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.
What this leaves you to do
ISO 22301:2019 has 57 controls. Holding CFTC System Safeguards (17 CFR 37, 38, 39, 49) already evidences 22 of them, so the work in front of you is 35 controls, not 57, which is 61% of the standard rather than all of it.
That is the whole claim. Every number in that sentence comes from the two counts above it and can be re-derived from the free tools without taking our word for any of it.
In money, using only our numbers. The full report is $299 and names 22 controls of ISO 22301:2019 you do not have to implement again, which is $13.59 per control identified. That arithmetic uses our price and our count and assumes nothing about you.
In your hours, using your assumption. We do not know what a control costs you to implement, so pick the column that looks like your organisation. These are your figures, not our claim.
| If a control takes you | 4 hours | 8 hours | 16 hours |
|---|---|---|---|
| the 22 already evidenced are | 88 hours | 176 hours | 352 hours |
| and the 35 remaining are | 140 hours | 280 hours | 560 hours |
Multiply by your own rate. We publish no rate because we have not measured yours, and a number built on an invented rate is the kind of claim this platform exists to argue against.
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.
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.
Requires deficiencies be documented, analysed and remediated in a timely manner.
Top management and the board must receive, review and act on system safeguards results.
Sets a measurable continuity objective of resuming obligations by the next business day.
Objective is defined with a time frame and tied to fulfilment of specific obligations.
Requires establishing, maintaining and periodically verifying resources sufficient for all obligations.
Current recovery plans, procedures and assessments must be documented and produced on request.
Requires a maintained programme controlling operations and automated systems against operational risk.
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.
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