Crosswalk pair
CIS Critical Security Controls and SOX (Sarbanes-Oxley) Section 404, control by control
13 canonical controls in Keel’s library satisfy clauses of both CIS Critical Security Controls 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.
13
Controls that satisfy both
Canonical controls that crosswalk to at least one clause of each.
18
In Keel’s library for CIS Critical Security Controls
72% of them also map to SOX (Sarbanes-Oxley) Section 404.
29
In Keel’s library for SOX (Sarbanes-Oxley) Section 404
45% of them also map to CIS Critical Security Controls.
56
Evidence artifacts expected
Across the shared controls, from Keel’s evidence guidance. Gathered once.
-
CIS Critical Security Controls 72%
13 controls of 18 in Keel’s library for CIS Critical Security Controls also map to SOX (Sarbanes-Oxley) Section 404.
-
SOX (Sarbanes-Oxley) Section 404 45%
13 controls of 29 in Keel’s library for SOX (Sarbanes-Oxley) Section 404 also map to CIS Critical Security Controls.
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 | CIS Critical Security Controls clauses | SOX (Sarbanes-Oxley) Section 404 clauses |
|---|---|---|
| Access Control | ||
| Access control policy Rules for granting, reviewing, and revoking access to systems and data based on business need and least privilege; anyone who works with sensitive data, or in a place from which it can be reached, is individually authorized for that work or supervised while doing it; and a documented emergency route exists to obtain the data when the normal access path is unavailable, with every use of that route recorded and reviewed afterwards. | 6.8 | P11 |
| Multi-factor authentication Documented procedures verify that a person or system seeking access to sensitive data is the one it claims to be, on every path by which that data can be reached - and multi-factor authentication is the enforced mechanism for remote access, administrative access, and access to sensitive systems and data. The multi-factor mechanism itself is configured so it cannot be bypassed, so the factors it uses are genuinely independent of one another - one factor’s success granting no knowledge of and no route around another - and so access is refused unless every factor required has succeeded. | 6.3, 6.5 | P11 |
| User provisioning & deprovisioning Joiner/mover/leaver process to grant, change, and promptly remove access across systems, in which every person is issued an account of their own carrying a unique name or number, so an action in a log traces back to one named individual rather than to a shared or generic login. Each person’s right of access is recorded when it is established and reviewed on a schedule thereafter, as well as granted and changed - so what someone holds is a documented position that has been looked at again, not the accumulated residue of past requests - and what may be granted follows the organization’s access authorization rules rather than the judgement of whoever processes the request. | 5.3, 6.1, 6.2 | P11 |
| Data Protection & Privacy | ||
| Encryption in transit & at rest Strong cryptography protects sensitive data in transit over public networks and at rest in storage. | 3.11 | P11 |
| Infrastructure & Operations | ||
| 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. | 1.1, 2.1 | P11 |
| Logging & monitoring Security-relevant events - including successful and failed log-in attempts - are logged, protected, retained, and reviewed for anomalies, and the discrepancies that review finds are reported to the people who act on them. The review runs on a defined cadence and covers the records of system activity as a set - the audit logs, the reports of who accessed what, and the record of security incidents - rather than the log stream alone. | 8.1, 8.2 | P11 |
| Network security controls Firewalls/segmentation and network controls restrict traffic to and from sensitive environments. | 4.4, 4.5, 12.2, 13.4 | P11 |
| Secure software development Secure coding, review, and testing practices across the development lifecycle. | 16.1, 16.12 | 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. | 7.1, 7.3 | P11 |
| Resilience & Continuity | ||
| Backups Regular, tested backups of critical data and systems with defined retention, each one a RETRIEVABLE EXACT COPY of the data it protects - complete and restorable, not a partial or lossy snapshot - including a copy taken before equipment holding that data is moved. | 11.2, 11.5 | 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 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, the people whose data is affected are told where the risk to them warrants it, and where a deadline is missed the notification itself explains the delay instead of passing over it. | 17.1, 17.4 | P11 |
| Third-party Risk | ||
| Third-party / vendor risk management Due diligence, contractual safeguards, and ongoing monitoring of vendors that handle your data: the agreement obliges the vendor to comply in its own right with the security requirements that apply to it - an absolute standard, not a promise to match whatever you happen to do - to pass those obligations down to any subcontractor it brings in BY ENTERING INTO a contract or equivalent written arrangement with that subcontractor rather than by merely requiring equivalent practice of it, and to report to you, within a stated time, security incidents it becomes aware of and confirmed breaches of your data. Where a contract is not the instrument available, an equivalent written arrangement carrying the same obligations discharges the duty. The same obligations, together with the separation that keeps a related organization out of data it is not entitled to, are written into the governing document of any other arrangement that puts your data in the hands of a sponsor, parent, affiliate or plan. Diligence is not confined to security where the relationship warrants more: for suppliers significant enough to matter, the organization states the standards of conduct it expects of them - how they behave commercially and how they treat the environment around their operations - and screens candidates and incumbents against those stated expectations as part of the same selection and monitoring cycle, rather than accepting a signature on a code as evidence of it. | 15.4, 15.5, 15.6 | P11, P15 |
| People & Culture | ||
| Security awareness training Ongoing security and data-handling awareness training for all personnel, with completion tracking, and periodic security updates - reminders, bulletins and alerts - issued to the workforce between training cycles. New joiners are trained within a defined period of starting, anyone whose work is affected is retrained within a defined period after a material change to the policies or procedures, and every completion is recorded. | 14.1 | P4, P14 |
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 — an absence, not a judgment about that standard.
Also reached by these 13 controls
- AI Governance Essentials
- Amazon Appstore Child-Directed Apps
- Apple App Store Kids Category
- COPPA
- ESG Essentials
- EU AI Act
- GDPR
- Google Play Families
- HIPAA
- ISO 9001
- ISO/IEC 27001
- ISO/IEC 42001
- NIST AI Risk Management Framework
- NIST Cybersecurity Framework
- NIST SP 800-171
- NIST SP 800-53
- PCI DSS
- SOC 2
- US Employment Law - Federal Baseline
Nearby pairs
- SOX (Sarbanes-Oxley) Section 404 and ISO/IEC 27001 24 shared controls
- SOX (Sarbanes-Oxley) Section 404 and SOC 2 23 shared controls
- SOX (Sarbanes-Oxley) Section 404 and NIST SP 800-53 20 shared controls
- CIS Critical Security Controls and ISO/IEC 27001 17 shared controls
- CIS Critical Security Controls and NIST SP 800-53 17 shared controls
- CIS Critical Security Controls and PCI DSS 16 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 CIS Critical Security Controls. 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.