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September 4, 2024

What you need to know about FAA Security Protection Regulations 2024

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04
Sep 2024
This blog gives an overview of the proposed FAA regulations for safeguarding aviation systems and their cyber-physical networks. Read more to discover key points, challenges, and potential solutions for each use case.

Overview of FAA Rules 2024

Objective

The goal of the Federal Aviation Administration amended rules is to create new design standards that protect airplane systems from intentional unauthorized electronic interactions (IUEI), which can pose safety risks. The timely motivation for this goal is due to the ongoing trend in aircraft design, which features a growing integration of airplane, engine, and propeller systems, along with expanded connectivity to both internal and external data networks and services.

“This proposed rulemaking would impose new design standards to address cybersecurity threats for transport category airplanes, engines, and propellers. The intended effect of this proposed action is to standardize the FAA’s criteria for addressing cybersecurity threats, reducing certification costs and time while maintaining the same level of safety provided by current special conditions.” (1)

Background

Increasing integration of aircraft systems with internal and external networks raises cybersecurity vulnerability concerns.

Key vulnerabilities include:  

  • Field Loadable Software
  • Maintenance laptops
  • Public networks (e.g., Internet)
  • Wireless sensors
  • USB devices
  • Satellite communications
  • Portable devices and flight bags  

Requirements for Applicants

Applicants seeking design approval must:

  • Provide isolation or protection from unauthorized access
  • Prevent inadvertent or malicious changes to aircraft systems
  • Establish procedures to maintain cybersecurity protections

Purpose

“These changes would introduce type certification and continued airworthiness requirements to protect the equipment, systems, and networks of transport category airplanes, engines, and propellers against intentional unauthorized electronic interactions (IUEI)1 that could create safety hazards. Design approval applicants would be required to identify, assess, and mitigate such hazards, and develop Instructions for Continued Airworthiness (ICA) that would ensure such protections continue in service.” (1)

Key points:

  • Introduce new design standards to address cybersecurity threats for transport category airplanes, engines, and propellers.
  • Aim to reduce certification costs and time while maintaining safety levels similar to current special conditions

Applicant Responsibilities for Identifying, Assessing, and Mitigating IUEI Risks

The proposed rule requires applicants to safeguard airplanes, engines, and propellers from intentional unauthorized electronic interactions (IUEI). To do this, they must:

  1. Identify and assess risks: Find and evaluate any potential electronic threats that could harm safety.
  2. Mitigate risks: Take steps to prevent these threats from causing problems, ensuring the aircraft remain safe and functional.

Let’s break down each of the requirements:

Performing risk analysis

“For such identification and assessment of security risk, the applicant would be required to perform a security risk analysis to identify all threat conditions associated with the system, architecture, and external or internal interfaces.”(3)

Challenge

The complexity and variety of OT devices make it difficult and time-consuming to identify and associate CVEs with assets. Security teams face several challenges:

  • Prioritization Issues: Sifting through extensive CVE lists to prioritize efforts is a struggle.
  • Patch Complications: Finding corresponding patches is complicated by manufacturer delays and design flaws.
  • Operational Constraints: Limited maintenance windows and the need for continuous operations make it hard to address vulnerabilities, often leaving them unresolved for years.
  • Inadequate Assessments: Standard CVE assessments may not fully capture the risks associated with increased connectivity, underscoring the need for a contextualized risk assessment approach.

This highlights the need for a more effective and tailored approach to managing vulnerabilities in OT environments.

Assessing severity of risks

“The FAA would expect such risk analysis to assess the severity of the effect of threat conditions on associated assets (system, architecture, etc.), consistent with the means of compliance the applicant has been using to meet the FAA’s special conditions on this topic.” (3)

Challenge

As shown by the MITRE ATT&CK® Techniques for ICS matrices, threat actors can exploit many avenues beyond just CVEs. To effectively defend against these threats, security teams need a broader perspective, considering lateral movement and multi-stage attacks.

Challenges in Vulnerability Management (VM) cycles include:

  • Initiation: VM cycles often start with email updates from the Cybersecurity and Infrastructure Security Agency (CISA), listing new CVEs from the NIST database.
  • Communication: Security practitioners must survey and forward CVE lists to networking teams at facilities that might be running the affected assets. Responses from these teams are inconsistent, leading vulnerability managers to push patches that may not fit within limited maintenance windows.
  • Asset Tracking: At many OT locations, determining if a company is running a specific firmware version can be extremely time-consuming. Teams often rely on spreadsheets and must perform manual checks by physically visiting production floors ("sneaker-netting").
  • Coordination: Plant engineers and centralized security teams must exchange information to validate asset details and manually score vulnerabilities, further complicating and delaying remediation efforts.

Determine likelihood of exploitation

“Such assessment would also need to analyze these vulnerabilities for the likelihood of exploitation.” (3)

Challenge

Even when a vulnerability is identified, its actual impact can vary significantly based on the specific configurations, processes, and technologies in use within the organization. This creates challenges for OT security practitioners:

  • Risk Assessment: Accurately assessing and prioritizing the risk becomes difficult without a clear understanding of how the vulnerability affects their unique systems.
  • Decision-Making: Practitioners may struggle to determine whether immediate action is necessary, balancing the risk of operational downtime against the need for security.
  • Potential Consequences: This uncertainty can lead to either leaving critical systems exposed or causing unnecessary disruptions by applying measures that aren't truly needed.

This complexity underscores the challenge of making informed, timely decisions in OT security environments.

Vulnerability mitigation

“The proposed regulation would then require each applicant to 'mitigate' the vulnerabilities, and the FAA expects such mitigation would occur through the applicant’s installation of single or multilayered protection mechanisms or process controls to ensure functional integrity, i.e., protection.” (3)

Challenge

OT security practitioners face a constant challenge in balancing security needs with the requirement to maintain operational uptime. In many OT environments, especially in critical infrastructure, applying security patches can be risky:

  • Risk of Downtime: Patching can disrupt essential processes, leading to significant financial losses or even safety hazards.
  • Operational Continuity vs. Security: Practitioners often prioritize operational continuity, sometimes delaying timely security updates.
  • Alternative Strategies: To protect systems without direct patching, they must implement compensating controls, further complicating security efforts.

This delicate balance between security and uptime adds complexity to the already challenging task of securing OT environments.

Establishing procedures/playbooks

“Finally, each applicant would be required to include the procedures within their instructions for continued airworthiness necessary to maintain such protections.” (3)

Challenge

SOC teams typically have a lag before their response, leading to a higher dwell time and bigger overall costs. On average, only 15% of the total cost of ransomware is affiliated with the ransom itself (2). The rest is cost from business interruption. This means it's crucial that organizations can respond and recover earlier. 

Darktrace / OT enabling compliance and enhanced cybersecurity

Darktrace's OT solution addresses the complex challenges of cybersecurity compliance in Operational Technology (OT) environments by offering a comprehensive approach to risk management and mitigation.

Key risk management features include:

  • Contextualized Risk Analysis: Darktrace goes beyond traditional vulnerability scoring, integrating IT, OT, and CVE data with MITRE techniques to map critical attack paths. This helps in identifying and prioritizing vulnerabilities based on their exposure, difficulty of exploitation, and network impact.
  • Guidance on Remediation: When patches are unavailable, Darktrace provides alternative strategies to bolster defenses around vulnerable assets, ensuring unpatched systems are not left exposed—a critical need in OT environments where operational continuity is essential.
  • AI-Driven Adaptability: Darktrace's AI continuously adapts to your organization as it grows; refining incident response playbooks bespoke to your environment in real-time. This ensures that security teams have the most up-to-date, tailored strategies, reducing response times and minimizing the impact of security incidents.

Ready to learn more?  

Darktrace / OT doesn’t just offer risk management capabilities. It is the only solution  
that leverages Self-Learning AI to understand your normal business operations, allowing you to detect and stop insider, known, unknown, and zero-day threats at scale.  

Dive deeper into how Darktrace / OT secures critical infrastructure organizations with in-depth insights on its advanced capabilities. Download the Darktrace / OT Solution Brief to explore the technology behind its AI-driven protection and see how it can transform your OT security strategy.

Curious about how Darktrace / OT enhances aviation security? Explore our customer story on Brisbane Airport to see how our solution is transforming security operations in the aviation sector.  

References

  1. https://research-information.bris.ac.uk/ws/portalfiles/portal/313646831/Catch_Me_if_You_Can.pdf
  1. https://www.bleepingcomputer.com/news/security/ransom-payment-is-roughly-15-percent-of-the-total-cost-of-ransomware-attacks/
  1. https://public-inspection.federalregister.gov/2024-17916.pdf?mod=djemCybersecruityPro&tpl=cs
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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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Daniel Simonds
Director of Operational Technology
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February 18, 2025

Unifying IT & OT With AI-Led Investigations for Industrial Security

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As industrial environments modernize, IT and OT networks are converging to improve efficiency, but this connectivity also creates new attack paths. Previously isolated OT systems are now linked to IT and cloud assets, making them more accessible to attackers.

While organizations have traditionally relied on air gaps, firewalls, data diodes, and access controls to separate IT and OT, these measures alone aren’t enough. Threat actors often infiltrate IT/Enterprise networks first then exploit segmentation, compromising credentials, or shared IT/OT systems to move laterally, escalate privileges, and ultimately enter the OT network.

To defend against these threats, organizations must first ensure they have complete visibility across IT and OT environments.

Visibility: The first piece of the puzzle

Visibility is the foundation of effective industrial cybersecurity, but it’s only the first step. Without visibility across both IT and OT, security teams risk missing key alerts that indicate a threat targeting OT at their earliest stages.

For Attacks targeting OT, early stage exploits often originate in IT environments, adversaries perform internal reconnaissance among other tactics and procedures but then laterally move into OT first affecting IT devices, servers and workstations within the OT network. If visibility is limited, these threats go undetected. To stay ahead of attackers, organizations need full-spectrum visibility that connects IT and OT security, ensuring no early warning signs are missed.

However, visibility alone isn’t enough. More visibility also means more alerts, this doesn’t just make it harder to separate real threats from routine activity, but bogs down analysts who have to investigate all these alerts to determine their criticality.

Investigations: The real bottleneck

While visibility is essential, it also introduces a new challenge: Alert fatigue. Without the right tools, analysts are often occupied investigating alerts with little to no context, forcing them to manually piece together information and determine if an attack is unfolding. This slows response times and increases the risk of missing critical threats.

Figure 1: Example ICS attack scenario

With siloed visibility across IT and OT each of these events shown above would be individually alerted by a detection engine with little to no context nor correlation. Thus, an analyst would have to try to piece together these events manually. Traditional security tools struggle to keep pace with the sophistication of these threats, resulting in an alarming statistic: less than 10% of alerts are thoroughly vetted, leaving organizations vulnerable to undetected breaches. As a result, incidents inevitably follow.

Darktrace’s Cyber AI Analyst uses AI-led investigations to improve workflows for analysts by automatically correlating alerts wherever they occur across both IT and OT. The multi-layered AI engine identifies high-priority incidents, and provides analysts with clear, actionable insights, reducing noise and highlighting meaningful threats. The AI significantly alleviates workloads, enabling teams to respond faster and more effectively before an attack escalates.

Overcoming organizational challenges across IT and OT

Beyond technical challenges like visibility and alert management, organizational dynamics further complicate IT-OT security efforts. Fundamental differences in priorities, workflows, and risk perspectives create challenges that can lead to misalignment between teams:

Non-transferable practices: IT professionals might assume that cybersecurity practices from IT environments can be directly applied to OT environments. This can lead to issues, as OT systems and workflows may not handle IT security processes as expected. It's crucial to recognize and respect the unique requirements and constraints of OT environments.

Segmented responsibilities: IT and OT teams often operate under separate organizational structures, each with distinct priorities, goals, and workflows. While IT focuses on data security, network integrity, and enterprise applications, OT prioritizes uptime, reliability, and physical processes.

Different risk perspectives: While IT teams focus on preventing cyber threats and regulatory violations, OT teams prioritize uptime and operational reliability making them drawn towards asset inventory tools that provide no threat detection capability.

Result: A combination of disparate and ineffective tools and misaligned teams can make any progress toward risk reduction at an organization seem impossible. The right tools should be able to both free up time for collaboration and prompt better communication between IT and OT teams where it is needed. However, different size operations structure their IT and OT teams differently which impacts the priorities for each team.

In real-world scenarios, small IT teams struggle to manage security across both IT and OT, while larger organizations with OT security teams face alert fatigue and numerous false positives slowing down investigations and hindering effective communication with the IT security teams.

By unifying visibility and investigations, Darktrace / OT helps organizations of all sizes detect threats earlier, streamline workflows, and enhance security across both IT and OT environments. The following examples illustrate how AI-driven investigations can transform security operations, improving detection, investigation, and response.

Before and after AI-led investigation

Before: Small manufacturing company

At a small manufacturing company, a 1-3 person IT team juggles everything from email security to network troubleshooting. An analyst might see unusual traffic through the firewall:

  • Unusual repeated outbound traffic from an IP within their OT network destined to an unidentifiable external IP.

With no dedicated OT security tools and limited visibility into the industrial network, they don’t know what the internal device in question is, if it is beaconing to a malicious external IP, and what it may be doing to other devices within the OT network. Without a centralized dashboard, they must manually check logs, ask operators about changes, and hunt for anomalies across different systems.

After a day of investigation, they concluded the traffic was not to be expected activity. They stop production within their smaller OT network, update their firewall rules and factory reset all OT devices and systems within the blast radius of the IP device in question.

After: Faster, automated response with Cyber AI Analyst

With Darktrace / OT and Cyber AI Analyst, the IT team moves from reactive, manual investigations to proactive, automated threat detection:

  • Cyber AI Analyst connects alerts across their IT and OT infrastructure temporally mapping them to attack frameworks and provides contextual analysis of how alerts are linked, revealing in real time attackers attempting lateral movement from IT to OT.
  • A human-readable incident report explains the full scope of the incident, eliminating hours of manual investigation.
  • The team is faster to triage as they are led directly to prioritized high criticality alerts, now capable of responding immediately instead of wasting valuable time hunting for answers.

By reducing noise, providing context, and automating investigations, Cyber AI Analyst transforms OT security, enabling small IT teams to detect, understand, and respond to threats—without deep OT cybersecurity expertise.

Before: Large critical infrastructure organization

In large critical infrastructure operations, OT and IT teams work in separate silos. The OT security team needs to quickly assess and prioritize alerts, but their system floods them with notifications:

  • Multiple new device connected to the ICS network alerts
  • Multiple failed logins to HMI detected
  • Multiple Unusual Modbus/TCP commands detected
  • Repeated outbound OT traffic to IT destinations

At first glance, these alerts seem important, but without context, it’s unclear whether they indicate a routine error, a misconfiguration, or an active cyber-attack. They might ask:

  • Are the failed logins just a mistake, or a brute-force attempt?
  • Is the outbound traffic part of a scheduled update, or data exfiltration?

Without correlation across events, the engineer must manually investigate each one—checking logs, cross-referencing network activity, and contacting operators—wasting valuable time. Meanwhile, if it’s a coordinated attack, the adversary may already be disrupting operations.

After: A new workflow with Cyber AI Analyst

With Cyber AI Analyst, the OT security team gets clear, automated correlation of security events, making investigations faster and more efficient:

  • Automated correlation of OT threats: Instead of isolated alerts, Cyber AI Analyst stitches together related events, providing a single, high-confidence incident report that highlights key details.
  • Faster time to meaning: The system connects anomalous behaviors (e.g., failed logins, unusual traffic from an HMI, and unauthorized PLC modifications) into a cohesive narrative, eliminating hours of manual log analysis.
  • Prioritized and actionable alerts: OT security receives clear, ranked incidents, immediately highlighting what matters most.
  • Rapid threat understanding: Security teams know within minutes whether an event is a misconfiguration or a cyber-attack, allowing for faster containment.

With Cyber AI Analyst, large organizations cut through alert noise, accelerate investigations, and detect threats faster—without disrupting OT operations.

An AI-led approach to industrial cybersecurity

Security vendors with a primary focus on IT may lack insight into OT threats. Even OT-focused vendors have limited visibility into IT device exploitation within OT networks, leading to failed ability to detect early indicators of compromise. A comprehensive solution must account for the unique characteristics of various OT environments.

In a world where industrial security is no longer just about protecting OT but securing the entire digital-physical ecosystem as it interacts with the OT network, Darktrace / OT is an AI-driven solution that unifies visibility across IT, IoT and OT, Cloud into one cohesive defense strategy.

Whether an attack originates from an external breach, an insider threat, a supply chain compromise, in the Cloud, OT, or IT domains Cyber AI Analyst ensures that security teams see the full picture - before disruption occurs.

Learn more about Darktrace / OT 

  • Unify IT and OT security under a single platform, ensuring seamless communication and protection for all interconnected devices.
  • Maintain uptime with AI-driven threat containment, stopping attacks without disrupting production.
  • Mitigate risks with or without patches, leveraging MITRE mitigations to reduce attack opportunities.

Download the solution brief to see how Darktrace secures critical infrastructure.

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About the author
Daniel Simonds
Director of Operational Technology

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February 13, 2025

Why Darktrace / EMAIL excels against APTs

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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

Discover the most advanced cloud-native AI email security solution to protect your domain and brand while preventing phishing, novel social engineering, business email compromise, account takeover, and data loss.

  • Gain up to 13 days of earlier threat detection and maximize ROI on your current email security
  • Experience 20-25% more threat blocking power with Darktrace / EMAIL
  • Stop the 58% of threats bypassing traditional email security

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

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About the author
Carlos Gray
Product Manager
Your data. Our AI.
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