TheArtOfService
CFTC System Safeguards (17 CFR 37, 38, 39, 49)PCI DSS 4.0

CFTC System Safeguards (17 CFR 37, 38, 39, 49) covers 9.2% of PCI DSS 4.0

23 of the 249 controls in PCI DSS 4.0 are already satisfied by evidence you collected for CFTC System Safeguards (17 CFR 37, 38, 39, 49). 226 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.

9.2%
of the target already covered
23
controls evidenced
226
genuine gaps
0
claims rejected in review

This number is directional. It says how much of PCI DSS 4.0 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.

Req 11: Test Security Regularly6 of 21 evidenced, 15 to do
Req 6: Secure Systems and Software5 of 19 evidenced, 14 to do
Req 12: Information Security Policies8 of 37 evidenced, 29 to do
Req 9: Restrict Physical Access3 of 26 evidenced, 23 to do
Req 2: Secure Configurations1 of 11 evidenced, 10 to do
Req 1: Network Security Controls0 of 19 evidenced, 19 to do
Req 10: Logging and Monitoring0 of 27 evidenced, 27 to do
Req 3: Protect Stored Account Data0 of 29 evidenced, 29 to do
Req 4: Protect Cardholder Data in Transit0 of 6 evidenced, 6 to do
Req 5: Anti-Malware0 of 13 evidenced, 13 to do
Req 7: Restrict Access by Need to Know0 of 12 evidenced, 12 to do
Req 8: Identify and Authenticate Users0 of 29 evidenced, 29 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(h), 38.1051(h), 39.18(e)(1)(i), 49.24(j)11.1.1argued against and upheld
Testing policy documented

Requires regular periodic objective testing and review covering all required test types.

37.1401(h)(2), 38.1051(h)(2), 39.18(e)(2), 49.24(j)(2)11.3.1argued against and upheld
Internal vulnerability scans quarterly

Requires vulnerability testing no less frequently than quarterly for covered entities.

37.1401(h)(3), 38.1051(h)(3), 39.18(e)(3), 49.24(j)(3)11.4.1argued against and upheld
Penetration testing methodology defined

Requires penetration testing of defined scope at a risk determined frequency.

37.1401(h)(4), 38.1051(h)(4), 39.18(e)(4), 49.24(j)(4)11.4.2argued against and upheld
Internal penetration testing annually

Requires annual internal penetration testing by independent or non operating personnel.

37.1401(h)(3), 38.1051(h)(3), 39.18(e)(3), 49.24(j)(3)11.4.3argued against and upheld
External penetration testing annually

Requires annual external penetration testing by independent contractors for covered entities.

37.1401(m), 38.1051(m), 39.18(e)(10), 49.24(n)11.4.4argued against and upheld
Pen test findings remediated

Findings from required testing must be documented and remediated in a timely manner.

37.1401(h)(6), 38.1051(h)(6), 39.18(e)(6), 49.24(j)(6)12.10.1argued against and upheld
Incident response plan

Requires a written security incident response plan with defined content and escalation.

37.1401(h)(6), 38.1051(h)(6), 39.18(e)(6), 49.24(j)(6)12.10.2argued against and upheld
IRP reviewed and tested annually

Incident response plan must be tested at least annually for covered entities.

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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