TheArtOfService
FedRAMP ModerateCFTC System Safeguards (17 CFR 37, 38, 39, 49)

FedRAMP Moderate covers 69.2% of CFTC System Safeguards (17 CFR 37, 38, 39, 49)

27 of the 39 controls in CFTC System Safeguards (17 CFR 37, 38, 39, 49) are already satisfied by evidence you collected for FedRAMP Moderate. 12 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.

69.2%
of the target already covered
27
controls evidenced
12
genuine gaps
0
claims rejected in review

This number is directional. It says how much of CFTC System Safeguards (17 CFR 37, 38, 39, 49) your FedRAMP Moderate 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.

88 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 Recovery9 of 12 evidenced, 3 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.

RA-337.1401(a)(1), 38.1051(a)(1), 49.24(b)(1)argued against and upheld
Enterprise Risk Management and Governance Category

Annual documented risk assessment identifies and analyses security and technology risk.

CA-7(4)37.1401(a)(1), 38.1051(a)(1), 49.24(b)(1)argued against and upheld
Enterprise Risk Management and Governance Category

Risk monitoring covering effectiveness, compliance and change is built into continuous monitoring.

CA-237.1401(a)(1), 38.1051(a)(1), 49.24(b)(1)argued against and upheld
Enterprise Risk Management and Governance Category

Annual third party control assessment is the technology audit and controls assessment.

CA-537.1401(a)(1), 38.1051(a)(1), 49.24(b)(1)argued against and upheld
Enterprise Risk Management and Governance Category

Plan of action and milestones drives remediation of identified deficiencies.

RA-537.1401(a)(2), 38.1051(a)(2), 39.18(b)(2)(i), 49.24(b)(2)argued against and upheld
Information Security Category

Monthly vulnerability scanning with defined remediation windows.

AU-637.1401(a)(2), 38.1051(a)(2), 39.18(b)(2)(i), 49.24(b)(2)argued against and upheld
Information Security Category

Audit records reviewed and analysed weekly with findings reported.

AC-637.1401(a)(2), 38.1051(a)(2), 39.18(b)(2)(i), 49.24(b)(2)argued against and upheld
Information Security Category

Least privilege limits access to systems and data to what duties require.

AC-537.1401(a)(2), 38.1051(a)(2), 39.18(b)(2)(i), 49.24(b)(2)argued against and upheld
Information Security Category

Duties requiring separation are identified and access authorizations set accordingly.

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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