Implications of NIS2 on cybersecurity and AI

Explore the key aspects of the NIS2 Directive, the latest EU cyber security legislation coming into effect in 2024. Learn how it impacts AI and security teams.
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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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The NIS2 Directive requires member states to adopt laws that will improve the cyber resilience of organizations within the EU. It impacts organizations that are “operators of essential services”. Under NIS 1, EU member states could choose what this meant. In an effort to ensure more consistent application, NIS2 has set out its own definition. It eliminates the distinction between operators of essential services and digital service providers from NIS1, instead defining a new list of sectors:

  • Energy (electricity, district heating and cooling, gas, oil, hydrogen)
  • Transport (air, rail, water, road)
  • Banking (credit institutions)
  • Financial market infrastructures
  • Health (healthcare providers and pharma companies)
  • Drinking water (suppliers and distributors)
  • Digital infrastructure (DNS, TLD registries, telcos, data center providers, etc.)
  • ICT service providers (B2B): MSSPs and managed service providers
  • Public administration (central and regional government institutions, as defined per member state)
  • Space
  • Postal and courier services
  • Waste management
  • Chemicals
  • Food
  • Manufacturing of medical devices
  • Computers and electronics
  • Machinery and equipment
  • Motor vehicles, trailers and semi-trailers and other transport equipment
  • Digital providers (online market places, online search engines, and social networking service platforms) and research organizations.

With these updates, it becomes harder to try and find industry segments not included within the scope. NIS2 represents legally binding cyber security requirements for a significant region and economy. Standout features that have garnered the most attention include the tight timelines associated with notification requirements. Under NIS 2, in-scope entities must submit an initial report or “early warning” to the competent national authority or computer security incident response team (CSIRT) within 24 hours from when the entity became aware of a significant incident. This is a new development from the first iteration of the Directive, which used more vague language of the need to notify authorities “without undue delay”.

Another aspect gaining attention is oversight and regulation – regulators are going to be empowered with significant investigation and supervision powers including on-site inspections.

The stakes are now higher, with the prospect of fines that are capped at €10 million or 2% of an offending organization’s annual worldwide turnover – whichever is greater. Added to that, the NIS2 Directive includes an explicit obligation to hold members of management bodies personally responsible for breaches of their duties to ensure compliance with NIS2 obligations – and members can be held personally liable.  

The risk management measures introduced in the Directive are not altogether surprising – they reflect common best practices. Many organizations (especially those that are newly in scope for NIS2) may have to expand their cyber security capabilities, but there’s nothing controversial or alarming in the required measures.  For organizations in this situation, there are various tools, best practices, and frameworks they can leverage.  Darktrace in particular provides capabilities in the areas of visibility, incident handling, and reporting that can help.

NIS2 and Cyber AI

The use of AI is not an outright requirement within NIS2 – which may be down to lack of knowledge and expertise in the area, and/or the immaturity of the sector. The clue to this might be in the timing: the provisional agreement on the NIS2 text was reached in May 2022 – six months before ChatGPT and other open-source Generative AI tools propelled broader AI technology into the forefront of public consciousness. If the language were drafted today, it's not far-fetched to imagine AI being mentioned much more prominently and perhaps even becoming a requirement.

NIS2 does, however, very clearly recommend that “member states should encourage the use of any innovative technology, including artificial intelligence”[1].  Another section speaks directly to essential and important entities, saying that they should “evaluate their own cyber security capabilities, and where appropriate, pursue the integration of cyber security enhancing technologies, such as artificial intelligence or machine learning systems…”[2]

One of the recitals states that “member states should adopt policies on the promotion of active cyber protection”.  Where active cyber protection is defined as “the prevention, detection, monitoring, analysis and mitigation of network security breaches in an active manner.”[3]  

From a Darktrace perspective, our self-learning Cyber AI technology is precisely what enables our technology to deliver active cyber protection – protecting organizations and uplifting security teams at every stage of an incident lifecycle – from proactively hardening defenses before an attack is launched, to real-time threat detection and response, through to recovering quickly back to a state of good health.  

The visibility provided by Darktrace is vital to understanding the effectiveness of policies and ensuring policy compliance. NIS2 also covers incident handling and business continuity, which Darktrace HEAL addresses through AI-enabled incident response, readiness reports, simulations, and secure collaborations.

Reporting is integral to NIS2 and organizations can leverage Darktrace’s incident reporting features to present the necessary technical details of an incident and provide a jump start to compiling a full report with business context and impact.  

What’s next for NIS2

We don’t yet know the details for how EU member states will transpose NIS2 into national law – they have until 17th October 2024 to work this out. The Commission also commits to reviewing the functioning of the Directive every three years. Given how much our overall understanding and appreciation for not only the dangers of AI but also its power (perhaps even necessity in the realm of cyber security) is changing, we may see many member states will leverage the recitals’ references to AI in order to make a strong push if not a requirement that essential and important organizations within their jurisdiction leverage AI.

Organizations are starting to prepare now to meet the forthcoming legislation related to NIS2. Download our CISO’s Guide to NIS2 Preparedness, which includes everything you need to know to get ahead of the directive.

[1] (51) on page 11
[2]
(89) on page 17
[3]
(57) on page 12

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Inside the SOC
Darktrace cyber analysts are world-class experts in threat intelligence, threat hunting and incident response, and provide 24/7 SOC support to thousands of Darktrace customers around the globe. Inside the SOC is exclusively authored by these experts, providing analysis of cyber incidents and threat trends, based on real-world experience in the field.
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November 26, 2025

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

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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 Stepprompt, 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

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

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

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

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November 20, 2025

Managing OT Remote Access with Zero Trust Control & AI Driven Detection

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The shift toward IT-OT convergence

Recently, industrial environments have become more connected and dependent on external collaboration. As a result, truly air-gapped OT systems have become less of a reality, especially when working with OEM-managed assets, legacy equipment requiring remote diagnostics, or third-party integrators who routinely connect in.

This convergence, whether it’s driven by digital transformation mandates or operational efficiency goals, are making OT environments more connected, more automated, and more intertwined with IT systems. While this convergence opens new possibilities, it also exposes the environment to risks that traditional OT architectures were never designed to withstand.

The modernization gap and why visibility alone isn’t enough

The push toward modernization has introduced new technology into industrial environments, creating convergence between IT and OT environments, and resulting in a lack of visibility. However, regaining that visibility is just a starting point. Visibility only tells you what is connected, not how access should be governed. And this is where the divide between IT and OT becomes unavoidable.

Security strategies that work well in IT often fall short in OT, where even small missteps can lead to environmental risk, safety incidents, or costly disruptions. Add in mounting regulatory pressure to enforce secure access, enforce segmentation, and demonstrate accountability, and it becomes clear: visibility alone is no longer sufficient. What industrial environments need now is precision. They need control. And they need to implement both without interrupting operations. All this requires identity-based access controls, real-time session oversight, and continuous behavioral detection.

The risk of unmonitored remote access

This risk becomes most evident during critical moments, such as when an OEM needs urgent access to troubleshoot a malfunctioning asset.

Under that time pressure, access is often provisioned quickly with minimal verification, bypassing established processes. Once inside, there’s little to no real-time oversight of user actions whether they’re executing commands, changing configurations, or moving laterally across the network. These actions typically go unlogged or unnoticed until something breaks. At that point, teams are stuck piecing together fragmented logs or post-incident forensics, with no clear line of accountability.  

In environments where uptime is critical and safety is non-negotiable, this level of uncertainty simply isn’t sustainable.

The visibility gap: Who’s doing what, and when?

The fundamental issue we encounter is the disconnect between who has access and what they are doing with it.  

Traditional access management tools may validate credentials and restrict entry points, but they rarely provide real-time visibility into in-session activity. Even fewer can distinguish between expected vendor behavior and subtle signs of compromise, misuse or misconfiguration.  

As a result, OT and security teams are often left blind to the most critical part of the puzzle, intent and behavior.

Closing the gaps with zero trust controls and AI‑driven detection

Managing remote access in OT is no longer just about granting a connection, it’s about enforcing strict access parameters while continuously monitoring for abnormal behavior. This requires a two-pronged approach: precision access control, and intelligent, real-time detection.

Zero Trust access controls provide the foundation. By enforcing identity-based, just-in-time permissions, OT environments can ensure that vendors and remote users only access the systems they’re explicitly authorized to interact with, and only for the time they need. These controls should be granular enough to limit access down to specific devices, commands, or functions. By applying these principles consistently across the Purdue Model, organizations can eliminate reliance on catch-all VPN tunnels, jump servers, and brittle firewall exceptions that expose the environment to excess risk.

Access control is only one part of the equation

Darktrace / OT complements zero trust controls with continuous, AI-driven behavioral detection. Rather than relying on static rules or pre-defined signatures, Darktrace uses Self-Learning AI to build a live, evolving understanding of what’s “normal” in the environment, across every device, protocol, and user. This enables real-time detection of subtle misconfigurations, credential misuse, or lateral movement as they happen, not after the fact.

By correlating user identity and session activity with behavioral analytics, Darktrace gives organizations the full picture: who accessed which system, what actions they performed, how those actions compared to historical norms, and whether any deviations occurred. It eliminates guesswork around remote access sessions and replaces it with clear, contextual insight.

Importantly, Darktrace distinguishes between operational noise and true cyber-relevant anomalies. Unlike other tools that lump everything, from CVE alerts to routine activity, into a single stream, Darktrace separates legitimate remote access behavior from potential misuse or abuse. This means organizations can both audit access from a compliance standpoint and be confident that if a session is ever exploited, the misuse will be surfaced as a high-fidelity, cyber-relevant alert. This approach serves as a compensating control, ensuring that even if access is overextended or misused, the behavior is still visible and actionable.

If a session deviates from learned baselines, such as an unusual command sequence, new lateral movement path, or activity outside of scheduled hours, Darktrace can flag it immediately. These insights can be used to trigger manual investigation or automated enforcement actions, such as access revocation or session isolation, depending on policy.

This layered approach enables real-time decision-making, supports uninterrupted operations, and delivers complete accountability for all remote activity, without slowing down critical work or disrupting industrial workflows.

Where Zero Trust Access Meets AI‑Driven Oversight:

  • Granular Access Enforcement: Role-based, just-in-time access that aligns with Zero Trust principles and meets compliance expectations.
  • Context-Enriched Threat Detection: Self-Learning AI detects anomalous OT behavior in real time and ties threats to access events and user activity.
  • Automated Session Oversight: Behavioral anomalies can trigger alerting or automated controls, reducing time-to-contain while preserving uptime.
  • Full Visibility Across Purdue Layers: Correlated data connects remote access events with device-level behavior, spanning IT and OT layers.
  • Scalable, Passive Monitoring: Passive behavioral learning enables coverage across legacy systems and air-gapped environments, no signatures, agents, or intrusive scans required.

Complete security without compromise

We no longer have to choose between operational agility and security control, or between visibility and simplicity. A Zero Trust approach, reinforced by real-time AI detection, enables secure remote access that is both permission-aware and behavior-aware, tailored to the realities of industrial operations and scalable across diverse environments.

Because when it comes to protecting critical infrastructure, access without detection is a risk and detection without access control is incomplete.

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Pallavi Singh
Product Marketing Manager, OT Security & Compliance
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