TheArtOfService
CFTC System Safeguards (17 CFR 37, 38, 39, 49)ISO 22301:2019

CFTC System Safeguards (17 CFR 37, 38, 39, 49) covers 38.6% of ISO 22301:2019

22 of the 57 controls in ISO 22301:2019 are already satisfied by evidence you collected for CFTC System Safeguards (17 CFR 37, 38, 39, 49). 35 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.

38.6%
of the target already covered
22
controls evidenced
35
genuine gaps
0
claims rejected in review

This number is directional. It says how much of ISO 22301:2019 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.

41 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.

Operation, ISO 22301:201912 of 19 evidenced, 7 to do
Performance evaluation, ISO 22301:20194 of 8 evidenced, 4 to do
Improvement, ISO 22301:20191 of 2 evidenced, 1 to do
Planning, ISO 22301:20192 of 7 evidenced, 5 to do
Support, ISO 22301:20192 of 8 evidenced, 6 to do
Leadership, ISO 22301:20191 of 5 evidenced, 4 to do
Context of the organization, ISO 22301:20190 of 8 evidenced, 8 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(m), 38.1051(m), 39.18(e)(10), 49.24(n)10.1argued against and upheld
Nonconformity and corrective action

Requires deficiencies be documented, analysed and remediated in a timely manner.

37.1401(l), 38.1051(l), 39.18(e)(9), 49.24(m)5.1argued against and upheld
Leadership and commitment

Top management and the board must receive, review and act on system safeguards results.

37.1401(c) and (d), 38.1051(c) and (d), 39.18(c)(2), 49.24(f)6.2.1argued against and upheld
Establishing business continuity objectives

Sets a measurable continuity objective of resuming obligations by the next business day.

37.1401(c) and (d), 38.1051(c) and (d), 39.18(c)(2), 49.24(f)6.2.2argued against and upheld
Determining business continuity objectives

Objective is defined with a time frame and tied to fulfilment of specific obligations.

39.18(b)(4)7.1argued against and upheld
Resources

Requires establishing, maintaining and periodically verifying resources sufficient for all obligations.

37.1401(g), 38.1051(g), 39.18(f), 49.24(i)7.5argued against and upheld
Documented information

Current recovery plans, procedures and assessments must be documented and produced on request.

37.1401(a), 38.1051(a), 39.18(b)(1), 49.24(a)(1) and 49.24(b)8.1argued against and upheld
Operational planning and control

Requires a maintained programme controlling operations and automated systems against operational risk.

37.1401(h)(7), 38.1051(h)(7), 39.18(e)(7), 49.24(j)(7)8.2argued against and upheld
Business impact analysis and risk assessment

Requires an annual written assessment of threats, vulnerabilities and prioritised risks to operations.

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.

Buy this crosswalk