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.

Written by

Kendra Gonzalez Duran

Principal Analyst

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

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.

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.

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.

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

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.
https://www.sec.gov/files/form8-k.pdf
https://www.sec.gov/news/press-release/2023-139
‍https://www.ecfr.gov/current/title-17/chapter-II/part-229‍
https://www.sec.gov/files/form8-k.pdf
https://www.sec.gov/corpfin/secg-cybersecurity

Written by

Kendra Gonzalez Duran

Principal Analyst

Inside the SOC

Written by

Kendra Gonzalez Duran

Principal Analyst

The Darktrace Community

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November 27, 2025

CastleLoader & CastleRAT: Behind TAG150’s Modular Malware Delivery System

What is TAG-150?

TAG-150, a relatively new Malware-as-a-Service (MaaS) operator, has been active since March 2025, demonstrating rapid development and an expansive, evolving infrastructure designed to support its malicious operations. The group employs two custom malware families, CastleLoader and CastleRAT, to compromise target systems, with a primary focus on the United States [1]. TAG-150’s infrastructure included numerous victim-facing components, such as IP addresses and domains functioning as command-and-control (C2) servers associated with malware families like SecTopRAT and WarmCookie, in addition to CastleLoader and CastleRAT [2].

As of May 2025, CastleLoader alone had infected a reported 469 devices, underscoring the scale and sophistication of TAG-150’s campaign [1].

What are CastleLoader and CastleRAT?

CastleLoader is a loader malware, primarily designed to download and install additional malware, enabling chain infections across compromised systems [3]. TAG-150 employs a technique known as ClickFix, which uses deceptive domains that mimic document verification systems or browser update notifications to trick victims into executing malicious scripts. Furthermore, CastleLoader leverages fake GitHub repositories that impersonate legitimate tools as a distribution method, luring unsuspecting users into downloading and installing malware on their devices [4].

CastleRAT, meanwhile, is a remote access trojan (RAT) that serves as one of the primary payloads delivered by CastleLoader. Once deployed, CastleRAT grants attackers extensive control over the compromised system, enabling capabilities such as keylogging, screen capturing, and remote shell access.

TAG-150 leverages CastleLoader as its initial delivery mechanism, with CastleRAT acting as the main payload. This two-stage attack strategy enhances the resilience and effectiveness of their operations by separating the initial infection vector from the final payload deployment.

How are they deployed?

Castleloader uses code-obfuscation methods such as dead-code insertion and packing to hinder both static and dynamic analysis. After the payload is unpacked, it connects to its command-and-control server to retrieve and running additional, targeted components.

Its modular architecture enables it to function both as a delivery mechanism and a staging utility, allowing threat actors to decouple the initial infection from payload deployment. CastleLoader typically delivers its payloads as Portable Executables (PEs) containing embedded shellcode. This shellcode activates the loader’s core module, which then connects to the C2 server to retrieve and execute the next-stage malware.[6]

Following this, attackers deploy the ClickFix technique, impersonating legitimate software distribution platforms like Google Meet or browser update notifications. These deceptive sites trick victims into copying and executing PowerShell commands, thereby initiating the infection kill chain. [1]

When a user clicks on a spoofed Cloudflare “Verification Step” prompt, a background request is sent to a PHP script on the distribution domain (e.g., /s.php?an=0). The server’s response is then automatically copied to the user’s clipboard using the ‘unsecuredCopyToClipboard()’ function. [7].

The Python-based variant of CastleRAT, known as “PyNightShade,” has been engineered with stealth in mind, showing minimal detection across antivirus platforms [2]. As illustrated in Figure 1, PyNightShade communicates with the geolocation API service ip-api[.]com, demonstrating both request and response behavior

Figure 1: Packet Capture (PCAP) of PyNightShade, the Python-based variant of CastleRAT, communicating with the geolocation API service ip-api[.]com.

Darktrace Coverage

In mid-2025, Darktrace observed a range of anomalous activities across its customer base that appeared linked to CastleLoader, including the example below from a US based organization.

The activity began on June 26, when a device on the customer’s network was observed connecting to the IP address 173.44.141[.]89, a previously unseen IP for this network along with the use of multiple user agents, which was also rare for the user. It was later determined that the IP address was a known indicator of compromise (IoC) associated with TAG-150’s CastleRAT and CastleLoader operations [2][5].

Figure 2: Darktrace’s detection of a device making unusual connections to the malicious endpoint 173.44.141[.]89.

The device was observed downloading two scripts from this endpoint, namely ‘/service/download/data_5x.bin’ and ‘/service/download/data_6x.bin’, which have both been linked to CastleLoader infections by open-source intelligence (OSINT) [8]. The archives contains embedded shellcode, which enables attackers to execute arbitrary code directly in memory, bypassing disk writes and making detection by endpoint detection and response (EDR) tools significantly more difficult [2].

Figure 3: Darktrace’s detection of two scripts from the malicious endpoint.

In addition to this, the affected device exhibited a high volume of internal connections to a broad range of endpoints, indicating potential scanning activity. Such behavior is often associated with reconnaissance efforts aimed at mapping internal infrastructure.

Darktrace / NETWORK correlated these behaviors and generated an Enhanced Monitoring model, a high-fidelity security model designed to detect activity consistent with the early stages of an attack. These high-priority models are continuously monitored and triaged by Darktrace’s Security Operations Center (SOC) as part of the Managed Threat Detection and Managed Detection & Response services, ensuring that subscribed customers are promptly alerted to emerging threats.

Figure 4: Darktrace detected an unusual ZIP file download alongside the anomalous script, followed by internal connectivity. This activity was correlated under an Enhanced Monitoring model.

Darktrace Autonomous Response

Fortunately, Darktrace’s Autonomous Response capability was fully configured, enabling it to take immediate action against the offending device by blocking any further connections external to the malicious endpoint, 173.44.141[.]89. Additionally, Darktrace enforced a ‘group pattern of life’ on the device, restricting its behavior to match other devices in its peer group, ensuring it could not deviate from expected activity, while also blocking connections over 443, shutting down any unwanted internal scanning.

Figure 5: Actions performed by Darktrace’s Autonomous Response to contain the ongoing attack.

Conclusion

The rise of the MaaS ecosystem, coupled with attackers’ growing ability to customize tools and techniques for specific targets, is making intrusion prevention increasingly challenging for security teams. Many threat actors now leverage modular toolkits, dynamic infrastructure, and tailored payloads to evade static defenses and exploit even minor visibility gaps. In this instance, Darktrace demonstrated its capability to counter these evolving tactics by identifying early-stage attack chain behaviors such as network scanning and the initial infection attempt. Autonomous Response then blocked the CastleLoader IP delivering the malicious ZIP payload, halting the attack before escalation and protecting the organization from a potentially damaging multi-stage compromise

Credit to Ahmed Gardezi (Cyber Analyst) Tyler Rhea (Senior Cyber Analyst)
Edited by Ryan Traill (Analyst Content Lead)

Appendices

Darktrace Model Detections

Anomalous Connection / Unusual Internal Connections
Anomalous File / Zip or Gzip from Rare External Location
Anomalous File / Script from Rare External Location
Initial Attack Chain Activity (Enhanced Monitoring Model)

MITRE ATT&CK Mapping

T15588.001 - Resource Development – Malware
TG1599 – Defence Evasion – Network Boundary Bridging
T1046 – Discovery – Network Service Scanning
T1189 – Initial Access

List of IoCs
IoC - Type - Description + Confidence

173.44.141[.]89 – IP – CastleLoader C2 Infrastructure
173.44.141[.]89/service/download/data_5x.bin – URI – CastleLoader Script
173.44.141[.]89/service/download/data_6x.bin – URI - CastleLoader Script
wsc.zip – ZIP file – Possible Payload

References

[1] - https://blog.polyswarm.io/castleloader

[2] - https://www.recordedfuture.com/research/from-castleloader-to-castlerat-tag-150-advances-operations

[3] - https://www.pcrisk.com/removal-guides/34160-castleloader-malware

[4] - https://www.scworld.com/brief/malware-loader-castleloader-targets-devices-via-fake-github-clickfix-phishing

[5] https://www.virustotal.com/gui/ip-address/173.44.141.89/community

[6] https://thehackernews.com/2025/07/castleloader-malware-infects-469.html

[7] https://www.cryptika.com/new-castleloader-attack-using-cloudflare-themed-clickfix-technique-to-infect-windows-computers/

[8] https://www.cryptika.com/castlebot-malware-as-a-service-deploys-range-of-payloads-linked-to-ransomware-attacks/

About the author

Ahmed Gardezi

Cyber Analyst

Blog

Compliance

November 26, 2025

UK Cyber Security & Resilience Bill: What Organizations Need to Know

Why the Bill has been introduced

The UK’s cyber threat landscape has evolved dramatically since the 2018 NIS regime was introduced. Incidents such as the Synnovis attack against hospitals and the British Library ransomware attack show how quickly operational risk can become public harm. In this context, the UK Department for Science, Innovation and Technology estimates that cyber-attacks cost UK businesses around £14.7 billion each year.

At the same time, the widespread adoption of AI has expanded organisations’ attack surfaces and empowered threat actors to launch more effective and sophisticated activities, including crafting convincing phishing campaigns, exploiting vulnerabilities and initiating ransomware attacks at unprecedented speed and scale.

The CSRB responds to these challenges by widening who is regulated, accelerating incident reporting and tightening supply chain accountability, while enabling rapid updates that keep pace with technology and emerging risks.

Key provisions of the Cyber Security and Resilience Bill

A wider set of organisations in scope

The Bill significantly broadens the range of organisations regulated under the NIS framework.

Managed service providers (MSPs) - medium and large MSPs, including MSSPs, managed SOCs, SIEM providers and similar services,will now fall under NIS obligations due to their systemic importance and privileged access to client systems. The Information Commissioner’s Office (ICO) will act as the regulator. Government analysis anticipates that a further 900 to 1,100 MSPs will be in scope.
Data infrastructure is now recognised as essential to the functioning of the economy and public services. Medium and large data centres, as well as enterprise facilities meeting specified thresholds, will be required to implement appropriate and proportionate measures to manage cyber risk. Oversight will be shared between DSIT and Ofcom, with Ofcom serving as the operational regulator.
Organisations that manage electrical loads for smart appliances, such as those supporting EV charging during peak times, are now within scope.

These additions sit alongside existing NIS-regulated sectors such as transport, energy, water, health, digital infrastructure, and certain digital services (including online marketplaces, search engines, and cloud computing).

Stronger supply chain requirements

Under the CSRB, regulators can now designate third-party suppliers as ‘designated critical suppliers’ (DCS) when certain threshold criteria are met and where disruption could have significant knock-on effects. Designated suppliers will be subject to the same security and incident-reporting obligations as Operators of Essential Services (OES) and Relevant Digital Service Providers (RDSPs).

Government will scope the supply chain duties for OES and RDSPs via secondary legislation, following consultation. infrastructure incidents where a single supplier’s compromise caused widespread disruption.

Faster incident reporting

Sector-specific regulators, 12 in total, will be responsible for implementing the CSRB, allowing for more effective and consistent reporting. In addition, the CSRB introduces a two-stage reporting process and expands incident reporting criteria. Regulated entities must submit an initial notification within 24 hours of becoming aware of a significant incident, followed by an incident report within 72 hours. Incident reporting criteria are also broadened to capture incidents beyond those which actually resulted in an interruption, ensuring earlier visibility for regulators and the National Cyber Security Centre (NCSC). The importance of information sharing across agencies, law enforcement and regulators is also facilitated by the CSRB.

The reforms also require data centres and managed service providers to notify affected customers where they are likely to have been impacted by a cyber incident.

An agile regulatory framework

To keep pace with technological change, the CSRB will enable the Secretary of State to update elements of the framework via secondary legislation. Supporting materials such as the NCSC Cyber Assessment Framework (CAF) are to be "put on a stronger footing” allowing for requirements to be more easily followed, managed and updated. Regulators will also now be able to recover full costs associated with NIS duties meaning they are better resourced to carry out their associated responsibilities.

Relevant Managed Service Providers must identify and take appropriate and proportionate measures to manage risks to the systems they rely on for providing services within the UK. Importantly, these measures must, having regard to the state of the art, ensure a level of security appropriate to the risk posed, and prevent or minimise the impact of incidents.

The Secretary of State will also be empowered to issue a Statement of Strategic Priorities, setting cross-regime outcomes to drive consistency across the 12 competent authorities responsible for implementation.

Penalties

The enforcement framework will be strengthened, with maximum fines aligned with comparable regimes such as the GDPR, which incorporate maximums tied to turnover. Under the CSRB, maximum penalties for more serious breaches could be up to £17 million or 4% of global turnover, whichever is higher.

Next steps

The Bill is expected to progress through Parliament over the course of 2025 and early 2026, with Royal Assent anticipated in 2026. Once enacted, most operational measures will not take immediate effect. Instead, Government will bring key components into force through secondary legislation following further consultation, providing regulators and industry with time to adjust practices and prepare for compliance.

Anticipated timeline

2025-2026: Parliamentary scrutiny and passage;
2026: Royal Assent;
2026 consultation: DSIT intends to consult on detailed implementation;
From 2026 onwards: Phased implementation via secondary legislation, following further consultation led by DSIT.

How Darktrace can help

The CSRB represents a step change in how the UK approaches digital risk, shifting the focus from compliance to resilience.

Darktrace can help organisations operationalise this shift by using AI to detect, investigate and respond to emerging threats at machine speed, before they escalate into incidents requiring regulatory notification. Proactive tools which can be included in the Darktrace platform allow security teams to stress-test defences, map supply chain exposure and rehearse recovery scenarios, directly supporting the CSRB’s focus on resilience, transparency and rapid response. If an incident does occur, Darktrace’s autonomous agent, Cyber AI Analyst, can accelerate investigations and provide a view of every stage of the attack chain, supporting timely reporting.

Darktrace’s AI can provide organisations with a vital lens into both internal and external cyber risk. By continuously learning patterns of behaviour across interconnected systems, Darktrace can flag potential compromise or disruption to detect supply chain risk before it impacts your organisation.

In a landscape where compliance and resilience go hand in hand, Darktrace can equip organisations to stay ahead of both evolving threats and evolving regulatory requirements.

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What you need to know about the new SEC Cybersecurity rules

What is new in 2023 to SEC cybersecurity rules?

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

How does the SEC define cybersecurity incident?

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

Accelerate reporting

Determine if a cybersecurity incident is material

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

SEC cybersecurity rules: Risk management

SEC cybersecurity rules: Governance

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

Impact scores

Automatic executive threat reports

DISCLAIMER‍

References

CastleLoader & CastleRAT: Behind TAG150’s Modular Malware Delivery System

UK Cyber Security & Resilience Bill: What Organizations Need to Know

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Blog

Network

November 27, 2025

CastleLoader & CastleRAT: Behind TAG150’s Modular Malware Delivery System

What is TAG-150?

What are CastleLoader and CastleRAT?

How are they deployed?

Darktrace Coverage

Darktrace Autonomous Response

Conclusion

Appendices

References

Blog

Compliance

November 26, 2025

UK Cyber Security & Resilience Bill: What Organizations Need to Know

Why the Bill has been introduced

Key provisions of the Cyber Security and Resilience Bill

A wider set of organisations in scope

Stronger supply chain requirements

Faster incident reporting

An agile regulatory framework

Penalties

Next steps

Anticipated timeline

How Darktrace can help