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

PCI DSS 4.0 covers 30.8% of CFTC System Safeguards (17 CFR 37, 38, 39, 49)

12 of the 39 controls in CFTC System Safeguards (17 CFR 37, 38, 39, 49) are already satisfied by evidence you collected for PCI DSS 4.0. 27 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.

30.8%

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 PCI DSS 4.0 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.

60 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: Cybersecurity Testing6 of 10 evidenced, 4 to do

CFTC System Safeguards: Risk Analysis and Oversight Program4 of 10 evidenced, 6 to do

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

CFTC System Safeguards: Business Continuity and Disaster Recovery1 of 12 evidenced, 11 to do

CFTC System Safeguards: Registrant Specific Requirements0 of 3 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.

12.7.137.1401(a)(2), 38.1051(a)(2), 39.18(b)(2)(i), 49.24(b)(2)argued against and upheld

Information Security Category

Screening personnel before access is the personnel security and screening element.

10.4.137.1401(a)(2), 38.1051(a)(2), 39.18(b)(2)(i), 49.24(b)(2)argued against and upheld

Information Security Category

Daily review of security event and critical system logs is the log maintenance and analysis element.

8.3.137.1401(a)(2), 38.1051(a)(2), 39.18(b)(2)(i), 49.24(b)(2)argued against and upheld

Information Security Category

Authenticating all user and administrator access is the identification and authentication element.

7.2.237.1401(a)(2), 38.1051(a)(2), 39.18(b)(2)(i), 49.24(b)(2)argued against and upheld

Information Security Category

Access assigned by job classification and least privilege is the least privilege element.

12.5.137.1401(a)(5), 38.1051(a)(5), 39.18(b)(2)(iv), 49.24(b)(5)argued against and upheld

Systems Operations Category

A current inventory of system components is the inventory element.

6.5.137.1401(a)(5), 38.1051(a)(5), 39.18(b)(2)(iv), 49.24(b)(5)argued against and upheld

Systems Operations Category

Established change control procedures for production changes is the configuration change element.

6.3.337.1401(a)(5), 38.1051(a)(5), 39.18(b)(2)(iv), 49.24(b)(5)argued against and upheld

Systems Operations Category

Installing applicable security patches within defined timeframes is the patch management element.

2.2.137.1401(a)(5), 38.1051(a)(5), 39.18(b)(2)(iv), 49.24(b)(5)argued against and upheld

Systems Operations Category

Configuration standards covering all system components is the baseline configuration element.

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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