Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1CFTC System Safeguards (17 CFR 37, 38, 39, 49)

Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1 covers 61.5% of CFTC System Safeguards (17 CFR 37, 38, 39, 49)

24 of the 39 controls in CFTC System Safeguards (17 CFR 37, 38, 39, 49) are already satisfied by evidence you collected for Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1. 15 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.

61.5%

of the target already covered

controls evidenced

genuine gaps

claims rejected in review

This number is directional. It says how much of CFTC System Safeguards (17 CFR 37, 38, 39, 49) your Cloud Security Alliance Cloud Controls Matrix (CCM) v4.0.1 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.

85 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.

CFTC System Safeguards: Risk Analysis and Oversight Program8 of 10 evidenced, 2 to do

CFTC System Safeguards: Cybersecurity Testing8 of 10 evidenced, 2 to do

CFTC System Safeguards: Business Continuity and Disaster Recovery6 of 12 evidenced, 6 to do

CFTC System Safeguards: Registrant Specific Requirements1 of 3 evidenced, 2 to do

CFTC System Safeguards: Notification, Records and Remediation1 of 4 evidenced, 3 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.

CCM-A&A-0637.1401(a)(1), 38.1051(a)(1), 49.24(b)(1)argued against and upheld

Enterprise Risk Management and Governance Category

Risk prioritised corrective action plans with owners and due dates are remediation of deficiencies.

CCM-A&A-0537.1401(a)(1), 38.1051(a)(1), 49.24(b)(1)argued against and upheld

Enterprise Risk Management and Governance Category

Defined audit management process covering control assessment and conclusions is the technology audit element.

CCM-GRC-0237.1401(a)(1), 38.1051(a)(1), 49.24(b)(1)argued against and upheld

Enterprise Risk Management and Governance Category

Documented enterprise risk programme assessing, owning, treating and accepting technology risk.

CCM-GRC-0137.1401(a)(1), 38.1051(a)(1), 49.24(b)(1)argued against and upheld

Enterprise Risk Management and Governance Category

Governance policies with visible leadership sponsorship deliver board and management oversight.

CCM-LOG-0537.1401(a)(2), 38.1051(a)(2), 39.18(b)(2)(i), 49.24(b)(2)argued against and upheld

Information Security Category

Reviewing audit logs for anomalies and acting within a set time is audit log maintenance and analysis.

CCM-IAM-0537.1401(a)(2), 38.1051(a)(2), 39.18(b)(2)(i), 49.24(b)(2)argued against and upheld

Information Security Category

Least privilege access grants are named verbatim in the category.

CCM-IAM-0437.1401(a)(2), 38.1051(a)(2), 39.18(b)(2)(i), 49.24(b)(2)argued against and upheld

Information Security Category

Separation of duties across identities is named verbatim in the category.

CCM-GRC-0537.1401(a)(2), 38.1051(a)(2), 39.18(b)(2)(i), 49.24(b)(2)argued against and upheld

Information Security Category

An information security programme spanning all control domains is what the category requires.

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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