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July 17, 2024

What you need to know about the new SEC Cybersecurity rules

In July 2023, the U.S. Securities and Exchange Commission (SEC) adopted new rules concerning cybersecurity incidents and disclosures. This blog describes the new rules and demonstrates how Darktrace can help organizations achieve compliance with these standards.
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.
Written by
Kendra Gonzalez Duran
Principal Analyst
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17
Jul 2024

What is new in 2023 to SEC cybersecurity rules?

Form 8-K Item 1.05: Requiring the timely disclosure of material cybersecurity incidents.

Regulation S-K item 106: requiring registrants’ annual reports on Form 10-K to address cybersecurity risk management, strategy, and governance processes.

Comparable disclosures are required for reporting foreign private issuers on Forms 6-K and 20-F respectively.

What is Form 8-K Item 1.05 SEC cybersecurity rules?

Form 8-K Item 1.05 requires the following to be reported within four business days from when an incident is determined to be “material” (1), unless extensions are granted by the SEC under certain qualifying conditions:

“If the registrant experiences a cybersecurity incident that is determined by the registrant to be material, describe the material aspects of the nature, scope, and timing of the incident, and the material impact or reasonably likely material impact on the registrant, including its financial condition and results of operations.” (2, 3)

How does the SEC define cybersecurity incident?

Cybersecurity incident defined by the SEC means an unauthorized occurrence, or a series of related unauthorized occurrences, on or conducted through a registrant’s information systems that jeopardizes the confidentiality, integrity, or availability of a registrant’s information systems or any information residing therein. (4)

How can Darktrace assist in the process of disclosing incidents to the SEC?

Accelerate reporting

Darktrace’s Cyber AI Analyst generates automated reports that synthesize discrete data points potentially indicative of cybersecurity threats, forming reports that provide an overview of the evolution and impact of a threat.

Thus, when a potential threat is identified by Darktrace, AI Analyst can quickly compile information that organizations might include in their disclosure of an occurrence they determined to be material, including the following: incident timelines, incident events, incident summary, related model breaches, investigation process (i.e., how Darktrace’s AI conducted the investigation), linked incident events, and incident details. The figure below illustrates how Darktrace compiles and presents incident information and insights in the UI.

Overview of information provided in an ‘AI Analyst Report’ that could be relevant to registrants reporting a material cybersecurity incident to the SEC
Figure 1: Overview of information provided in an ‘AI Analyst Report’ that could be relevant to registrants reporting a material cybersecurity incident to the SEC

It should be noted that Instruction 4 to the new Form 8-K Item 1.05 specifies the “registrant need not disclose specific or technical information about its planned response to the incident or its cybersecurity systems, related networks and devices, or potential system vulnerabilities in such detail as would impede the registrant’s response or remediation of the incident” (5).

As such, the incident report generated by Darktrace may provide more information, including technical details, than is needed for the 8-K disclosure. In general, users should take appropriate measures to ensure that the information they provide in SEC reports meets the requirements outlined by the relevant regulations. Darktrace cannot recommend that an incident should be reported, nor report an incident itself.

Determine if a cybersecurity incident is material

Item 1.05 requires registrants to determine for themselves whether cybersecurity incidents qualify as ‘material’. This involves considerations such as ‘the nature scope and timing of the incident, and the material impact or reasonably likely material impact on the registrant, including its financial condition and results of operations.’

While it is up to the registrant to determine, consistent with existing legal standards, the materiality of an incident, Darktrace’s solution can provide relevant information which might aid in this evaluation. Darktrace’s Threat Visualizer user interface provides a 3-D visualization of an organization’s digital environment, allowing users to assess the likely degree to which an attack may have spread throughout their digital environment. Darktrace Cyber AI Analyst identifies connections among discrete occurrences of threatening activity, which can help registrants quickly assess the ‘scope and timing of an incident'.

Furthermore, in order to establish materiality it would be useful to understand how an attack might extend across recipients and environments. In the image below, Darktrace/Email identifies how a user was impacted across different platforms. In this example, Darktrace/Email identified an attacker that deployed a dual channel social engineering attack via both email and a SaaS platform in an effort to acquire login credentials. In this case, the attacker useding a legitimate SharePoint link that only reveals itself to be malicious upon click. Once the attacker gained the credentials, it proceeded to change email rules to obfuscate its activity.

Darktrace/Email presents this information in one location, making such investigations easier for the end user.

Darktrace/Email indicating a threat across SaaS and email
Figure 2: Darktrace/Email indicating a threat across SaaS and email

What is regulation S-K item 106 of the SEC cybersecurity rules?

The new rules add Item 106 to Regulation S-K requiring registrants to disclose certain information regarding their risk management, strategy, and governance relating to cybersecurity in their annual reports on Form 10-K. The new rules add Item 16K to Form 20-F to require comparable disclosure by [foreign private issuers] in their annual reports on Form 20-F. (6)

SEC cybersecurity rules: Risk management

Specifically, with respect to risk management, Item 106(b) and Item 16K(b) require registrants to describe their processes, if any, for assessing, identifying, and managing material risks from cybersecurity threats, as well as whether any risks from cybersecurity threats, including as a result of any previous cybersecurity incidents, have materially affected or are reasonably likely to materially affect them. The new rules include a non-exclusive list of disclosure items registrants should provide based on their facts and circumstances. (6)

SEC cybersecurity rules: Governance

With respect to governance, Item 106 and Item 16K require registrants to describe the board of directors’ oversight of risks from cybersecurity threats (including identifying any board committee or subcommittee responsible for such oversight) and management’s role in assessing and managing material risks from cybersecurity threats. (6)

How can Darktrace solutions aid in disclosing their risk management, strategy, and governance related to cybersecurity?

Impact scores

Darktrace End-to-End (E2E) leverages AI to understand the complex relationships across users and devices to model possible attack paths, giving security teams a contextual understanding of risk across their digital environments beyond isolated CVEs or CVSS scores. Additionally, teams can prioritize risk management actions to increase their cyber resilience through the E2E Advisory dashboard.

Attack paths consider:

  • Potential damages: Both the potential consequences if a given device was compromised and its immediate implications on other devices.
  • Exposure: Devices' level of interactivity and accessibility. For example, how many emails does a user get via mailing lists and from what kind of sources?
  • Impact: Where a user or asset sits in terms of the IT or business hierarchy and how they communicate with each other. Darktrace can simulate a range of possible outcomes for an uncertain event.
  • Weakness: A device’s patch latency and difficulty, a composite metric that looks at attacker MITRE methods and our own scores to determine how hard each stage of compromise is to achieve.

Because the SEC cybersecurity rules require “oversight of risks from cybersecurity threats” and “management’s role in assessing and managing material risks from cybersecurity threats” (6), the scores generated by Darktrace E2E can aid end-user’s ability to identify risks facing their organization and assign responsibilities to address those risks.

E2E attack paths leverage a deep understanding of a customer’ digital environment and highlight potential attack routes that an attacker could leverage to reach critical assets or entities. Difficulty scores (see Figure 5) allow security teams to measure potential damage, exposure, and impact of an attack on a specific asset or entity.

An example of an attack path in a digital environment
Figure 3: An example of an attack path in a digital environment

Automatic executive threat reports

Darktrace’s solution automatically produces Executive Threat Reports that present a simple visual overview of model breaches (i.e., indicators of unusual and threatening behaviors) and activity in the network environment. Reports can be customized to include extra details or restricted to high level information.

These reports can be generated on a weekly, quarterly, and yearly basis, and can be documented by registrants in relation to Item 106(b) to document parts of their efforts toward assessing, identifying, and managing material risks from cybersecurity threats.

Moreover, Cyber AI Analyst incident reports (described above) can be leveraged to document key details concerning significant previous incidents identified by the Darktrace solution that the registrant determined to be ‘material’.

While the disclosures required by Item 106(c) relate to the governance processes by which the board of directors, the management, and other responsible bodies within an organization oversee risks resulting from cybersecurity threats, the information provided by Darktrace’s Executive Threat Reports and Cyber AI Analyst incident reports can also help relevant stakeholders communicate more effectively regarding the threat landscape and previous incidents.

DISCLAIMER

The material above is provided for informational purposes only. This summary does not constitute legal or compliance advice, recommendations, or guidance. Darktrace encourages you to verify the contents of this summary with your own advisors.

References

  1. Note that the rule does not set forth any specific timeline between the incident and the materiality determination, but the materiality determination should be made without unreasonable delay.
  2. https://www.sec.gov/files/form8-k.pdf
  3. https://www.sec.gov/news/press-release/2023-139
  4. https://www.ecfr.gov/current/title-17/chapter-II/part-229
  5. https://www.sec.gov/files/form8-k.pdf
  6. https://www.sec.gov/corpfin/secg-cybersecurity
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.
Written by
Kendra Gonzalez Duran
Principal Analyst

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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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