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September 22, 2025

Understanding the Canadian Critical Cyber Systems Protection Act

The Canadian federal Government introduced Bill C-8 which would enact the Critical Cyber Systems Protection Act (CCSPA). The CCSPA will formalize baseline cybersecurity duties for operators in federally regulated critical sectors.
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22
Sep 2025

Introduction: The Canadian Critical Cyber Systems Protection Act

On 18 June 2025, the Canadian federal Government introduced Bill C-8 which, if adopted following completion of the legislative process, will enact the Critical Cyber Systems Protection Act (CCSPA) and give Canada its first federal, cross-sector and legally binding cybersecurity regime for designated critical infrastructure providers. As of August 2025, the Bill has completed first reading and stands at second reading in the Canadian House of Commons.

Political context

The measure revives most of the stalled 2022 Bill C-26 “An Act Respecting Cyber Security” which “died on Paper” when Parliament was prorogued in January 2025, in the wake of former Prime Minister Justin Trudeau’s resignation.

The new government, led by Mark Carney since March 2025, has re-tabled the package with the same two-part structure: (1) amendments to the Telecommunications Act that enable security directions to telecoms; and (2) a new CCSPA setting out mandatory cybersecurity duties for designated operators. This blog focuses on the latter.

If enacted, Canada will join fellow Five Eyes partners such as the United Kingdom and Australia, which already impose statutory cyber-security duties on operators of critical national infrastructure.

The case for new cybersecurity legislation in Canada

The Canadian cyber threat landscape has expanded. The country's national cyber authority, the Canadian Centre for Cybersecurity (Cyber Centre), recently assessed that the number of cyber incidents has “sharply increased” in the last two years, as has the severity of those incidents, with essential services providers among the targets. Likewise, in its 2025-2026 National Cyber Threat Assessment, the Cyber Centre warned that AI technologies are “amplifying cyberspace threats” by lowering barriers to entry, improving the speed and sophistication of social-engineering attacks and enabling more precise operations.

This context mirrors what we are seeing globally: adversaries, including state actors, are taking advantage of the availability and sophistication of AI tools, which they have leverage to amplify the effectiveness of their operations. In this increasingly complex landscape, regulation must keep pace and evolve in step with the risk.

What the Canadian Critical Cyber Systems Protection Act aims to achieve

  • If enacted, the CCSPA will apply to operators in federally regulated critical infrastructure sectors which are vital to national security and public safety, as further defined in “Scope” below (the “Regulated Entities”), to adopt and comply with a minimum standard of cybersecurity duties (further described below)  which align with those its Five Eyes counterparts are already adhering to.

Who does the CCSPA apply to

The CCSPA would apply to designated operators that deliver services or systems within federal jurisdiction in the following priority areas:

  • telecommunications services
  • interprovincial or international pipeline and power line systems, nuclear energy systems, transportation systems
  • banking and clearing  
  • settlement systems

The CCSPA would also grant the Governor in Council (Federal Cabinet) with powers to add or remove entities in scope via regulation.

Scope of the CCSPA

The CCSPA introduces two key instruments:

First, it strengthens cyber threat information sharing between responsible ministers, sector regulators, and the Communications Security Establishment (through the Cyber Centre).

Second, it empowers the Governor in Council (GIC) to issue Cyber Security Directions (CSDs) - binding orders requiring a designated operator to implement specified measures to protect a critical cyber system within defined timeframes.

CSDs may be tailored to an individual operator or applied to a class of operators and can address technology, process, or supplier risks. To safeguard security and commercial confidentiality, the CCSPA restricts disclosure of the existence or content of a CSD except as necessary to carry it out.

Locating decision-making with the GIC ensures that CSDs are made with a cross-government view that weighs national security, economic priorities and international agreement.

New obligations for designated providers

The CCSPA would impose key cybersecurity compliance and obligations on designated providers. As it stands, this includes:

  1. Establishing and maintaining cybersecurity programs: these will need to be comprehensive, proportionate and developed proactively. Once implemented, they will need to be continuously reviewed
  2. Mitigating supply chain risks: Regulated Entities will be required to assess their third-party products and services by conducting a supply chain analysis, and take active steps to mitigate any identified risks
  3. Reporting incidents:  Regulated Entities will need to be more transparent with their reporting, by making the Communications Security Establishment (CSE) aware of any incident which has, or could potentially have, an impact on a critical system. The reports must be made within specific timelines, but in any event within no more than 72 hours;
  4. Compliance with cybersecurity directions:  the government will, under the CCSPA, have the authority to issue cybersecurity directives in an effort to remain responsive to emerging threats, which Regulated Entities will be required to follow once issued
  5. Record keeping: this shouldn’t be a surprise to many of those Regulated Entities which fall in scope, which are already likely to be subject to record keeping requirements. Regulated Entities should expect to be maintaining records and conducting audits of their systems and processes against the requirements of the CCSPA

It should be noted, however, that this may be subject to change, so Regulated Entities should keep an eye on the progress of the Bill as it makes its way through parliament.

Enforcement of the Act would be carried out by sector-specific regulators identified in the Act such as the Office of the Superintendent of Financial Institutions, Minister of Transport, Canada Energy Regulator, Canadian Nuclear Safety Commission and the Ministry of Industry.

What are the penalties for CCSPA non-compliance?

When assessing the penalties associated with non-compliance with the requirements of the CCSPA, it is clear that such non-compliance will be taken seriously, and the severity of the penalties follows the trend of those applied by the European Union to key pieces of EU legislation. The “administrative monetary penalties” (AMPs) set by regulation could see fines being applied of up to C$1 million for individuals and up to C$15 million for organizations.

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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.
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October 20, 2025

Salty Much: Darktrace’s view on a recent Salt Typhoon intrusion

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What is Salt Typhoon?

Salt Typhoon represents one of the most persistent and sophisticated cyber threats targeting global critical infrastructure today. Believed to be linked to state-sponsored actors from the People’s Republic of China (PRC), this advanced persistent threat (APT) group has executed a series of high-impact campaigns against telecommunications providers, energy networks, and government systems—most notably across the United States.

Active since at least 2019, the group—also tracked as Earth Estries, GhostEmperor, and UNC2286—has demonstrated advanced capabilities in exploiting edge devices, maintaining deep persistence, and exfiltrating sensitive data across more than 80 countries. While much of the public reporting has focused on U.S. targets, Salt Typhoon’s operations have extended into Europe, the Middle East, and Africa (EMEA) where it has targeted telecoms, government entities, and technology firms. Its use of custom malware and exploitation of high-impact vulnerabilities (e.g., Ivanti, Fortinet, Cisco) underscores the strategic nature of its campaigns, which blend intelligence collection with geopolitical influence [1].

Leveraging zero-day exploits, obfuscation techniques, and lateral movement strategies, Salt Typhoon has demonstrated an alarming ability to evade detection and maintain long-term access to sensitive environments. The group’s operations have exposed lawful intercept systems, compromised metadata for millions of users, and disrupted essential services, prompting coordinated responses from intelligence agencies and private-sector partners worldwide. As organizations reassess their threat models, Salt Typhoon serves as a stark reminder of the evolving nature of nation-state cyber operations and the urgent need for proactive defense strategies.

Darktrace’s coverage

In this case, Darktrace observed activity in a European telecommunications organisation consistent with Salt Typhoon’s known tactics, techniques and procedures (TTPs), including dynamic-link library (DLL) sideloading and abuse of legitimate software for stealth and execution.

Initial access

The intrusion likely began with exploitation of a Citrix NetScaler Gateway appliance in the first week of July 2025. From there, the actor pivoted to Citrix Virtual Delivery Agent (VDA) hosts in the client’s Machine Creation Services (MCS) subnet. Initial access activities in the intrusion originated from an endpoint potentially associated with the SoftEther VPN service, suggesting infrastructure obfuscation from the outset.

Tooling

Darktrace subsequently observed the threat actor delivering a backdoor assessed with high confidence to be SNAPPYBEE (also known as Deed RAT) [2][3] to multiple Citrix VDA hosts. The backdoor was delivered to these internal endpoints as a DLL alongside legitimate executable files for antivirus software such as Norton Antivirus, Bkav Antivirus, and IObit Malware Fighter. This pattern of activity indicates that the attacker relied on DLL side-loading via legitimate antivirus software to execute their payloads. Salt Typhoon and similar groups have a history of employing this technique [4][5], enabling them to execute payloads under the guise of trusted software and bypassing traditional security controls.

Command-and-Control (C2)

The backdoor delivered by the threat actor leveraged LightNode VPS endpoints for C2, communicating over both HTTP and an unidentified TCP-based protocol. This dual-channel setup is consistent with Salt Typhoon’s known use of non-standard and layered protocols to evade detection. The HTTP communications displayed by the backdoor included POST requests with an Internet Explorer User-Agent header and Target URI patterns such as “/17ABE7F017ABE7F0”. One of the C2 hosts contacted by compromised endpoints was aar.gandhibludtric[.]com (38.54.63[.]75), a domain recently linked to Salt Typhoon [6].

Detection timeline

Darktrace produced high confidence detections in response to the early stages of the intrusion, with both the initial tooling and C2 activities being strongly covered by both investigations by Darktrace Cyber AI AnalystTM investigations and Darktrace models. Despite the sophistication of the threat actor, the intrusion activity identified and remediated before escalating beyond these early stages of the attack, with Darktrace’s timely high-confidence detections likely playing a key role in neutralizing the threat.

Cyber AI Analyst observations

Darktrace’s Cyber AI Analyst autonomously investigated the model alerts generated by Darktrace during the early stages of the intrusion. Through its investigations, Cyber AI Analyst discovered the initial tooling and C2 events and pieced them together into unified incidents representing the attacker’s progression.

Cyber AI Analyst weaved together separate events from the intrusion into broader incidents summarizing the attacker’s progression.
Figure 1: Cyber AI Analyst weaved together separate events from the intrusion into broader incidents summarizing the attacker’s progression.

Conclusion

Based on overlaps in TTPs, staging patterns, infrastructure, and malware, Darktrace assesses with moderate confidence that the observed activity was consistent with Salt Typhoon/Earth Estries (ALA GhostEmperor/UNC2286). Salt Typhoon continues to challenge defenders with its stealth, persistence, and abuse of legitimate tools. As attackers increasingly blend into normal operations, detecting behavioral anomalies becomes essential for identifying subtle deviations and correlating disparate signals. The evolving nature of Salt Typhoon’s tradecraft, and its ability to repurpose trusted software and infrastructure, ensures it will remain difficult to detect using conventional methods alone. This intrusion highlights the importance of proactive defense, where anomaly-based detections, not just signature matching, play a critical role in surfacing early-stage activity.

Credit to Nathaniel Jones (VP, Security & AI Strategy, FCISO), Sam Lister (Specialist Security Researcher), Emma Foulger (Global Threat Research Operations Lead), Adam Potter (Senior Cyber Analyst)

Edited by Ryan Traill (Analyst Content Lead)

Appendices

Indicators of Compromise (IoCs)

IoC-Type-Description + Confidence

89.31.121[.]101 – IP Address – Possible C2 server

hxxp://89.31.121[.]101:443/WINMM.dll - URI – Likely SNAPPYBEE download

b5367820cd32640a2d5e4c3a3c1ceedbbb715be2 - SHA1 – Likely SNAPPYBEE download

hxxp://89.31.121[.]101:443/NortonLog.txt - URI - Likely DLL side-loading activity

hxxp://89.31.121[.]101:443/123.txt - URI - Possible DLL side-loading activity

hxxp://89.31.121[.]101:443/123.tar - URI - Possible DLL side-loading activity

hxxp://89.31.121[.]101:443/pdc.exe - URI - Possible DLL side-loading activity

hxxp://89.31.121[.]101:443//Dialog.dat - URI - Possible DLL side-loading activity

hxxp://89.31.121[.]101:443/fltLib.dll - URI - Possible DLL side-loading activity

hxxp://89.31.121[.]101:443/DisplayDialog.exe - URI - Possible DLL side-loading activity

hxxp://89.31.121[.]101:443/DgApi.dll - URI - Likely DLL side-loading activity

hxxp://89.31.121[.]101:443/dbindex.dat - URI - Likely DLL side-loading activity

hxxp://89.31.121[.]101:443/1.txt - URI - Possible DLL side-loading activity

hxxp://89.31.121[.]101:443/imfsbDll.dll – Likely DLL side-loading activity

hxxp://89.31.121[.]101:443/imfsbSvc.exe - URI – Likely DLL side-loading activity

aar.gandhibludtric[.]com – Hostname – Likely C2 server

38.54.63[.]75 – IP – Likely C2 server

156.244.28[.]153 – IP – Possible C2 server

hxxp://156.244.28[.]153/17ABE7F017ABE7F0 - URI – Possible C2 activity

MITRE TTPs

Technique | Description

T1190 | Exploit Public-Facing Application - Citrix NetScaler Gateway compromise

T1105 | Ingress Tool Transfer – Delivery of backdoor to internal hosts

T1665 | Hide Infrastructure – Use of SoftEther VPN for C2

T1574.001 | Hijack Execution Flow: DLL – Execution of backdoor through DLL side-loading

T1095 | Non-Application Layer Protocol – Unidentified application-layer protocol for C2 traffic

T1071.001| Web Protocols – HTTP-based C2 traffic

T1571| Non-Standard Port – Port 443 for unencrypted HTTP traffic

Darktrace Model Alerts during intrusion

Anomalous File::Internal::Script from Rare Internal Location

Anomalous File::EXE from Rare External Location

Anomalous File::Multiple EXE from Rare External Locations

Anomalous Connection::Possible Callback URL

Antigena::Network::External Threat::Antigena Suspicious File Block

Antigena::Network::Significant Anomaly::Antigena Significant Server Anomaly Block

Antigena::Network::Significant Anomaly::Antigena Controlled and Model Alert

Antigena::Network::Significant Anomaly::Antigena Alerts Over Time Block

Antigena::Network::External Threat::Antigena File then New Outbound Block  

References

[1] https://www.cisa.gov/news-events/cybersecurity-advisories/aa25-239a

[2] https://www.trendmicro.com/en_gb/research/24/k/earth-estries.html

[3] https://www.trendmicro.com/content/dam/trendmicro/global/en/research/24/k/earth-estries/IOC_list-EarthEstries.txt

[4] https://www.trendmicro.com/en_gb/research/24/k/breaking-down-earth-estries-persistent-ttps-in-prolonged-cyber-o.html

[5] https://lab52.io/blog/deedrat-backdoor-enhanced-by-chinese-apts-with-advanced-capabilities/

[6] https://www.silentpush.com/blog/salt-typhoon-2025/

The content provided in this blog is published by Darktrace for general informational purposes only and reflects our understanding of cybersecurity topics, trends, incidents, and developments at the time of publication. While we strive to ensure accuracy and relevance, the information is provided “as is” without any representations or warranties, express or implied. Darktrace makes no guarantees regarding the completeness, accuracy, reliability, or timeliness of any information presented and expressly disclaims all warranties.

Nothing in this blog constitutes legal, technical, or professional advice, and readers should consult qualified professionals before acting on any information contained herein. Any references to third-party organizations, technologies, threat actors, or incidents are for informational purposes only and do not imply affiliation, endorsement, or recommendation.

Darktrace, its affiliates, employees, or agents shall not be held liable for any loss, damage, or harm arising from the use of or reliance on the information in this blog.

The cybersecurity landscape evolves rapidly, and blog content may become outdated or superseded. We reserve the right to update, modify, or remove any content.

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Nathaniel Jones
VP, Security & AI Strategy, Field CISO

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October 15, 2025

How a Major Civil Engineering Company Reduced MTTR across Network, Email and the Cloud with Darktrace

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Asking more of the information security team

“What more can we be doing to secure the company?” is a great question for any cyber professional to hear from their Board of Directors. After successfully defeating a series of attacks and seeing the potential for AI tools to supercharge incoming threats, a UK-based civil engineering company’s security team had the answer: Darktrace.

“When things are coming at you at machine speed, you need machine speed to fight it off – it’s as simple as that,” said their Information Security Manager. “There were incidents where it took us a few hours to get to the bottom of what was going on. Darktrace changed that.”

Prevention was also the best cure. A peer organization in the same sector was still in business continuity measures 18 months after an attack, and the security team did not want to risk that level of business disruption.

Legacy tools were not meeting the team’s desired speed or accuracy

The company’s native SaaS email platform took between two and 14 days to alert on suspicious emails, with another email security tool flagging malicious emails after up to 24 days. After receiving an alert, responses often took a couple of days to coordinate. The team was losing precious time.

Beyond long detection and response times, the old email security platform was no longer performing: 19% of incoming spam was missed. Of even more concern: 6% of phishing emails reached users’ inboxes, and malware and ransomware email was also still getting through, with 0.3% of such email-borne payloads reaching user inboxes.

Choosing Darktrace

“When evaluating tools in 2023, only Darktrace had what I was looking for: an existing, mature, AI-based cybersecurity solution. ChatGPT had just come out and a lot of companies were saying ‘AI this’ and ‘AI that’. Then you’d take a look, and it was all rules- and cases-based, not AI at all,” their Information Security Manager.

The team knew that, with AI-enabled attacks on the horizon, a cybersecurity company that had already built, fielded, and matured an AI-powered cyber defense would give the security team the ability to fend off machine-speed attacks at the same pace as the attackers.

Darktrace accomplishes this with multi-layered AI that learns each organization’s normal business operations. With this detailed level of understanding, Darktrace’s Self-Learning AI can recognize unusual activity that may indicate a cyber-attack, and works to neutralize the threat with precise response actions. And it does this all at machine speed and with minimal disruption.

On the morning the team was due to present its findings, the session was cancelled – for a good reason. The Board didn’t feel further discussion was necessary because the case for Darktrace was so conclusive. The CEO described the Darktrace option as ‘an insurance policy we can’t do without’.

Saving time with Darktrace / EMAIL

Darktrace / EMAIL reduced the discovery, alert, and response process from days or weeks to seconds .

Darktrace / EMAIL automates what was originally a time-consuming and repetitive process. The team has recovered between eight and 10 working hours a week by automating much of this process using / EMAIL.

Today, Darktrace / EMAIL prevents phishing emails from reaching employees’ inboxes. The volume of hostile and unsolicited email fell to a third of its original level after Darktrace / EMAIL was set up.

Further savings with Darktrace / NETWORK and Darktrace / IDENTITY

Since its success with Darktrace / EMAIL, the company adopted two more products from the Darktrace ActiveAI Security Platform – Darktrace / NETWORK and Darktrace / IDENTITY.

These have further contributed to cost savings. An initial plan to build a 24/7 SOC would have required hiring and retaining six additional analysts, rather than the two that currently use Darktrace, costing an additional £220,000 per year in salary. With Darktrace, the existing analysts have the tools needed to become more effective and impactful.

An additional benefit: Darktrace adoption has lowered the company’s cyber insurance premiums. The security team can reallocate this budget to proactive projects.

Detection of novel threats provides reassurance

Darktrace’s unique approach to cybersecurity added a key benefit. The team’s previous tool took a rules-based approach – which was only good if the next attack featured the same characteristics as the ones on which the tool was trained.

“Darktrace looks for anomalous behavior, and we needed something that detected and responded based on use cases, not rules that might be out of date or too prescriptive,” their Information Security Manager. “Our existing provider could take a couple of days to update rules and signatures, and in this game, speed is of the essence. Darktrace just does everything we need - without delay.”

Where rules-based tools must wait for a threat to emerge before beginning to detect and respond to it, Darktrace identifies and protects against unknown and novel threats, speeding identification, response, and recovery, minimizing business disruption as a result.

Looking to the future

With Darktrace in place, the UK-based civil engineering company team has reallocated time and resources usually spent on detection and alerting to now tackle more sophisticated, strategic challenges. Darktrace has also equipped the team with far better and more regularly updated visibility into potential vulnerabilities.

“One thing that frustrates me a little is penetration testing; our ISO accreditation mandates a penetration test at least once a year, but the results could be out of date the next day,” their Information Security Manager. “Darktrace / Proactive Exposure Management will give me that view in real time – we can run it daily if needed - and that’s going to be a really effective workbench for my team.”

As the company looks to further develop its security posture, Darktrace remains poised to evolve alongside its partner.

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