PCI DSS ↔ SOX (Sarbanes-Oxley) Section 404
18 canonical controls in Keel’s library satisfy clauses of both PCI DSS 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.
Controls that satisfy both
| Canonical control | PCI DSS clauses | SOX (Sarbanes-Oxley) Section 404 clauses |
|---|---|---|
|
Information security policy
A board-approved information security policy set, reviewed at least annually and communicated to the workforce.
|
12.1 | P12 |
|
Risk assessment & treatment
A documented process to identify, analyze, evaluate, and treat information security risks on a defined cadence.
|
12.3 | P6, P7, P9 |
|
Access control policy
Rules for granting, reviewing, and revoking access to systems and data based on business need and least privilege.
|
7.1, 7.2 | P11 |
|
User provisioning & deprovisioning
Joiner/mover/leaver process to grant, change, and promptly remove access across systems.
|
8.2 | P11 |
|
Multi-factor authentication
MFA enforced for remote access, administrative access, and access to sensitive systems and data.
|
8.4, 8.5 | P11 |
|
Encryption in transit & at rest
Strong cryptography protects sensitive data in transit over public networks and at rest in storage.
|
3.5, 4.2 | P11 |
|
Logging & monitoring
Security-relevant events are logged, protected, retained, and reviewed for anomalies.
|
10.2, 10.3, 10.4 | P11, P13 |
|
Vulnerability management
Regular scanning, prioritization, and remediation of vulnerabilities across systems and applications.
|
6.3, 11.3 | P11 |
|
Incident response
A documented, tested plan to detect, triage, contain, remediate, and communicate security incidents.
|
12.10 | P11 |
|
Change management
Changes to systems and software are requested, reviewed, tested, approved, and tracked.
|
6.5 | P9, P11 |
|
Third-party / vendor risk management
Due diligence, contractual safeguards, and ongoing monitoring of vendors that handle your data.
|
12.8 | P11, P15 |
|
Security awareness training
Ongoing security awareness training for all personnel, with completion tracking.
|
12.6 | P4, P14 |
|
Asset inventory
An inventory of hardware, software, and information assets with assigned owners.
|
12.5 | P11 |
|
Physical security
Physical access to facilities and equipment holding sensitive data is restricted and monitored.
|
9.2 | P11 |
|
Secure software development
Secure coding, review, and testing practices across the development lifecycle.
|
6.2 | P11 |
|
Network security controls
Firewalls/segmentation and network controls restrict traffic to and from sensitive environments.
|
1.2, 1.3 | P11 |
|
Data retention & secure disposal
Data is retained per policy and securely destroyed when no longer needed.
|
3.2 | P13 |
|
Personnel security (HR)
Background screening, confidentiality agreements, and onboarding/offboarding security steps.
|
12.7 | P4 |
Clause identifiers (PCI DSS and SOX (Sarbanes-Oxley) Section 404) are referenced factually for mapping. Keel is not affiliated with or endorsed by the bodies that publish these standards. Control descriptions are Keel’s own; a framework’s full authored control count is on its framework page.
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 PCI DSS. 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.