CFTC System Safeguards (17 CFR 37, 38, 39, 49)ISO 27001:2022

CFTC System Safeguards (17 CFR 37, 38, 39, 49) covers 24.7% of ISO 27001:2022

23 of the 93 controls in ISO 27001:2022 are already satisfied by evidence you collected for CFTC System Safeguards (17 CFR 37, 38, 39, 49). 70 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.

24.7%

of the target already covered

controls evidenced

genuine gaps

claims rejected in review

This number is directional. It says how much of ISO 27001:2022 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.

64 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.

Organizational controls10 of 37 evidenced, 27 to do

People controls2 of 8 evidenced, 6 to do

Technological controls8 of 34 evidenced, 26 to do

Physical controls3 of 14 evidenced, 11 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)(2), 38.1051(a)(2), 39.18(b)(2)(i), 49.24(b)(2)5.15argued against and upheld

Access control

Requires access to systems and data with least privilege and account monitoring.

39.18(d)(1) and (2)5.19argued against and upheld

Information security in supplier relationships

Outsourcing retains complete responsibility and requires expert supervision of the provider.

37.1401(h)(6), 38.1051(h)(6), 39.18(e)(6), 49.24(j)(6)5.24argued against and upheld

Information security incident management planning and preparation

Written incident response plan defines roles, reporting, communication and escalation before an incident.

37.1401(h)(6), 38.1051(h)(6), 39.18(e)(6), 49.24(j)(6)5.25argued against and upheld

Assessment and decision on information security events

Plan must cover definition and classification of security incidents.

37.1401(h)(6), 38.1051(h)(6), 39.18(e)(6), 49.24(j)(6)5.26argued against and upheld

Response to information security incidents

Plan sets response procedures and must be tested at least annually for covered entities.

37.1401(h), 38.1051(h), 39.18(e)(1)(ii), 49.24(a)(3), 49.24(e)(4) and 49.24(j)5.30argued against and upheld

ICT readiness for business continuity

Requires regular periodic testing of recovery capabilities against the recovery requirements.

37.1401(c), 38.1051(c), 39.18(c)(1), 49.24(a)(2) and 49.24(d)5.30argued against and upheld

ICT readiness for business continuity

Requires a business continuity and disaster recovery plan with backup facilities and technological resources.

37.1401(h)(2)(iii), (3)(ii) and (iii), (4)(ii), (5)(ii) and (iii), (7)(ii); 38.1051(h) equivalents; 39.18(e) equivalents; 49.24(j) equivalents5.35argued against and upheld

Independent review of information security

Testing must be by independent contractors or employees not responsible for the systems tested.

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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