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January 8, 2024

Uncovering CyberCartel Threats in Latin America

Jan 2024

Discover how Darktrace investigates CyberCartel attacks targeting Latin America. Learn about the methods and findings of this crucial analysis.

Introduction

In September 2023, Darktrace published its first Half-Year Threat Report, highlighting Threat Research, Security Operation Center (SOC), model breach, and Cyber AI Analyst analysis and trends across the Darktrace customer fleet. According to Darktrace’s Threat Report, the most observed threat type to affect Darktrace customers during the first half of 2023 was Malware-as-a-Service (Maas). The report highlighted a growing trend where malware strains, specifically in the MaaS ecosystem, “use cross-functional components from other strains as part of their evolution and customization” [1].

Darktrace’s Threat Research team assessed this ‘Frankenstein’ approach would very likely increase, as shown by the fact that indicators of compromise (IoCs) are becoming “less and less mutually exclusive between malware strains as compromised infrastructure is used by multiple threat actors through access brokers or the “as-a-Service” market” [1].

Darktrace investigated one such threat during the last months of summer 2023, eventually leading to the discovery of CyberCartel-related activity across a significant number of Darktrace customers, especially in Latin America.

CyberCartel Overview and Darktrace Coverage

During a threat hunt, Darktrace’s Threat Research team discovered the download of a binary with a unique Uniform Resource Identifier (URI) pattern. When examining Darktrace’s customer base, it was discovered that binaries with this same URI pattern had been downloaded by a significant number of customer accounts, especially by customers based in Latin America. Although not identical, the targets and tactics, techniques, and procedures (TTPs) resembled those mentioned in an article regarding a botnet called Fenix [2], particularly active in Latin America.

During the Threat Research team’s investigation, nearly 40 potentially affected customer accounts were identified. Darktrace’s global Threat Research team investigates pervasive threats across Darktrace’s customer base daily. This cross-fleet research is based on Darktrace’s anomaly-based detection capability, Darktrace DETECT™, and revolves around technical analysis and contextualization of detection information.

Amid the investigation, further open-source intelligence (OSINT) research revealed that most indicators observed during Darktrace’s investigations were associated to a Latin American threat group named CyberCartel, with a small number of IoCs being associated with the Fenix botnet. While CyberCartel seems to have been active since 2012 and relies on MaaS offerings from well-known malware families, Fenix botnet was allegedly created at the end of last year and “specifically targets users accessing government services, particularly tax-paying individuals in Mexico and Chile” [2].

Both groups share similar targets and TTPs, as well as objectives: installing malware with information-stealing capabilities. In the case of Fenix infections, the compromised device will be added to a botnet and execute tasks given by the attacker(s); while in the case of CyberCartel, it can lead to various types of second-stage info-stealing and Man-in-the-Browser capabilities, including retrieving system information from the compromised device, capturing screenshots of the active browsing tab, and redirecting the user to fraudulent websites such as fake banking sites. According to a report by Metabase Q [2], both groups possibly share command and control (C2) infrastructure, making accurate attribution and assessment of the confidence level for which group was affecting the customer base extremely difficult. Indeed, one of the C2 IPs (104.156.149[.]33) observed on nearly 20 customer accounts during the investigation had OSINT evidence linking it to both CyberCartel and Fenix, as well as another group known to target Mexico called Manipulated Caiman [3] [4] [5].

CyberCartel and Fenix both appear to target banking and governmental services’ users based in Latin America, especially individuals from Mexico and Chile. Target institutions purportedly include tax administration services and several banks operating in the region. Malvertising and phishing campaigns direct users to pages imitating the target institutions’ webpages and prompt the download of a compressed file advertised in a pop-up window. This file claims enhance the user’s security and privacy while navigating the webpage but instead redirects the user to a compromised website hosting a zip file, which itself contains a URL file containing instructions for retrieval of the first stage payload from a remote server.

pop-up window with malicious file — Figure 1: Example of a pop-up window asking the user to download a compressed file allegedly needed to continue navigating the portal. Connections to the domain srlxlpdfmxntetflx[.]com were observed in one account investigated by Darktrace

During their investigations, the Threat Research team observed connections to 100% rare domains (e.g., situacionfiscal[.]online, consultar-rfc[.]online, facturmx[.]info), many of them containing strings such as “mx”, “rcf” and “factur” in their domain names, prior to the downloads of files with the unique URI pattern identified during the aforementioned threat hunting session.

The reference to “rfc” is likely a reference to the Registro Federal de Contribuyentes, a unique registration number issued by Mexico’s tax collection agency, Servicio de Administración Tributaria (SAT). These domains were observed as being 100% rare for the environment and were connected to a few minutes prior to connections to CyberCartel endpoints. Most of the endpoints were newly registered, with creation dates starting from only a few months earlier in the first half of 2023. Interestingly, some of these domains were very similar to legitimate government websites, likely a tactic employed by threat actors to convince users to trust the domains and to bypass security measures.

Figure 2: Screenshot from similarweb[.]com showing the degree of affinity between malicious domains situacionfiscal[.]online and facturmx[.]info and the legitimate Mexican government hostname sat[.]gob[.]mx

Figure 3: Screenshot of the likely source infection website facturmx[.]info taken when visited in a sandbox environment

In other customer networks, connections to mail clients were observed, as well as connections to win-rar[.]com, suggesting an interaction with a compressed file. Connections to legitimate government websites were also detected around the same time in some accounts. Shortly after, the infected devices were detected connecting to 100% rare IP addresses over the HTTP protocol using WebDAV user agents such as Microsoft-WebDAV-MiniRedir/10.0.X and DavCInt. Web Distributed Authoring and Versioning, in its full form, is a legitimate extension to the HTTP protocol that allows users to remotely share, copy, move and edit files hosted on a web server. Both CyberCartel and Fenix botnet reportedly abuse this protocol to retrieve the initial payload via a shortcut link. The use (or abuse) of this protocol allows attackers to evade blocklists and streamline payload distribution. In cases investigated by Darktrace, the use of this protocol was not always considered unusual for the breach device, indicating it also was commonly used for its legitimate purposes.

HTTP methods observed included PROPFIND, GET, and OPTIONS, where a higher proportion of PROPFIND requests were observed. PROPFIND is an HTTP method related to the use of WebDAV that retrieves properties in an exactly defined, machine-readable, XML document (GET responses do not have a define format). Properties are pieces of data that describe the state of a resource, i.e., data about data [7]. They are used in distributed authoring environments to provide for efficient discovery and management of resources.

Figure 4: Device event log showing a connection to facturmx[.]info followed by a WebDAV connection to the 100% rare IP 172.86.68[.]104

In a number of cases, connections to compromised endpoints were followed by the download of one or more executable files with names following the regex pattern /(yes|4496|[A-Za-z]{8})/(((4496|4545)[A-Za-z]{24})|Herramienta_de_Seguridad_SII).(exe|jse), for example 4496UCJlcqwxvkpXKguWNqNWDivM.exe. PROPFIND and GET HTTP requests for dynamic-link library (DLL) files such as urlmon.dll and netutils.dll were also detected. These are legitimate Windows files that are essential to handle network and internet-related tasks in Windows. Irrespective of whether they had malicious or legitimate signatures, Darktrace DETECT was able to recognize that the download of these files was suspicious with rare external endpoints not previously observed on the respective customer networks.

Figure 5: Advanced Search results showing some of the HTTP requests made by the breach device to a CyberCartel endpoint via PROPFIND, GET, or OPTIONS methods for executable and DLL files

Following Darktrace DETECT’s model breaches, these HTTP connections were investigated by Cyber AI Analyst™. AI Analyst provided a summary and further technical details of these connections, as shown in figure 6.

Figure 6: Cyber AI Analyst incident showing a summary of the event, as well as technical details. The AI investigation process is also detailed

AI Analyst searched for all HTTP connections made by the breach device and found more than 2,500 requests to more than a hundred endpoints for one given device. It then looked for the user agents responsible for these connections and found 15 possible software agents responsible for the HTTP requests, and from these identified a single suspicious software agent, Microsoft-WebDAV-Min-Redir. As mentioned previously, this is a legitimate software, but its use by the breach device was considered unusual by Darktrace’s machine learning technology. By performing analysis on thousands of connections to hundreds of endpoints at machine speed, AI Analyst is able to perform the heavy lifting on behalf of human security teams and then collate its findings in a single summary pane, giving end-users the information needed to assess a given activity and quickly start remediation as needed. This allows security teams and administrators to save precious time and provides unparalleled visibility over any potentially malicious activity on their network.

Following the successful identification of CyberCartel activity by DETECT, Darktrace RESPOND™ is then able to contain suspicious behavior, such as by restricting outgoing traffic or enforcing normal patterns of life on affected devices. This would allow customer security teams extra time to analyze potentially malicious behavior, while leaving the rest of the network free to perform business critical operations. Unfortunately, in the cases of CyberCartel compromises detected by Darktrace, RESPOND was not enabled in autonomous response mode meaning preventative actions had to be applied manually by the customer’s security team after the fact.

Figure 7. Device event log showing connections to 100% rare CyberCartel endpoint 172.86.68[.]194 and subsequent suggested RESPOND actions.

Conclusion

Threat actors targeting high-value entities such as government offices and banks is unfortunately all too commonplace. In the case of Cyber Cartel, governmental organizations and entities, as well as multiple newspapers in the Latin America, have cautioned users against these malicious campaigns, which have occurred over the past few years [8] [9]. However, attackers continuously update their toolsets and infrastructure, quickly rendering these warnings and known-bad security precautions obsolete. In the case of CyberCartel, the abuse of the legitimate WebDAV protocol to retrieve the initial payload is just one example of this. This method of distribution has also been leveraged by in Bumblebee malware loader’s latest campaign [10]. The abuse of the legitimate WebDAV protocol to retrieve the initial CyberCartel payload outlined in this case is one example among many of threat actors adopting new distribution methods used by others to further their ends.

As threat actors continue to search for new ways of remaining undetected, notably by incorporating legitimate processes into their attack flow and utilizing non-exclusive compromised infrastructure, it is more important than ever to have an understanding of normal network operation in order to detect anomalies that are indicative of an ongoing compromise. Darktrace’s suite of products, including DETECT+RESPOND, is well placed to do just that, with machine-speed analysis, detection, and response helping security teams and administrators keep their digital environments safe from malicious actors.

Credit to: Nahisha Nobregas, SOC Analyst

References

[1] https://darktrace.com/blog/darktrace-half-year-threat-report

[2] https://www.metabaseq.com/fenix-botnet/

[3] https://perception-point.io/blog/manipulated-caiman-the-sophisticated-snare-of-mexicos-banking-predators-technical-edition/

[4] https://www.virustotal.com/gui/ip-address/104.156.149.33/community

[5] https://silent4business.com/tendencias/1

[6] https://www.metabaseq.com/cybercartel/

[7] http://www.webdav.org/specs/rfc2518.html#rfc.section.4.1

[8] https://www.csirt.gob.cl/alertas/8ffr23-01415-01/

[9] https://www.gob.mx/sat/acciones-y-programas/sitios-web-falsos

[10] https://www.bleepingcomputer.com/news/security/bumblebee-malware-returns-in-new-attacks-abusing-webdav-folders/

Appendices

Darktrace DETECT Model Detections

AI Analyst Incidents:

• Possible HTTP Command and Control

• Suspicious File Download

Model Detections:

• Anomalous Connection / New User Agent to IP Without Hostname

• Device / New User Agent and New IP

• Anomalous File / EXE from Rare External Location

• Multiple EXE from Rare External Locations

• Anomalous File / Script from Rare External Location

List of IoCs

IoC - Type - Description + Confidence

f84bb51de50f19ec803b484311053294fbb3b523 - SHA1 hash - Likely CyberCartel Payload IoCs

4eb564b84aac7a5a898af59ee27b1cb00c99a53d - SHA1 hash - Likely CyberCartel payload

8806639a781d0f63549711d3af0f937ffc87585c - SHA1 hash - Likely CyberCartel payload

9d58441d9d31b5c4011b99482afa210b030ecac4 - SHA1 hash - Possible CyberCartel payload

37da048533548c0ad87881e120b8cf2a77528413 - SHA1 hash - Likely CyberCartel payload

2415fcefaf86a83f1174fa50444be7ea830bb4d1 - SHA1 hash - Likely CyberCartel payload

15a94c7e9b356d0ff3bcee0f0ad885b6cf9c1bb7 - SHA1 hash - Likely CyberCartel payload

cdc5da48fca92329927d9dccf3ed513dd28956af - SHA1 hash - Possible CyberCartel payload

693b869bc9ba78d4f8d415eb7016c566ead839f3 - SHA1 hash - Likely CyberCartel payload

04ce764723eaa75e4ee36b3d5cba77a105383dc5 - SHA1 hash - Possible CyberCartel payload

435834167fd5092905ee084038eee54797f4d23e - SHA1 hash - Possible CyberCartel payload

3341b4f46c2f45b87f95168893a7485e35f825fe - SHA1 hash - Likely CyberCartel payload

f6375a1f954f317e16f24c94507d4b04200c63b9 - SHA1 hash - Likely CyberCartel payload

252efff7f54bd19a5c96bbce0bfaeeecadb3752f - SHA1 hash - Likely CyberCartel payload

8080c94e5add2f6ed20e9866a00f67996f0a61ae - SHA1 hash - Likely CyberCartel payload

c5117cedc275c9d403a533617117be7200a2ed77 - SHA1 hash - Possible CyberCartel payload

19dd866abdaf8bc3c518d1c1166fbf279787fc03 - SHA1 hash - Likely CyberCartel payload

548287c0350d6e3d0e5144e20d0f0ce28661f514 - SHA1 hash - Likely CyberCartel payload

f0478e88c8eefc3fd0a8e01eaeb2704a580f88e6 - SHA1 hash - Possible CyberCartel payload

a9809acef61ca173331e41b28d6abddb64c5f192 - SHA1 hash - Likely CyberCartel payload

be96ec94f8f143127962d7bf4131c228474cd6ac - SHA1 hash -Likely CyberCartel payload

44ef336395c41bf0cecae8b43be59170bed6759d - SHA1 hash - Possible CyberCartel payload

facturmx[.]info - Hostname - Likely CyberCartel infection source

consultar-rfc[.]online - Hostname - Possible CyberCartel infection source

srlxlpdfmxntetflx[.]com - Hostname - Likely CyberCartel infection source

facturmx[.]online - Hostname - Possible CyberCartel infection source

rfcconhomoclave[.]mx - Hostname - Possible CyberCartel infection source

situacionfiscal[.]online - Hostname - Likely CyberCartel infection source

descargafactura[.]club - Hostname - Likely CyberCartel infection source

104.156.149[.]33 - IP - Likely CyberCartel C2 endpoint

172.86.68[.]194 - IP - Likely CyberCartel C2 endpoint

139.162.73[.]58 - IP - Likely CyberCartel C2 endpoint

172.105.24[.]190 - IP - Possible CyberCartel C2 endpoint

MITRE ATT&CK Mapping

Tactic - Technique

Command and Control - Ingress Tool Transfer (T1105)

Command and Control - Web Protocols (T1071.001)

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Inside the SOC

Darktrace cyber analysts are world-class experts in threat intelligence, threat hunting and incident response, and provide 24/7 SOC support to thousands of Darktrace customers around the globe. Inside the SOC is exclusively authored by these experts, providing analysis of cyber incidents and threat trends, based on real-world experience in the field.

Author

Alexandra Sentenac

Cyber Analyst

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Email

February 13, 2025

Why Darktrace / EMAIL excels against APTs

What are APTs?

An Advanced Persistent Threat (APT) describes an adversary with sophisticated levels of expertise and significant resources, with the ability to carry out targeted cyber campaigns. These campaigns may penetrate an organization and remain undetected for long periods, allowing attackers to gather intelligence or cause damage over time.

Over the last few decades, the term APT has evolved from being almost exclusively associated with nation-state actors to a broader definition that includes highly skilled, well-resourced threat groups. While still distinct from mass, opportunistic cybercrime or "spray and pray" attacks, APT now refers to the elite tier of adversaries, whether state-sponsored or not, who demonstrate advanced capabilities, persistence, and a clear strategic focus. This shift reflects the growing sophistication of cyber threats, where non-state actors can now rival nation-states in executing covert, methodical intrusions to achieve long-term objectives.

These attacks are resource-intensive for threat actors to execute, but the potential rewards—ranging from financial gain to sensitive data theft—can be significant. In 2020, Business Email Compromise (BEC) attacks netted cybercriminals over $1.8 billion.¹

And recently, the advent of AI has helped to automate launching these attacks, lowering the barriers to entry and making it more efficient to orchestrate the kind of attack that might previously have taken weeks to create. Research shows that AI can do 90% of a threat actor’s work² – reducing time-to-target by automating tasks rapidly and avoiding errors in phishing communications. Email remains the most popular vector for initiating these sophisticated attacks, making it a critical battleground for cyber defense.

What makes APTs so successful?

The success of Advanced Persistent Threats (APTs) lies in their precision, persistence, and ability to exploit human and technical vulnerabilities. These attacks are carefully tailored to specific targets, using techniques like social engineering and spear phishing to gain initial access.

Once inside, attackers move laterally through networks, often remaining undetected for months or even years, silently gathering intelligence or preparing for a decisive strike. Alternatively, they might linger inside an account within the M365 environment, which could be even more valuable in terms of gathering information – in 2023 the average time to identify a breach in 2023 was 204 days.³‍

The subtle and long-term outlook nature of APTs makes them highly effective, as traditional security measures often fail to identify the subtle signs of compromise.

How Darktrace’s approach is designed to catch the most advanced threats

Luckily for our customers, Darktrace’s AI approach is uniquely equipped to detect and neutralize APTs. Unlike the majority of email security solutions that rely on static rules and signatures, or that train their AI on previous known-bad attack patterns, Darktrace leverages Self-Learning AI that baselines normal patterns of behavior within an organization, to immediately detect unusual activity that may signal an APT in progress.

But in the modern era of email threats, no email security solution can guarantee 100% effectiveness. Because attackers operate with great sophistication, carefully adapting their tactics to evade detection – whether by altering attachments, leveraging compromised accounts, or moving laterally across an organization – a siloed security approach risks missing these subtle, multi-domain threats. That’s why a robust defense-in-depth strategy is essential to mitigate APTs.

Real-world threat finds: Darktrace / EMAIL in action

Let’s take a look at some real-world scenarios where Darktrace / EMAIL stopped tactics associated with APT campaigns in their tracks – from adversary-in-the-middle attacks to suspicious lateral movement.

1: How Darktrace disrupted an adversary-in-the-middle attack by identifying abnormal login redirects and blocking credential exfiltration

In October 2024, Darktrace detected an adversary-in-the-middle (AiTM) attack targeting a Darktrace customer. The attack began with a phishing email from a seemingly legitimate Dropbox address, which contained multiple link payloads inviting the recipient to access a file. Other solutions would have struggled to catch this attack, as the initial AitM attack was launched through delivering a malicious URL through a trusted vendor or service. Once compromised, the threat actor could have laid low on the target account, gathering reconnaissance, without detection from the email security solution.

Darktrace / EMAIL identified the abnormal login redirects and flagged the suspicious activity. Darktrace / IDENTITY then detected unusual login patterns and blocked credential exfiltration attempts, effectively disrupting the attack and preventing the adversary from gaining unauthorized access. Read more.

Figure 1: Overview of the malicious email in the Darktrace / EMAIL console, highlighting Dropbox associated content/link payloads

2: How Darktrace stopped lateral movement to block NTLM hash theft

In early 2024, Darktrace detected an attack by the TA577 threat group, which aimed to steal NTLM hashes to gain unauthorized access to systems. The attack began with phishing emails containing ZIP files that connected to malicious infrastructure.

A traditional email security solution would have likely missed this attack by focusing too heavily on analyzing the zip file payloads or relying on reputation analysis to understand whether the infrastructure was registered as bad before this activity was a recognized IoC.

Because it correlates activity across domains, Darktrace identified unusual lateral movement within the network and promptly blocked the attempts to steal NTLM hashes, effectively preventing the attackers from accessing sensitive credentials and securing the network. Read more.

Figure 2: A summary of anomaly indicators seen for a campaign email sent by TA577, as detected by Darktrace / EMAIL

3: How Darktrace prevented the WarmCookie backdoor deployment embedded in phishing emails

In mid-2024, Darktrace identified a phishing campaign targeting organizations with emails impersonating recruitment firms. These emails contained malicious links that, when clicked, deployed the WarmCookie backdoor.

These emails are difficult to detect, as they use social engineering tactics to manipulate users into engaging with emails and following the embedded malicious links – but if a security solution is not analysing content and context, these could be allowed through.

In several observed cases across customer environments, Darktrace detected and blocked the suspicious behavior associated with WarmCookie that had already managed to evade customers’ native email security. By using behavioral analysis to correlate anomalous activity across the digital estate, Darktrace was able to identify the backdoor malware strain and notify customers. Read more.

Conclusion

These threat examples highlight a key principle of the Darktrace approach – that a backwards-facing approach grounded in threat intelligence will always be one step behind.

Most threat actors operate in campaigns, carefully crafting attacks and testing them across multiple targets. Once a campaign is identified, good defenders and traditional security solutions quickly update their defenses with new threat intelligence, rules, and signatures. However, APTs have the resources to rapidly adapt – spinning up new infrastructure, modifying payloads and altering their attack footprint to evade detection.

This is where Darktrace / EMAIL excels. Only by analyzing each user, message and interaction can an email security solution hope to catch the types of highly-sophisticated attacks that have the potential to cause major reputational and financial damage. Darktrace / EMAIL ensures that even the most subtle threats are detected and blocked with autonomous response, before causing impact – helping organizations remain one step ahead of increasingly adaptive threat actors.

Download the Darktrace / EMAIL Solution Brief

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Gain up to 13 days of earlier threat detection and maximize ROI on your current email security
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Stop the 58% of threats bypassing traditional email security

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References

[1] FBI Internet Crime Report 2020

[2] https://www.optiv.com/insights/discover/blog/future-security-automation-how-ai-machine-learning-and-automation-are

[3] IBM Cost of a Data Breach Report 2023

‍

About the author

Carlos Gray

Product Manager

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Compliance

February 11, 2025

NIS2 Compliance: Interpreting 'State-of-the-Art' for Organisations

NIS2 Background

17 October 2024 marked the deadline for European Union (EU) Member States to implement the NIS2 Directive into national law. The Directive aims to enhance the EU’s cybersecurity posture by establishing a high common level of cybersecurity for critical infrastructure and services. It builds on its predecessor, the 2018 NIS Directive, by expanding the number of sectors in scope, enforcing greater reporting requirements and encouraging Member States to ensure regulated organisations adopt ‘state-of-the-art' security measures to protect their networks, OT and IT systems.

The challenge of NIS2 & 'state-of-the-art'

Preamble (51) - "Member States should encourage the use of any innovative technology, including artificial intelligence, the use of which could improve the detection and prevention of cyberattacks, enabling resources to be diverted towards cyberattacks more effectively."

Article 21 - calls on Member States to ensure that essential and important entities “take appropriate and proportionate” cyber security measures, and that they do so by “taking into account the state-of-the-art and, where applicable, relevant European and international standards, as well as the cost of implementation.”

Regulartory expectations and ambiguity of NIS2

While organisations in scope can rely on technical guidance provided by ENISA¹ , the EU’s agency for cybersecurity, or individual guidelines provided by Member States or Public-Private Partnerships where they have been published,² the mention of ‘state-of-the-art' remains up to interpretation in most Member States. The use of the phrase implies that cybersecurity measures must evolve continuously to keep pace with emerging threats and technological advancements without specifying what ‘state-of-the-art’ actually means for a given context and risk.³

This ambiguity makes it difficult for organisations to determine what constitutes compliance at any given time and could lead to potential inconsistencies in implementation and enforcement. Moreover, the rapid pace of technological change means that what is considered "state-of-the-art" today will become outdated, further complicating compliance efforts.

However, this is not unique to NIS regulation. As EU scholars have noted, while “state-of-the-art" is widely referred to in legal text relating to technology, there is no standardised legal definition of what it actually constitutes.⁴

Defining state-of-the-art cybersecurity

In this blog, we outline technical considerations for state-of-the-art cybersecurity. We draw from expertise within our own business and in academia as well as guidelines and security standards set by national agencies, such as Germany’s Federal Office for Information Security (BSI) or Spain’s National Security Framework (ENS), to put forward five criteria to define state-of-the-art cybersecurity.

The five core criteria include:

Continuous monitoring
Incident correlation
Detection of anomalous activity
Autonomous response
Proactive cyber resilience

These principles build on long-standing security considerations, such as business continuity, vulnerability management and basic security hygiene practices.

Although these considerations are written in the context of the NIS2 Directive, they are likely to also be relevant for other jurisdictions. We hope these criteria help organisations understand how to best meet their responsibilities under the NIS2 Directive and assist Competent Authorities in defining compliance expectations for the organisations they regulate.

Ultimately, adopting state-of-the-art cyber defences is crucial for ensuring that organisations are equipped with the best tools to combat new and fast-growing threats. Leading technical authorities, such as the UK National Cyber Security Centre (NCSC), recognise that adoption of AI-powered cyber defences will offset the increased volume and impact of AI on cyber threats.⁵

State of the art cybersecurity in the context of NIS2

1. Continuous monitoring

Continuous monitoring is required to protect an increasingly complex attack surface from attackers.

First, organisations' attack surfaces have expanded following the widespread adoption of hybrid or cloud infrastructures and the increased adoption of connected Internet of Things (IoT) devices.⁶ This exponential growth creates a complex digital environment for organisations, making it difficult for security teams to track all internet-facing assets and identify potential vulnerabilities.

Second, with the significant increase in the speed and sophistication of cyber-attacks, organisations face a greater need to detect security threats and non-compliance issues in real-time.

Continuous monitoring, defined by the U.S. National Institute of Standards and Technology (NIST) as the ability to maintain “ongoing awareness of information security, vulnerabilities, and threats to support organizational risk management decisions,”⁷ has therefore become a cornerstone of an effective cybersecurity strategy. By implementing continuous monitoring, organisations can ensure a real-time understanding of their attack surface and that new external assets are promptly accounted for. For instance, Spain’s technical guidelines for regulation, as set forth by the National Security Framework (Royal Decree 311/2022), highlight the importance of adopting continuous monitoring to detect anomalous activities or behaviours and to ensure timely responses to potential threats (article 10).⁸

This can be achieved through the following means:

All assets that form part of an organisation's estate, both known and unknown, must be identified and continuously monitored for current and emerging risks. Germany’s BSI mandates the continuous monitoring of all protocol and logging data in real-time (requirement #110).⁹ This should be conducted alongside any regular scans to detect unknown devices or cases of shadow IT, or the use of unauthorised or unmanaged applications and devices within an organisation, which can expose internet-facing assets to unmonitored risks. Continuous monitoring can therefore help identify potential risks and high-impact vulnerabilities within an organisation's digital estate and eliminate potential gaps and blind spots.

Organisations looking to implement more efficient continuous monitoring strategies may turn to automation, but, as the BSI notes, it is important for responsible parties to be immediately warned if an alert is raised (reference 110).¹⁰ Following the BSI’s recommendations, the alert must be examined and, if necessary, contained within a short period of time corresponding with the analysis of the risk at hand.

Finally, risk scoring and vulnerability mapping are also essential parts of this process. Looking across the Atlantic, the US’ National Institute of Standards and Technology (NIST) defines continuous monitoring as “maintaining ongoing awareness of information security, vulnerabilities, and threats to support organizational risk management decisions”.¹¹ Continuous monitoring helps identify potential risks and significant vulnerabilities within an organisation's digital assets, fostering a dynamic understanding of risk. By doing so, risk scoring and vulnerability mapping allows organisations to prioritise the risks associated with their most critically exposed assets.

2. Correlation of incidents across your entire environment

Viewing and correlating incident alerts when working with different platforms and tools poses significant challenges to SecOps teams. Security professionals often struggle to cross-reference alerts efficiently, which can lead to potential delays in identifying and responding to threats. The complexity of managing multiple sources of information can overwhelm teams, making it difficult to maintain a cohesive understanding of the security landscape.

This fragmentation underscores the need for a centralised approach that provides a "single pane of glass" view of all cybersecurity alerts. These systems streamline the process of monitoring and responding to incidents, enabling security teams to act more swiftly and effectively. By consolidating alerts into a unified interface, organisations can enhance their ability to detect and mitigate threats, ultimately improving their overall security posture.

To achieve consolidation, organisations should consider the role automation can play when reviewing and correlating incidents. This is reflected in Spain’s technical guidelines for national security regulations regarding the requirements for the “recording of activity” (reinforcement R5).¹² Specifically, the guidelines state that:

"The system shall implement tools to analyses and review system activity and audit information, in search of possible or actual security compromises. An automatic system for collection of records, correlation of events and automatic response to them shall be available”.¹³

Similarly, the German guidelines stress that automated central analysis is essential not only for recording all protocol and logging data generated within the system environment but also to ensure that the data is correlated to ensure that security-relevant processes are visible (article 115).¹⁴

Correlating disparate incidents and alerts is especially important when considering the increased connectivity between IT and OT environments driven by business and functional requirements. Indeed, organisations that believe they have air-gapped systems are now becoming aware of points of IT/OT convergence within their systems. It is therefore crucial for organisations managing both IT and OT environments to be able to visualise and secure devices across all IT and OT protocols in real-time to identify potential spillovers.

By consolidating data into a centralised system, organisations can achieve a more resilient posture. This approach exposes and eliminates gaps between people, processes, and technology before they can be exploited by malicious actors. As seen in the German and Spanish guidelines, a unified view of security alerts not only enhances the efficacy of threat detection and response but also ensures comprehensive visibility and control over the organisation's cybersecurity posture.

3. Detection of anomalous activity

Recent research highlights the emergence of a "new normal" in cybersecurity, marked by an increase in zero-day vulnerabilities. Indeed, for the first time since sharing their annual list, the Five Eyes intelligence alliance reported that in 2023, the majority of the most routinely exploited vulnerabilities were initially exploited as zero-days.¹⁵

To effectively combat these advanced threats, policymakers, industry and academic stakeholders alike recognise the importance of anomaly-based techniques to detect both known and unknown attacks.

As AI-enabled threats become more prevalent,¹⁶ traditional cybersecurity methods that depend on lists of "known bads" are proving inadequate against rapidly evolving and sophisticated attacks. These legacy approaches are limited because they can only identify threats that have been previously encountered and cataloged. However, cybercriminals are constantly developing new, never-before-seen threats, such as signatureless ransomware or living off the land techniques, which can easily bypass these outdated defences.

The importance of anomaly detection in cybersecurity can be found in Spain’s technical guidelines, which states that “tools shall be available to automate the prevention and response process by detecting and identifying anomalies¹⁷” (reinforcement R4 prevention and automatic response to "incident management”).

Similarly, the UK NCSC’s Cyber Assessment Framework (CAF) highlights how anomaly-based detection systems are capable of detecting threats that “evade standard signature-based security solutions” (Principle C2 - Proactive Security Event Discovery¹⁸). The CAF’s C2 principle further outlines:

“The science of anomaly detection, which goes beyond using pre-defined or prescriptive pattern matching, is a challenging area. Capabilities like machine learning are increasingly being shown to have applicability and potential in the field of intrusion detection.”¹⁹

By leveraging machine learning and multi-layered AI techniques, organisations can move away from static rules and signatures, adopting a more behavioural approach to identifying and containing risks. This shift not only enhances the detection of emerging threats but also provides a more robust defence mechanism.

A key component of this strategy is behavioral zero trust, which focuses on identifying unauthorized and out-of-character attempts by users, devices, or systems. Implementing a robust procedure to verify each user and issuing the minimum required access rights based on their role and established patterns of activity is essential. Organisations should therefore be encouraged to follow a robust procedure to verify each user and issue the minimum required access rights based on their role and expected or established patterns of activity. By doing so, organisations can stay ahead of emerging threats and embrace a more dynamic and resilient cybersecurity strategy.

4. Autonomous response

The speed at which cyber-attacks occur means that defenders must be equipped with tools that match the sophistication and agility of those used by attackers. Autonomous response tools are thus essential for modern cyber defence, as they enable organisations to respond to both known and novel threats in real time.

These tools leverage a deep contextual and behavioral understanding of the organisation to take precise actions, effectively containing threats without disrupting business operations.

To avoid unnecessary business disruptions and maintain robust security, especially in more sensitive networks such as OT environments, it is crucial for organisations to determine the appropriate response depending on their environment. This can range from taking autonomous and native actions, such as isolating or blocking devices, or integrating their autonomous response tool with firewalls or other security tools to taking customized actions.

Autonomous response solutions should also use a contextual understanding of the business environment to make informed decisions, allowing them to contain threats swiftly and accurately. This means that even as cyber-attacks evolve and become more sophisticated, organisations can maintain continuous protection without compromising operational efficiency.

Indeed, research into the adoption of autonomous cyber defences points to the importance of implementing “organisation-specific" and “context-informed” approaches.²⁰ To decide the appropriate level of autonomy for each network action, it is argued, it is essential to use evidence-based risk prioritisation that is customised to the specific operations, assets, and data of individual enterprises.²¹

By adopting autonomous response solutions, organisations can ensure their defences are as dynamic and effective as the threats they face, significantly enhancing their overall security posture.

5. Proactive cyber resilience

Adopting a proactive approach to cybersecurity is crucial for organisations aiming to safeguard their operations and reputation. By hardening their defences enough so attackers are unable to target them effectively, organisations can save significant time and money. This proactive stance helps reduce business disruption, reputational damage, and the need for lengthy, resource-intensive incident responses.

Proactive cybersecurity incorporates many of the strategies outlined above. This can be seen in a recent survey of information technology practitioners, which outlines four components of a proactive cybersecurity culture: (1) visibility of corporate assets, (2) leveraging intelligent and modern technology, (3) adopting consistent and comprehensive training methods and (4) implementing risk response procedures.²² To this, we may also add continuous monitoring which allows organisations to understand the most vulnerable and high-value paths across their architectures, allowing them to secure their critical assets more effectively.

Alongside these components, a proactive cyber strategy should be based on a combined business context and knowledge, ensuring that security measures are aligned with the organisation's specific needs and priorities.

This proactive approach to cyber resilience is reflected in Spain’s technical guidance (article 8.2): “Prevention measures, which may incorporate components geared towards deterrence or reduction of the exposure surface, should eliminate or reduce the likelihood of threats materializing.”²³ It can also be found in the NCSC’s CAF, which outlines how organisations can achieve “proactive attack discovery” (see Principle C2).²⁴ Likewise, Belgium’s NIS2 transposition guidelines mandate the use of preventive measures to ensure the continued availability of services in the event of exceptional network failures (article 30).²⁵

Ultimately, a proactive approach to cybersecurity not only enhances protection but also lowers regulatory risk and supports the overall resilience and stability of the organisation.

Looking forward

The NIS2 Directive marked a significant regulatory milestone in strengthening cybersecurity across the EU.²⁶ Given the impact of emerging technologies, such as AI, on cybersecurity, it is to see that Member States are encouraged to promote the adoption of ‘state-of-the-art' cybersecurity across regulated entities.

In this blog, we have sought to translate what state-of-the-art cybersecurity may look like for organisations looking to enhance their cybersecurity posture. To do so, we have built on existing cybersecurity guidance, research and our own experience as an AI-cybersecurity company to outline five criteria: continuous monitoring, incident correlation, detection of anomalous activity, autonomous response, and proactive cyber resilience.

By embracing these principles and evolving cybersecurity practices in line with the state-of-the-art, organisations can comply with the NIS2 Directive while building a resilient cybersecurity posture capable of withstanding evolutions in the cyber threat landscape. Looking forward, it will be interesting to see how other jurisdictions embrace new technologies, such as AI, in solving the cybersecurity problem.

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