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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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June 27, 2025

Patch and Persist: Darktrace’s Detection of Blind Eagle (APT-C-36)

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What is Blind Eagle?

Since 2018, APT-C-36, also known as Blind Eagle, has been observed performing cyber-attacks targeting various sectors across multiple countries in Latin America, with a particular focus on Colombian organizations.

Blind Eagle characteristically targets government institutions, financial organizations, and critical infrastructure [1][2].

Attacks carried out by Blind Eagle actors typically start with a phishing email and the group have been observed utilizing various Remote Access Trojans (RAT) variants, which often have in-built methods for hiding command-and-control (C2) traffic from detection [3].

What we know about Blind Eagle from a recent campaign

Since November 2024, Blind Eagle actors have been conducting an ongoing campaign targeting Colombian organizations [1].

In this campaign, threat actors have been observed using phishing emails to deliver malicious URL links to targeted recipients, similar to the way threat actors have previously been observed exploiting CVE-2024-43451, a vulnerability in Microsoft Windows that allows the disclosure of a user’s NTLMv2 password hash upon minimal interaction with a malicious file [4].

Despite Microsoft patching this vulnerability in November 2024 [1][4], Blind Eagle actors have continued to exploit the minimal interaction mechanism, though no longer with the intent of harvesting NTLMv2 password hashes. Instead, phishing emails are sent to targets containing a malicious URL which, when clicked, initiates the download of a malicious file. This file is then triggered by minimal user interaction.

Clicking on the file triggers a WebDAV request, with a connection being made over HTTP port 80 using the user agent ‘Microsoft-WebDAV-MiniRedir/10.0.19044’. WebDAV is a transmission protocol which allows files or complete directories to be made available through the internet, and to be transmitted to devices [5]. The next stage payload is then downloaded via another WebDAV request and malware is executed on the target device.

Attackers are notified when a recipient downloads the malicious files they send, providing an insight into potential targets [1].

Darktrace’s coverage of Blind Eagle

In late February 2025, Darktrace observed activity assessed with medium confidence to be  associated with Blind Eagle on the network of a customer in Colombia.

Within a period of just five hours, Darktrace / NETWORK detected a device being redirected through a rare external location, downloading multiple executable files, and ultimately exfiltrating data from the customer’s environment.

Since the customer did not have Darktrace’s Autonomous Response capability enabled on their network, no actions were taken to contain the compromise, allowing it to escalate until the customer’s security team responded to the alerts provided by Darktrace.

Darktrace observed a device on the customer’s network being directed over HTTP to a rare external IP, namely 62[.]60[.]226[.]112, which had never previously been seen in this customer’s environment and was geolocated in Germany. Multiple open-source intelligence (OSINT) providers have since linked this endpoint with phishing and malware campaigns [9].

The device then proceeded to download the executable file hxxp://62[.]60[.]226[.]112/file/3601_2042.exe.

Darktrace’s detection of the affected device connecting to an unusual location based in Germany.
Figure 1: Darktrace’s detection of the affected device connecting to an unusual location based in Germany.
Darktrace’s detection of the affected device downloading an executable file from the suspicious endpoint.
Figure 2: Darktrace’s detection of the affected device downloading an executable file from the suspicious endpoint.

The device was then observed making unusual connections to the rare endpoint 21ene.ip-ddns[.]com and performing unusual external data activity.

This dynamic DNS endpoint allows a device to access an endpoint using a domain name in place of a changing IP address. Dynamic DNS services ensure the DNS record of a domain name is automatically updated when the IP address changes. As such, malicious actors can use these services and endpoints to dynamically establish connections to C2 infrastructure [6].

Further investigation into this dynamic endpoint using OSINT revealed multiple associations with previous likely Blind Eagle compromises, as well as Remcos malware, a RAT commonly deployed via phishing campaigns [7][8][10].

Darktrace’s detection of the affected device connecting to the suspicious dynamic DNS endpoint, 21ene.ip-ddns[.]com.
Figure 3: Darktrace’s detection of the affected device connecting to the suspicious dynamic DNS endpoint, 21ene.ip-ddns[.]com.

Shortly after this, Darktrace observed the user agent ‘Microsoft-WebDAV-MiniRedir/10.0.19045’, indicating usage of the aforementioned transmission protocol WebDAV. The device was subsequently observed connected to an endpoint associated with Github and downloading data, suggesting that the device was retrieving a malicious tool or payload. The device then began to communicate to the malicious endpoint diciembrenotasenclub[.]longmusic[.]com over the new TCP port 1512 [11].

Around this time, the device was also observed uploading data to the endpoints 21ene.ip-ddns[.]com and diciembrenotasenclub[.]longmusic[.]com, with transfers of 60 MiB and 5.6 MiB observed respectively.

Figure 4: UI graph showing external data transfer activity.

This chain of activity triggered an Enhanced Monitoring model alert in Darktrace / NETWORK. These high-priority model alerts are designed to trigger in response to higher fidelity indicators of compromise (IoCs), suggesting that a device is performing activity consistent with a compromise.

 Darktrace’s detection of initial attack chain activity.
Figure 5: Darktrace’s detection of initial attack chain activity.

A second Enhanced Monitoring model was also triggered by this device following the download of the aforementioned executable file (hxxp://62[.]60[.]226[.]112/file/3601_2042.exe) and the observed increase in C2 activity.

Following this activity, Darktrace continued to observe the device beaconing to the 21ene.ip-ddns[.]com endpoint.

Darktrace’s Cyber AI Analyst was able to correlate each of the individual detections involved in this compromise, identifying them as part of a broader incident that encompassed C2 connectivity, suspicious downloads, and external data transfers.

Cyber AI Analyst’s investigation into the activity observed on the affected device.
Figure 6: Cyber AI Analyst’s investigation into the activity observed on the affected device.
Figure 7: Cyber AI Analyst’s detection of the affected device’s broader connectivity throughout the course of the attack.

As the affected customer did not have Darktrace’s Autonomous Response configured at the time, the attack was able to progress unabated. Had Darktrace been properly enabled, it would have been able to take a number of actions to halt the escalation of the attack.

For example, the unusual beaconing connections and the download of an unexpected file from an uncommon location would have been shut down by blocking the device from making external connections to the relevant destinations.

Conclusion

The persistence of Blind Eagle and ability to adapt its tactics, even after patches were released, and the speed at which the group were able to continue using pre-established TTPs highlights that timely vulnerability management and patch application, while essential, is not a standalone defense.

Organizations must adopt security solutions that use anomaly-based detection to identify emerging and adapting threats by recognizing deviations in user or device behavior that may indicate malicious activity. Complementing this with an autonomous decision maker that can identify, connect, and contain compromise-like activity is crucial for safeguarding organizational networks against constantly evolving and sophisticated threat actors.

Credit to Charlotte Thompson (Senior Cyber Analyst), Eugene Chua (Principal Cyber Analyst) and Ryan Traill (Analyst Content Lead)

Appendices

IoCs

IoC – Type - Confidence
Microsoft-WebDAV-MiniRedir/10.0.19045 – User Agent

62[.]60[.]226[.]112 – IP – Medium Confidence

hxxp://62[.]60[.]226[.]112/file/3601_2042.exe – Payload Download – Medium Confidence

21ene.ip-ddns[.]com – Dynamic DNS Endpoint – Medium Confidence

diciembrenotasenclub[.]longmusic[.]com  - Hostname – Medium Confidence

Darktrace’s model alert coverage

Anomalous File / Suspicious HTTP Redirect
Anomalous File / EXE from Rare External Location
Anomalous File / Multiple EXE from Rare External Location
Anomalous Server Activity / Outgoing from Server
Unusual Activity / Unusual External Data to New Endpoint
Device / Anomalous Github Download
Anomalous Connection / Multiple Connections to New External TCP Port
Device / Initial Attack Chain Activity
Anomalous Server Activity / Rare External from Server
Compromise / Suspicious File and C2
Compromise / Fast Beaconing to DGA
Compromise / Large Number of Suspicious Failed Connections
Device / Large Number of Model Alert

Mitre Attack Mapping:

Tactic – Technique – Technique Name

Initial Access - T1189 – Drive-by Compromise
Initial Access - T1190 – Exploit Public-Facing Application
Initial Access ICS - T0862 – Supply Chain Compromise
Initial Access ICS - T0865 – Spearphishing Attachment
Initial Access ICS - T0817 - Drive-by Compromise
Resource Development - T1588.001 – Malware
Lateral Movement ICS - T0843 – Program Download
Command and Control - T1105 - Ingress Tool Transfer
Command and Control - T1095 – Non-Application Layer Protocol
Command and Control - T1571 – Non-Standard Port
Command and Control - T1568.002 – Domain Generation Algorithms
Command and Control ICS - T0869 – Standard Application Layer Protocol
Evasion ICS - T0849 – Masquerading
Exfiltration - T1041 – Exfiltration Over C2 Channel
Exfiltration - T1567.002 – Exfiltration to Cloud Storage

References

1)    https://research.checkpoint.com/2025/blind-eagle-and-justice-for-all/

2)    https://assets.kpmg.com/content/dam/kpmgsites/in/pdf/2025/04/kpmg-ctip-blind-eagle-01-apr-2025.pdf.coredownload.inline.pdf

3)    https://www.checkpoint.com/cyber-hub/threat-prevention/what-is-remote-access-trojan/#:~:text=They%20might%20be%20attached%20to,remote%20access%20or%20system%20administration

4)    https://msrc.microsoft.com/update-guide/vulnerability/CVE-2024-43451

5)    https://www.ionos.co.uk/digitalguide/server/know-how/webdav/

6)    https://vercara.digicert.com/resources/dynamic-dns-resolution-as-an-obfuscation-technique

7)    https://threatfox.abuse.ch/ioc/1437795

8)    https://www.checkpoint.com/cyber-hub/threat-prevention/what-is-malware/remcos-malware/

9)    https://www.virustotal.com/gui/url/b3189db6ddc578005cb6986f86e9680e7f71fe69f87f9498fa77ed7b1285e268

10) https://www.virustotal.com/gui/domain/21ene.ip-ddns.com

11) https://www.virustotal.com/gui/domain/diciembrenotasenclub.longmusic.com/community

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Charlotte Thompson
Cyber Analyst

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June 19, 2025

Customer Case Study: Leading Petrochemical Manufacturer

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Headquartered in Saudi Arabia, this industry leading petrochemical manufacturer serves customers in more than 80 countries across diverse markets throughout Europe, Africa, Latin America, the Middle East, China, and Southeast Asia.

Cyber resiliency critical to growth strategy

This leading petrochemical manufacturer’s vision is to be one of the major global players in the production and marketing of designated petrochemicals and downstream products. The company aims to significantly increase its capacity to up to a million metric tons within the next few years.

With cyber-attacks on critical infrastructure increasing 30% globally last year, cyber resiliency is essential to supporting the company’s strategic business goals of:

  • Maximizing production through efficient asset utilization
  • Maximizing sales by conducting 90% of its business outside Saudi Arabia
  • Optimizing resources and processes by integrating with UN Global Compact principles for sustainability and efficiency
  • Growing its business portfolio by engaging in joint ventures to diversify production and add value to the economy

However, the industry leader faced several challenges in its drive to fortify its cybersecurity defenses.

Visibility gaps delay response time

The company’s existing security setup provided limited visibility to the in-house security team, hindering its ability to detect anomalous network and user activity in real time. This resulted in delayed responses to potential incidents, making proactive issue resolution difficult and any remediation in the event of a successful attack costly and time-consuming.

Manual detection drains resources

Without automated detection and response capabilities, the organization’s security team had to manually monitor for suspicious activity – a time-consuming and inefficient approach that strained resources and left the organization vulnerable. This made it difficult for the team to stay current with training or acquire new skills and certifications, which are core to the ethos of both the company’s owners and the team itself.

Cyber-attacks on critical infrastructure increasing

The petrochemical manufacturer is part of a broader ecosystem of companies, making the protection of its supply chain – both upstream and downstream – critical. With several manufacturing entities and multiple locations, the customer’s internal structure is complex and challenging to secure. As cyber-attacks on critical infrastructure escalate, it needed a more comprehensive approach to safeguard its business and the wider ecosystem.

Keeping and growing skills and focus in-house

To strengthen its cybersecurity strategy, the company considered two options:

  1. Make a significant initial and ongoing investment in a Security Operations Center (SOC), which would involve skills development outside the company and substantial management overhead.
  2. Use a combination of new, automated tools and an outsourced Managed Detection and Response (MDR) service to reduce the burden on internal security specialists and allow the company to invest in upskilling its staff so they can focus on more strategic tasks.

Faced with this choice between entirely outsourcing security and augmenting the security team with new capabilities, the customer chose the second option, selecting Darktrace to automate the company’s monitoring, detection, and response. Today, the petrochemical manufacturer is using:

Extending the SOC with 24/7 expert support

To alleviate the burden on its lean security team, the company augmented its in-house capabilities with Darktrace’s Managed Detection & Response service. This support acts as an extension of its SOC, providing 24/7 monitoring, investigation, and escalation of high-priority threats. With Darktrace’s global SOC managing alert triage and autonomously containing threats, the organization’s internal team can focus on strategic initiatives. The result is a stronger security posture and increased capacity to proactively address evolving cyber risks – without expanding headcount or sacrificing visibility.

A unique approach to AI

In its search for a new security platform, the company’s Director of Information Technology said Darktrace’s autonomous response capability, coupled with Self-Learning AI-driven threat reduction, were two big reasons for selecting Darktrace over competing products and services.

AI was a huge factor – no one else was doing what Darktrace was doing with [AI].”

Demonstrated visibility

Before Darktrace, the customer had no visibility into the network activity to and from remote worker devices. Some employees need the ability to connect to its networks at any time and from any location, including the Director of Information Technology. The trial deployment of Darktrace / ENDPOINT was a success and gave the team peace of mind that, no matter the location or device, high-value remote workers were protected by Darktrace.

Modular architecture  

Darktrace's modular architecture allowed the company to deploy security controls across its complex, multi-entity environment. The company’s different locations run on segregated networks but are still interconnected and need to be protected. Darktrace / NETWORK provides a unified view and coordinated security response across the organization’s entire network infrastructure, including endpoint devices.

Results

The petrochemical manufacturer is using Darktrace across all of its locations and has achieved total visibility across network and user activity. “Darktrace is increasing in value every day,” said the Director of Information Technology.

I don’t have a big team, and Darktrace makes our lives very, very easy, not least the automation of some of the tasks that require constant manual review.”

Time savings frees analysts to focus on proactive security

Darktrace / NETWORK provides continuous, AI-driven monitoring and analysis of the company’s network activity, user behavior, and threat patterns, establishing a baseline of what normal activity looks like, and then alerting analysts to any deviations from normal traffic, activity, and behaviors. Darktrace’s autonomous response capabilities speed up response to detected threats, meaning intervention from the security team is required for fewer incidents and alerts.

In October 2024 alone, Darktrace Cyber AI Analyst saved the team 810 investigation hours, and autonomously responded to 180 anomalous behaviors that were uncovered during the investigations. With Darktrace managing the majority of threat detection and response efforts, the security team has been able to change its day-to-day activity from manual review of traffic and alerts and belated response to activity, to proactively fortifying its detection and response posture and upskilling to meet evolving requirements.  

Layered email protection reduces phishing threats

The company’s email infrastructure posed a challenge due to petrochemical industry regulations requiring on-premises email servers, with some security delivered via Microsoft Azure. By integrating Darktrace / EMAIL into the Azure stack, the organization has reduced the volume of phishing emails its users receive by 5%.

“Now we have one more layer of security related to email – every email goes through two filters. If something is not being caught or traced by Azure, it is being detected by Darktrace,” said the Director of Information Technology. “As a result, we’re now seeing only about 15% to 20% of the phishing emails we used to receive before implementing Darktrace.”

Preparing for a secure future

The time saved using Darktrace has helped the security team take proactive steps, including preparing for new cyber resilience regulations for Saudi Arabia’s Critical National Infrastructure, as mandated by the National Cybersecurity Authority (NCA).

“The team now has ample time to prepare policies and procedures that meet the new NCA regulations and, in some cases, enhance the requirements of the new law,” said the Director of Information Technology. “All of this is possible because they don’t need to keep watch; Darktrace takes on so much of that task for them.”

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