CFTC System Safeguards (17 CFR 37, 38, 39, 49) vs FedRAMP Moderate

What is the difference between CFTC System Safeguards (17 CFR 37, 38, 39, 49) and FedRAMP Moderate?

CFTC System Safeguards (17 CFR 37, 38, 39, 49) is a risk management framework applying in the United States (CFTC), with 39 controls across 5 domains. FedRAMP Moderate is a cloud security framework applying in the United States, with 323 controls across 18 domains. They govern different subjects, so the overlap is limited to the governance requirements they share. The mapping below shows where that is.

CFTC System Safeguards (17 CFR 37, 38, 39, 49)39 controls

FedRAMP Moderate323 controls

Measured coverage between these frameworks

We map controls between these two frameworks in a knowledge graph and have a person review every mapping before it is published. Below is what that review found. The figures are read live from the graph, not written by hand.

CFTC System Safeguards (17 CFR 37, 38, 39, 49) into FedRAMP Moderate

9.9%

32 of 323 FedRAMP Moderate controls carry evidence from CFTC System Safeguards (17 CFR 37, 38, 39, 49), leaving 291 to satisfy separately.

82 candidate mappings were examined and 1 were rejected on review, signed off 2026-08-19.

Read the full crosswalk, including every rejected mapping →

FedRAMP Moderate into CFTC System Safeguards (17 CFR 37, 38, 39, 49)

69.2%

27 of 39 CFTC System Safeguards (17 CFR 37, 38, 39, 49) controls carry evidence from FedRAMP Moderate, leaving 12 to satisfy separately.

88 candidate mappings were examined and 0 were rejected on review, signed off 2026-08-19.

Read the full crosswalk, including every rejected mapping →

Coverage is directional. Mapping A into B is a different measurement from B into A, because the two standards do not carry the same depth on the same subjects.

Questions people ask about CFTC System Safeguards (17 CFR 37, 38, 39, 49) and FedRAMP Moderate

What is the difference between CFTC System Safeguards (17 CFR 37, 38, 39, 49) and FedRAMP Moderate?

CFTC System Safeguards (17 CFR 37, 38, 39, 49) has 39 controls while FedRAMP Moderate has 323 controls. Both frameworks address compliance requirements but differ in scope, focus, and applicability. Use our platform to explore the exact control-to-control mappings.

Do I need both CFTC System Safeguards (17 CFR 37, 38, 39, 49) and FedRAMP Moderate?

Whether you need both depends on your industry, regulatory requirements, and customer expectations. Many organizations implement multiple frameworks simultaneously. Our compliance platform helps you map controls between CFTC System Safeguards (17 CFR 37, 38, 39, 49) and FedRAMP Moderate so you can identify shared requirements and avoid duplicate effort.

How do CFTC System Safeguards (17 CFR 37, 38, 39, 49) and FedRAMP Moderate controls map to each other?

Our platform maps controls between CFTC System Safeguards (17 CFR 37, 38, 39, 49) and FedRAMP Moderate at a granular level. Each mapping shows whether controls are fully aligned, partially aligned, or represent gaps. This helps you prioritize implementation when pursuing both frameworks.

Which framework should I implement first, CFTC System Safeguards (17 CFR 37, 38, 39, 49) or FedRAMP Moderate?

The best starting point depends on your specific regulatory requirements, industry, and customer demands. Consider which framework is most urgently required by your stakeholders or regulators. Use our free compliance platform to run a gap analysis and determine the optimal implementation sequence.

Each framework on its own