Crosswalk pair
FedRAMP Consolidated Rules and SOX (Sarbanes-Oxley) Section 404, control by control
6 canonical controls in Keel’s library satisfy clauses of both FedRAMP Consolidated Rules and SOX (Sarbanes-Oxley) Section 404. Implement each once, attach the evidence once, and it counts toward each standard. The overlap is the work you don’t repeat.
The overlap
What the two libraries have in common
Every figure here counts canonical controls in Keel’s library, not clauses of either standard. Each standard’s own authored count is on its framework page.
6
Controls that satisfy both
Canonical controls that crosswalk to at least one clause of each.
23
In Keel’s library for FedRAMP Consolidated Rules
26% of them also map to SOX (Sarbanes-Oxley) Section 404.
32
In Keel’s library for SOX (Sarbanes-Oxley) Section 404
19% of them also map to FedRAMP Consolidated Rules.
23
Evidence artifacts expected
Across the shared controls, from Keel’s evidence guidance. Gathered once.
-
FedRAMP Consolidated Rules 26%
6 controls of 23 in Keel’s library for FedRAMP Consolidated Rules also map to SOX (Sarbanes-Oxley) Section 404.
-
SOX (Sarbanes-Oxley) Section 404 19%
6 controls of 32 in Keel’s library for SOX (Sarbanes-Oxley) Section 404 also map to FedRAMP Consolidated Rules.
The mapping
Controls that satisfy both
Each row is one control in Keel’s library and the clauses it answers on each side. Do the work once; both columns are then evidenced by the same artifacts.
| Canonical control | FedRAMP Consolidated Rules clauses | SOX (Sarbanes-Oxley) Section 404 clauses |
|---|---|---|
| Document & records control Documented information is created, approved, versioned, and controlled; records are retained and protected for a defined minimum period - measured from the document’s creation OR from the date it last was in effect, whichever is later, so a policy that stayed in force for years does not start its clock on the day it was written - and are available to the people who have to act on the procedures they describe. Documentation is reviewed on a schedule and updated when an operational, environmental or legal change has made the current version wrong. A change forced by law is documented and put into effect promptly, and where that legal change materially affects what the organization has published to individuals about how it handles their data, THAT NOTICE IS REVISED TOO, as part of the same prompt action rather than as a separate task left to whoever owns the notice. Any other change may be made at any time provided the revised version still complies and IS DOCUMENTED BEFORE THE CHANGE TAKES EFFECT - the record precedes the effective date, so a routine that documents changes in arrears does not discharge this. Records are protected for as long as they are kept, and against more than deletion: against loss, against destruction, against falsification, against being read by somebody with no entitlement to them, and against being released outside the organization without authority. The protection applied to a class of record is decided from the requirements attached to it - what the law, the regulator or the contract demands of that record type, and what it would cost if it were lost or altered - rather than from where it happens to be stored. Records are held so that a change to one is attributable and detectable rather than silent, the storage medium and format are chosen to remain readable for the whole retention period and the information is migrated before either stops being so, and the ability to retrieve a record intact is exercised rather than assumed. What the set of documented information consists of is itself a decision rather than an accumulation: it comprises the documented information the standard the system is built against explicitly requires, plus whatever else the organization determines is necessary for the system to be effective - and the second half is decided against the size of the organization and the kind of activity, product and service it deals in, the complexity of its processes, and the competence of its people, so a small organization is not judged against a large one’s binder and a large one cannot claim a small one’s. | SCG-ENH-VRH | P12 |
| Encryption in transit & at rest Strong cryptography protects sensitive data in transit over public networks and at rest in storage. The mechanisms are chosen to do two things and are judged against both: prevent unauthorized disclosure of the information, and prevent or detect unauthorized change to it - in transit, so a message altered between sender and receiver is caught rather than delivered, and at rest, so a stored record cannot be modified undetectably by somebody with access to the storage but not to the key. Which information is protected at rest, and on which system components, is decided and recorded rather than left to whatever the platform encrypts by default. The scope named explicitly reaches the end-user device as well as the server: data held on laptops, desktops and other end-user devices that carry sensitive information is encrypted at the device or volume level, so a device that leaves the building is an object somebody lost rather than a disclosure. And data in transit is encrypted wherever it is sensitive, not only where it crosses a public network - a session between two internal systems is protected on the same terms when what it carries warrants it. Where a law, a regulation or a contract requires the cryptography to be VALIDATED rather than merely strong, the organization uses a cryptographic module that carries the validation that instrument names, and it confirms that validation against the specific module, version and operating mode actually deployed rather than inferring it from the product’s name - because a validated module run outside the configuration it was validated in is not a validated module, and the certificate that proves the point is held as evidence rather than assumed to exist. | CMU-CSO-CAT, CMU-CSO-UVM | P11 |
| Asset inventory An inventory of hardware, software, and information assets with assigned owners, in which the movement of equipment and removable media into, out of, and within the organization’s premises is recorded against the person responsible for it. The record is maintained by the acts that change it rather than by a periodic sweep: installing a component, removing one, or updating a system updates the inventory as part of that work, and the estate is scanned for hardware, software and firmware that is present but not authorized, with the response to an unauthorized component - disable its network access, isolate it, remove it, notify a defined role - decided in advance. The inventory answers WHERE INFORMATION IS as well as what exists: for the categories of information the organization has defined as sensitive, it records where that information is processed and stored, which system components host it, and which users and roles can reach it, and it is updated when any of those change - with automated tools used to locate that information across components and to confirm the required protections are actually in place there, rather than relying on what a system was designed to hold. Each asset also carries its support status: the date vendor support ends is recorded, and a component that reaches end of support is replaced, or is covered by an alternative source of continued support that the organization has arranged and recorded, rather than left in service because it still runs. The inventory is kept current by discovery as well as by the acts that change it: an active discovery tool interrogates the network on a defined frequency, a passive tool identifies assets from the traffic they generate, the DHCP and address-management logs are read on a defined cadence so an address issued to something nobody registered surfaces, and automated software-inventory tooling documents what is installed across the estate rather than relying on a manual return. Support status decides authorization rather than merely being recorded: only software the vendor still supports is designated authorized in the inventory, and software that is unsupported and carries no documented exception setting out its mitigating controls and the residual risk somebody accepted is designated unauthorized, so the process that removes unauthorized software picks it up. What the register holds about those categories of information is itself a DATA INVENTORY: for each data type the organization has designated, the record carries the metadata that makes it usable - what the data is, who owns it, how it is classified, where it came from, what it is retained for and for how long - so the question of what data exists is answered from the register rather than from the systems one at a time. And the register tracks lifecycle STATE as well as existence: each system, device, piece of software, service and data set carries where it has reached in its life - requested, acquired, deployed, in service, superseded, withdrawn, disposed of - with the acts that move it between those states recorded against it, so an asset is managed from acquisition through operation to disposal rather than entered once and forgotten. | MAS-CSO-IIR | P11 |
| Change management Changes to systems and software are requested, reviewed, tested, approved, and tracked. Each request is explicitly approved OR DISAPPROVED by a role authorized to decide it, rather than proceeding because nobody objected, and the decision, the reason behind it and the change itself are written to a durable record - so the log shows what was refused as well as what shipped, and a change that went in without a decision is visible as one. A proposed change is analyzed for what it would do to security and privacy BEFORE it is approved, so the decision is taken with that answer in hand rather than reported afterwards; where the change is significant, the analysis is recorded and the roles who own the affected controls see it. Change control is a body rather than a queue: security and privacy representatives are members of the group that approves changes, so the question is asked in the room instead of by exception. A change is tested, validated and documented before it is finalized and moved into the running system, in an environment that resembles the one it is going to. After it lands, the controls it touched are verified to be implemented correctly, still operating as intended, and still producing the result the organization’s security and privacy requirements call for - verified, not assumed from the fact that the deployment succeeded. Who may make a change at all is restricted: the physical and logical access needed to alter a system is defined, documented, approved and enforced, and it is a narrower set than the people who may use the system. EXCEPTIONS are managed on the same terms as changes: a departure from a standard, a baseline or a policy is requested, assessed for the risk it creates, approved by a role authorized to accept that risk, recorded with a scope and an expiry, and tracked to closure or to a deliberate renewal - so an exception is a change somebody decided rather than a state nobody revisits. | VDR-CSO-DAC | P9, P11 |
| Vulnerability management Regular scanning, prioritization, and remediation of vulnerabilities across systems and applications, fed by current information about threats and weaknesses collected from outside the organization as well as from its own scans - vendor and industry security advisories for the software actually in use, and the threat feeds, bulletins and sector reporting that describe how systems like these are being attacked now - which is gathered continuously rather than at the next scan, evaluated for whether it applies here, and used to decide what is looked for and what is fixed first. The set of vulnerabilities the scanner actually looks for is updated on a defined cadence and whenever new ones are identified and reported, so a scan reflects what is known today rather than what the tool shipped with. Scans that need to see inside a system are given the privileged access to do so, granted deliberately to the scanning activity for the components that require it rather than left to run blind and report clean. Whether a fix is actually present is confirmed by automated mechanisms that report, per component, which security-relevant software and firmware updates are installed - so remediation is evidenced by the estate rather than by a closed ticket. The organization also runs a PUBLIC intake: a reporting channel that anybody outside the organization can find and use to report a vulnerability they have discovered in its systems or products, with a stated scope, a stated way to report, an acknowledgment, and a route into the same triage and remediation process everything else uses. All of this rests on a documented system and information integrity policy with supporting procedures, issued to the roles it binds, owned by a named role and reviewed on a defined cadence. The scanning and the fixing are each defined rather than assumed. Internal assets are scanned automatically on a defined cadence, both with credentials and without, because the two find different things - one shows what is installed, the other shows what somebody with no account can see. Externally exposed assets are scanned on their own cadence, which is at least as frequent, because they are reachable by everyone. Patching is automated for operating systems and, on the same terms and cadence, for the applications running on them, so an application left to be updated by whoever notices is not the gap. Remediation runs to a documented, risk-based strategy - what is fixed first, within what period, and who may approve an exception - reviewed on a defined cadence rather than written once. The public intake is governed by a written vulnerability handling policy that names how to report, who is responsible for handling a report, and the steps from intake through assignment and remediation to remediation testing, with reports tracked in a system that records a severity rating and the timing of identification, analysis and remediation, so how long the organization takes is a measured number rather than an impression. | VDR-CSO-ADT, VDR-CSO-AKE, VDR-CSO-DET, VDR-CSO-FAV, VDR-CSO-MSP, VDR-CSO-RES, VDR-TFR-KEV, VDR-TFR-MVF, VDR-TFR-MVX, VDR-TFR-NMV, VDR-TFR-PCD, VDR-TFR-PDD, VDR-TFR-PSD, VDR-TFR-PVR, VDR-TFR-RMN, VER-EVA-AIA, VER-EVA-EFA, VER-EVA-EFP, VER-EVA-EIR, VER-EVA-ELX, VER-EVA-EPA, VER-EVA-GRV, VER-RPT-AVI, VER-RPT-HLO, VER-RPT-PER, VER-RPT-VDT, VER-TFR-EVU, VER-TFR-MHR, VER-TFR-MRH | P11 |
| Incident response A documented, tested plan to detect, triage, contain, remediate, and communicate security incidents, and to mitigate - so far as is practicable - the harmful effect of a use or disclosure of personal data the organization knows breached its own policies or the law. Each incident is recorded together with its outcome - what happened, what was done about it and how it ended - as a record of that incident, which is a different artifact from the plan being documented. The mitigation duty runs to violations by the organization itself AND to violations by the processors, vendors and other parties handling that data on its behalf: the plan reaches an incident somebody else caused with the organization’s data, so learning of one triggers the same containment and remediation as an incident inside its own walls rather than a request that the other party deal with it. Where an incident carries a duty to tell someone outside the organization, the plan discharges it on the clock the applicable law sets - and, where the organization has itself committed to a timeframe for telling people, on that commitment too, whether or not a statute stands behind it - rather than whenever the investigation happens to conclude: whether an incident is notifiable is decided against written criteria rather than argued after the fact, the regulator or supervisory authority is notified inside the deadline that regime states and inside any shorter or additional timeframe the organization has committed to, the people whose data is affected are told where the risk to them warrants it and, independently of that threshold, wherever the organization’s own privacy commitments say they will be told - so individual notification is never conditioned solely on a statutory risk test - and any other party that law or those commitments require to be notified is told on the same terms, and where a deadline is missed the notification itself explains the delay instead of passing over it. What a notification carries is fixed in advance rather than composed under pressure: to a regulator it describes at least the nature of what happened, including where possible the categories and the approximate number of people affected and of records involved; names a contact point - the data protection officer where there is one, otherwise whoever can answer - from whom more can be obtained; describes the likely consequences; and describes the measures taken or proposed to address it, including where appropriate the measures that will mitigate its adverse effects. Where all of that cannot honestly be given at once, it is given in phases without further undue delay rather than held back until the picture is complete, and each phase says what is still outstanding. The communication to the people affected describes what happened in clear and plain language and carries the same contact point, likely consequences and measures. Every compromise of personal data is documented whether or not it turned out to be notifiable - the facts of it, its effects, and the remedial action taken - in enough detail that a regulator reviewing the file can verify for itself that the notification decision was the right one. Recovery is part of the plan rather than something that follows it: service and data are restored to a state the organization has established is clean, the restoration is verified before the system is handed back to use, the cause is determined rather than inferred from the symptom, and the weakness the incident exposed is fixed - with the plan itself updated for what the incident showed about it. Between the report and the response sits an assessment step that is a duty of its own: every reported event is assessed against written categorization and prioritization criteria by people competent to apply them, and the decision - whether this event is an incident, and at what severity - is recorded with the reasoning, so two assessors reach the same answer and an event judged not to be an incident is a decision somebody made rather than a report that went quiet. Learning is treated as a duty separate from fixing the incident in front of you: the types, volumes and costs of incidents are quantified and reviewed as a set for what the pattern says, and what is learned is pushed back into the controls, the risk assessment, the awareness material and the assessment criteria themselves rather than staying in the report of the incident that produced it. The plan is a documented incident response policy with supporting procedures, issued to the roles it binds, owned by a named role, and reviewed and updated on a defined cadence. The people the plan assigns roles to are trained for them: within a defined period of taking the role, again when the system or the plan changes in a way that affects it, and on a defined cadence thereafter, with the content revised for what exercises and real incidents have shown. The capability is TESTED rather than assumed - on a defined cadence, using tests the organization has chosen for the purpose, such as a tabletop, a walkthrough, a simulation or a live exercise - and that testing is coordinated with the organizational elements that own the related plans, incident response and contingency planning in particular, so the two do not each assume the other. Handling and reporting are supported by automated mechanisms rather than run by hand at the worst moment: detection, triage, tracking, evidence collection and the routing of a report are automated so far as the organization’s systems allow, and the reports that must go outside are produced and sent by mechanism rather than composed under pressure. The roles the plan assigns are named across the functions an incident actually needs and not security alone - legal, IT, information security, facilities, communications, human resources, the responders and the analysts - and the assignment is reviewed on a defined cadence. So are the CHANNELS: a primary and a secondary mechanism for communicating and reporting during an incident are chosen in advance, on the understanding that the ordinary one may be the thing that is unavailable or compromised, and both are reviewed on the same cadence. The plan reaches the parties outside the organization that an incident actually involves: the suppliers and other third parties whose services, staff or systems would be part of the response are named in it, take part in the planning and the exercises, and are called on during response and recovery on terms agreed in advance rather than negotiated during the event. ESCALATION is a defined step and not a judgment call - the plan states the conditions under which an incident is escalated or elevated, whether by severity, by elapsed time, by the functions it has reached or by the obligations it triggers, who it goes to at each step, and what changes when it gets there. The analysis establishes what actually took place during the incident as well as why it happened, and the incident’s magnitude - how many systems, records and people it reached, and over what period - is estimated as the investigation proceeds and then VALIDATED against the evidence rather than left at the first number anybody said out loud. Notification runs to internal stakeholders as well as external ones, so the functions inside the organization that have to act on an incident are told on the same defined terms as the parties outside it. And containment is followed by ERADICATION as a separate act: the malicious code, the unauthorized access and the persistence left behind are removed and their removal is confirmed, so a contained incident is not mistaken for a finished one. | IEC-CSO-DPR, IEC-CSO-EFI, IEC-CSO-EFR, VER-TFR-IRI, VER-TFR-NRI | P11 |
Beyond the pair
Where else this work counts
A framework is lit when a shared control above also maps to it. Unlit means none of them do, which is an absence rather than a judgment about that standard.
Also reached by these 6 controls
- AI Governance Essentials not reached
- Amazon Appstore Child-Directed Apps not reached
- Apple App Store Kids Category not reached
- CIS Critical Security Controls also reached
- COPPA also reached
- ESG Essentials not reached
- EU AI Act not reached
- FedRAMP 20x also reached
- FedRAMP Rev5 Class B also reached
- FedRAMP Rev5 Class C also reached
- FedRAMP Rev5 Class D also reached
- GDPR also reached
- Google Play Families not reached
- HIPAA also reached
- ISO 9001 also reached
- ISO/IEC 27001 also reached
- ISO/IEC 42001 also reached
- NIST AI Risk Management Framework not reached
- NIST Cybersecurity Framework also reached
- NIST SP 800-171 also reached
- NIST SP 800-53 also reached
- PCI DSS also reached
- PIPEDA also reached
- SOC 2 also reached
- US Employment Law - Federal Baseline not reached
Nearby pairs
- SOX (Sarbanes-Oxley) Section 404 and SOC 2 27 shared controls
- SOX (Sarbanes-Oxley) Section 404 and ISO/IEC 27001 24 shared controls
- SOX (Sarbanes-Oxley) Section 404 and NIST SP 800-53 21 shared controls
- SOX (Sarbanes-Oxley) Section 404 and FedRAMP Rev5 Class C 20 shared controls
- SOX (Sarbanes-Oxley) Section 404 and FedRAMP Rev5 Class D 20 shared controls
- SOX (Sarbanes-Oxley) Section 404 and NIST Cybersecurity Framework 20 shared controls
The thesis
Why this is one project, not two
On a crosswalk-native model, SOX (Sarbanes-Oxley) Section 404 mostly lights up controls you already built for FedRAMP Consolidated Rules. You’re not re-uploading the same screenshot for a second audit. You apply the framework and see the genuine delta worth working. That’s the whole idea behind collect once, comply everywhere.
Next step
Add SOX (Sarbanes-Oxley) Section 404 to the work you already did
Apply both frameworks in one workspace and see the overlap measured against the controls you already hold.