26 of the 153 controls in CIS Controls v8 are already satisfied by evidence you collected for CFTC System Safeguards (17 CFR 37, 38, 39, 49). 127 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.

17%
of the target already covered
26
controls evidenced
127
genuine gaps
0
claims rejected in review

This number is directional. It says how much of CIS Controls v8 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.

51 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.

CIS Control 18: Penetration Testing4 of 5 evidenced, 1 to do
CIS Control 7: Continuous Vulnerability Management5 of 7 evidenced, 2 to do
CIS Control 11: Data Recovery3 of 5 evidenced, 2 to do
CIS Control 17: Incident Response Management4 of 9 evidenced, 5 to do
CIS Control 15: Service Provider Management2 of 7 evidenced, 5 to do
CIS Control 1: Inventory and Control of Enterprise Assets1 of 5 evidenced, 4 to do
CIS Control 16: Application Software Security2 of 14 evidenced, 12 to do
CIS Control 2: Inventory and Control of Software Assets1 of 7 evidenced, 6 to do
CIS Control 6: Access Control Management1 of 8 evidenced, 7 to do
CIS Control 14: Security Awareness and Skills Training1 of 9 evidenced, 8 to do
CIS Control 4: Secure Configuration of Enterprise Assets and Software1 of 12 evidenced, 11 to do
CIS Control 8: Audit Log Management1 of 12 evidenced, 11 to do
CIS Control 10: Malware Defenses0 of 7 evidenced, 7 to do
CIS Control 12: Network Infrastructure Management0 of 8 evidenced, 8 to do
CIS Control 13: Network Monitoring and Defense0 of 11 evidenced, 11 to do
CIS Control 3: Data Protection0 of 14 evidenced, 14 to do
CIS Control 5: Account Management0 of 6 evidenced, 6 to do
CIS Control 9: Email and Web Browser Protections0 of 7 evidenced, 7 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)CIS-1.1argued against and upheld
Establish and Maintain Detailed Enterprise Asset Inventory

Systems operations requires inventory of authorised and unauthorised devices.

37.1401(c), 38.1051(c), 39.18(c)(1), 49.24(a)(2) and 49.24(d)CIS-11.1argued against and upheld
Establish and Maintain a Data Recovery Process

Requires a recovery plan, emergency procedures and backup facilities enabling timely recovery.

49.24(e)(3), 37.1401(j), 38.1051(j), 17 CFR 40.9CIS-11.4argued against and upheld
Establish and Maintain an Isolated Instance of Recovery Data

Critical entities must hold backup resources outside the area and off shared infrastructure.

37.1401(h), 38.1051(h), 39.18(e)(1)(ii), 49.24(a)(3), 49.24(e)(4) and 49.24(j)CIS-11.5argued against and upheld
Test Data Recovery

Requires periodic testing that backup resources are sufficient, with results retained.

37.1401(a)(2), 38.1051(a)(2), 39.18(b)(2)(i), 49.24(b)(2)CIS-14.1argued against and upheld
Establish and Maintain a Security Awareness Program

Expressly requires security awareness training within the information security category.

39.18(d)(1) and (2)CIS-15.2argued against and upheld
Establish and Maintain a Service Provider Management Policy

Outsourcing retains complete responsibility and requires expert supervision of providers.

39.18(d)(3)CIS-15.5argued against and upheld
Assess Service Providers

Required testing must cover outsourced resources with testers independent of the provider.

37.1401(a)(6), 38.1051(a)(6), 39.18(b)(2)(v), 49.24(b)(6)CIS-16.1argued against and upheld
Establish and Maintain a Secure Application Development Process

Systems development requires requirements, testing, change approvals and secure coding practices.

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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