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September 23, 2025

ShadowV2: An emerging DDoS for hire botnet

Darktrace exposed a cybercrime-as-a-service campaign using Python and Go-based malware, Docker containerization, and a full operator UI. With DDoS-as-a-service features, modular APIs, and advanced evasion, this platform highlights the need for defenders to monitor cloud workloads, container orchestration, and API activity to counter evolving threats.
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
Nate Bill
Threat Researcher
ShadowV2: An emerging DDoS for hire botnet Default blog imageDefault blog imageDefault blog imageDefault blog imageDefault blog imageDefault blog image
23
Sep 2025

Introduction: ShadowV2 DDoS

Darktrace's latest investigation uncovered a novel campaign that blends traditional malware with modern devops technology.

At the center of this campaign is a Python-based command-and-control (C2) framework hosted on GitHub CodeSpaces. This campaign also utilizes a Python based spreader with a multi-stage Docker deployment as the initial access vector.

The campaign further makes use of a Go-based Remote Access Trojan (RAT) that implements a RESTful registration and polling mechanism, enabling command execution and communication with its operators.

ShadowV2 attack techniques

What sets this campaign apart is the sophistication of its attack toolkit.

The threat actors employ advanced methods such as HTTP/2 rapid reset, a Cloudflare under attack mode (UAM) bypass, and large-scale HTTP floods, demonstrating a capability to combine distributed denial-of-service (DDoS) techniques with targeted exploitation.

With the inclusion of an OpenAPI specification, implemented with FastAPI and Pydantic and a fully developed login panel and operator interface, the infrastructure seems to resemble a “DDoS-as-a-service” platform rather than a traditional botnet, showing the extent to which modern malware increasingly mirrors legitimate cloud-native applications in both design and usability.

Analysis of a SadowV2 attack

Initial access

The initial compromise originates from a Python script hosted on GitHub CodeSpaces. This can be inferred from the observed headers:

User-Agent: docker-sdk-python/7.1.0

X-Meta-Source-Client: github/codespaces

The user agent shows that the attacker is using the Python Docker SDK, a library for Python programs that allows them to interact with Docker to create containers. The X-Meta-Source-Client appears to have been injected by GitHub into the request to allow for attribution, although there is no documentation online about this header.

The IP the connections originate from is 23.97.62[.]139, which is a Microsoft IP based in Singapore. This aligns with expectations as GitHub is owned by Microsoft.

This campaign targets exposed Docker daemons, specifically those running on AWS EC2. Darktrace runs a number of honeypots across multiple cloud providers and has only observed attacks against honeypots running on AWS EC2. By default, Docker is not accessible to the Internet, however, can be configured to allow external access. This can be useful for managing complex deployments where remote access to the Docker API is needed.

Typically, most campaigns targeting Docker will either take an existing image from Docker Hub and deploy their tools within it, or upload their own pre-prepared image to deploy. This campaign works slightly differently; it first spawns a generic “setup” container and installs a number of tools within it. This container is then imaged and deployed as a live container with the malware arguments passed in via environmental variables.

Attacker creates a blank container from an Ubuntu image.
Figure 1: Attacker creates a blank container from an Ubuntu image.
Attacker sets up their tools for the attack.
Figure 2: Attacker sets up their tools for the attack.
 Attacker deploys a new container using the image from the setup container.
Figure 3: Attacker deploys a new container using the image from the setup container.

It is unclear why the attackers chose this approach - one possibility is that the actor is attempting to avoid inadvertently leaving forensic artifacts by performing the build on the victim machine, rather than building it themselves and uploading it.

Malware analysis

The Docker container acts as a wrapper around a single binary, dropped in /app/deployment. This is an ELF binary written in Go, a popular choice for modern malware. Helpfully, the binary is unstripped, making analysis significantly easier.

The current version of the malware has not been reported by OSINT providers such as VirusTotal. Using the domain name from the MASTER_ADDR variable and other IoCs, we were able to locate two older versions of the malware that were submitted to VirusTotal on the June 25 and July 30 respectively [1] [2].  Neither of these had any detections and were only submitted once each using the web portal from the US and Canada respectively. Darktrace first observed the attack against its honeypot on June 24, so it could be a victim of this campaign submitting the malware to VirusTotal. Due to the proximity of the start of the attacks, it could also be the attacker testing for detections, however it is not possible to know for certain.

The malware begins by phoning home, using the MASTER_ADDR and VPS_NAME identifiers passed in from the Docker run environmental variables. In addition, the malware derives a unique VPS_ID, which is the VPS_NAME concatenated with the current unix timestamp. The VPS_ID is used for all communications with the C2 server as the identifier for the specific implant. If the malware is restarted, or the victim is re-infected, the C2 server will inform the implant of its original VPS_ID to ensure continuity.

Snippet that performs the registration by sending a POST request to the C2 API with a JSON structure.
Figure 4: Snippet that performs the registration by sending a POST request to the C2 API with a JSON structure.

From there, the malware then spawns two main loops that will remain active for the lifetime of the implant. Every second, it sends a heartbeat to the C2 by sending the VPS_ID to hxxps://shadow.aurozacloud[.]xyz/api/vps/heartbeat via POST request. Every 5 seconds, it retrieves hxxps://shadow.aurozacloud[.]xyz/api/vps/poll/<VPS ID> via a GET request to poll for new commands.

The poll mechanism shadow v2
Figure 5: The poll mechanism.

At this stage, Darktrace security researchers wrote a custom client that ran on the server infected by the attacker that mimicked their implant. The goal was to intercept commands from the C2. Based on this, it was observed initiating an attack against chache08[.]werkecdn[.]me using a 120 thread HTTP2 rapid reset attack. This site appears to be hosted on an Amsterdam VPS provided by FDCServers, a server hosting company. It was not possible to identify what normally runs on this site, as it returns a 403 Forbidden error when visited.

Darktrace’s code analysis found that the returned commands contain the following fields:

  • Method (e.g. GET, POST)
  • A unique ID for the attack
  • A URL endpoint used to report attack statistics
  • The target URL & port
  • The duration of the attack
  • The number of threads to use
  • An optional proxy to send HTTP requests through

The malware then spins up several threads, each running a configurable number of HTTP clients using Valyala’s fasthttp library, an open source Go library for making high-performance HTTP requests. After this is complete, it uses these clients to perform an HTTP flood attack against the target.

A snippet showing the fasthttp client creation loop, as well as a function to report the worker count back to the C2.
Figure 6: A snippet showing the fasthttp client creation loop, as well as a function to report the worker count back to the C2.

In addition, it also features several flags to enable different bypass mechanisms to augment the malware:

  • WordPress bypass (does not appear to be implemented - the flag is not used anywhere)
  • Random query strings appended to the URL
  • Spoofed forwarding headers with random IP addresses
  • Cloudflare under-attack-mode (UAM) bypass
  • HTTP2 rapid reset

The most interesting of these is the Cloudflare UAM bypass mechanism. When this is enabled, the malware will attempt to use a bundled ChromeDP binary to solve the Cloudflare JavaScript challenge that is presented to new visitors. If this succeeds, the clearance cookie obtained is then included in subsequent requests. This is unlikely to work in most cases as headless Chrome browsers are often flagged, and a regular CAPTCHA is instead served.

The UAM bypass success snippet.
Figure 7: The UAM bypass success snippet.

Additionally, the malware has a flag to enable an HTTP2 rapid reset attack mode instead of a regular HTTP flood. In HTTP2, a client can create thousands of requests within a single connection using multiplexing, allowing sites to load faster. The number of request streams per connection is capped however, so in a rapid reset attack many requests are made and then immediately cancelled to allow more requests to be created. This allows a single client to execute vastly more requests per second and use more server resources than it otherwise would, allowing for more effective denial-of-service (DoS) attacks.

 The HTTP2 rapid reset snippet from the main attack function.
Figure 8: The HTTP2 rapid reset snippet from the main attack function.

API/C2 analysis

As mentioned throughout the malware analysis section, the malware communicates with a C2 server using HTTP. The server is behind Cloudflare, which obscures its hosting location and prevents analysis. However, based on analysis of the spreader, it's likely running on GitHub CodeSpaces.

When sending a malformed request to the API, an error generated by the Pydantic library is returned:

{"detail":[{"type":"missing","loc":["body","vps_id"],"msg":"Field required","input":{"vps_name":"xxxxx"},"url":"https://errors.pydantic.dev/2.11/v/missing"}]}

This shows they are using Python for the API, which is the same language that the spreader is written in.

One of the larger frameworks that ships with Pydantic is FastAPI, which also ships with Swagger. The malware author left this publicly exposed, and Darktrace’s researchers were able to obtain a copy of their API documentation. The author appears to have noticed this however, as subsequent attempts to access it now returns a HTTP 404 Not Found error.

Swagger UI view based on the obtained OpenAPI spec.
Figure 9: Swagger UI view based on the obtained OpenAPI spec.

This is useful to have as it shows all the API endpoints, including the exact fields they take and return, along with comments on each endpoint written by the attacker themselves.

It is very likely a DDoS for hire platform (or at the very least, designed for multi-tenant use) based on the extensive user API, which features authentication, distinctions between privilege level (admin vs user), and limitations on what types of attack a user can execute. The screenshot below shows the admin-only user create endpoint, with the default limits.

The admin-only user create endpoint shadow v2
Figure 10: The admin-only user create endpoint.

The endpoint used to launch attacks can also be seen, which lines up with the options previously seen in the malware itself. Interestingly, this endpoint requires a list of zombie systems to launch the attack from. This is unusual as most DDoS for hire services will decide this internally or just launch the attack from every infected host (zombie). No endpoints that returned a list of zombies were found, however, it’s possible one exists as the return types are not documented for all the API endpoints.

The attack start endpoint shadow v2
Figure 11: The attack start endpoint.

There is also an endpoint to manage a blacklist of hosts that cannot be attacked. This could be to stop users from launching attacks against sites operated by the malware author, however it’s also possible the author could be attempting to sell protection to victims, which has been seen previously with other DDoS for hire services.

Blacklist endpoints shadow v2 DDoS
Figure 12: Blacklist endpoints.

Attempting to visit shadow[.]aurozacloud[.]xyz results in a seizure notice. It is most likely fake the same backend is still in use and all of the API endpoints continue to work. Appending /login to the end of the path instead brings up the login screen for the DDoS platform. It describes itself as an “advanced attack platform”, which highlights that it is almost certainly a DDoS for hire service. The UI is high quality, written in Tailwind, and even features animations.

The fake seizure notice.
Figure 13: The fake seizure notice.
The login UI at /login.
Figure 14: The login UI at /login.

Conclusion

By leveraging containerization, an extensive API, and with a full user interface, this campaign shows the continued development of cybercrime-as-a-service. The ability to deliver modular functionality through a Go-based RAT and expose a structured API for operator interaction highlights how sophisticated some threat actors are.

For defenders, the implications are significant. Effective defense requires deep visibility into containerized environments, continuous monitoring of cloud workloads, and behavioral analytics capable of identifying anomalous API usage and container orchestration patterns. The presence of a DDoS-as-a-service panel with full user functionality further emphasizes the need for defenders to think of these campaigns not as isolated tools but as evolving platforms.

Appendices

References

1. https://www.virustotal.com/gui/file/1b552d19a3083572bc433714dfbc2b75eb6930a644696dedd600f9bd755042f6

2. https://www.virustotal.com/gui/file/1f70c78c018175a3e4fa2b3822f1a3bd48a3b923d1fbdeaa5446960ca8133e9c

IoCs

Malware hashes (SHA256)

●      2462467c89b4a62619d0b2957b21876dc4871db41b5d5fe230aa7ad107504c99

●      1b552d19a3083572bc433714dfbc2b75eb6930a644696dedd600f9bd755042f6

●      1f70c78c018175a3e4fa2b3822f1a3bd48a3b923d1fbdeaa5446960ca8133e9c

C2 domain

●      shadow.aurozacloud[.]xyz

Spreader IPs

●      23.97.62[.]139

●      23.97.62[.]136

Yara rule

rule ShadowV2 {

meta:

author = "nathaniel.bill@darktrace.com"

description = "Detects ShadowV2 botnet implant"

strings:

$string1 = "shadow-go"

$string2 = "shadow.aurozacloud.xyz"

$string3 = "[SHADOW-NODE]"

$symbol1 = "main.registerWithMaster"

$symbol2 = "main.handleStartAttack"

$symbol3 = "attacker.bypassUAM"

$symbol4 = "attacker.performHTTP2RapidReset"

$code1 = { 48 8B 05 ?? ?? ?? ?? 48 8B 1D ?? ?? ?? ?? E8 ?? ?? ?? ?? 48 8D 0D ?? ?? ?? ?? 48 89 8C 24 38 01 00 00 48 89 84 24 40 01 00 00 48 8B 4C 24 40 48 BA 00 09 6E 88 F1 FF FF FF 48 8D 04 0A E8 ?? ?? ?? ?? 48 8D 0D ?? ?? ?? ?? 48 89 8C 24 48 01 00 00 48 89 84 24 50 01 00 00 48 8D 05 ?? ?? ?? ?? BB 05 00 00 00 48 8D 8C 24 38 01 00 00 BF 02 00 00 00 48 89 FE E8 ?? ?? ?? ?? }

$code2 = { 48 89 35 ?? ?? ?? ?? 0F B6 94 24 80 02 00 00 88 15 ?? ?? ?? ?? 0F B6 94 24 81 02 00 00 88 15 ?? ?? ?? ?? 0F B6 94 24 82 02 00 00 88 15 ?? ?? ?? ?? 0F B6 94 24 83 02 00 00 88 15 ?? ?? ?? ?? 48 8B 05 ?? ?? ?? ?? }

$code3 = { 48 8D 15 ?? ?? ?? ?? 48 89 94 24 68 04 00 00 48 C7 84 24 78 04 00 00 15 00 00 00 48 8D 15 ?? ?? ?? ?? 48 89 94 24 70 04 00 00 48 8D 15 ?? ?? ?? ?? 48 89 94 24 80 04 00 00 48 8D 35 ?? ?? ?? ?? 48 89 B4 24 88 04 00 00 90 }

condition:

uint16(0) == 0x457f and (2 of ($string*) or 2 of ($symbol*) or any of ($code*))

}

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 without notice.

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
Nate Bill
Threat Researcher

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September 23, 2025

It’s Time to Rethink Cloud Investigations

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Cloud Breaches Are Surging

Cloud adoption has revolutionized how businesses operate, offering speed, scalability, and flexibility. But for security teams, this transformation has introduced a new set of challenges, especially when it comes to incident response (IR) and forensic investigations.

Cloud-related breaches are skyrocketing – 82% of breaches now involve cloud-stored data (IBM Cost of a Data Breach, 2023). Yet incidents often go unnoticed for days: according to a 2025 report by Cybersecurity Insiders, of the 65% of organizations experienced a cloud-related incident in the past year, only 9% detected it within the first hour, and 62% took more than 24 hours to remediate it (Cybersecurity Insiders, Cloud Security Report 2025).

Despite the shift to cloud, many investigation practices remain rooted in legacy on-prem approaches. According to a recent report, 65% of organizations spend approximately 3-5 days longer when investigating an incident in the cloud vs. on premises.

Cloud investigations must evolve, or risk falling behind attackers who are already exploiting the cloud’s speed and complexity.

4 Reasons Cloud Investigations Are Broken

The cloud’s dynamic nature – with its ephemeral workloads and distributed architecture – has outpaced traditional incident response methods. What worked in static, on-prem environments simply doesn’t translate.

Here’s why:

  1. Ephemeral workloads
    Containers and serverless functions can spin up and vanish in minutes. Attackers know this as well – they’re exploiting short-lived assets for “hit-and-run” attacks, leaving almost no forensic footprint. If you’re relying on scheduled scans or manual evidence collection, you’re already too late.
  2. Fragmented tooling
    Each cloud provider has its own logs, APIs, and investigation workflows. In addition, not all logs are enabled by default, cloud providers typically limit the scope of their logs (both in terms of what data they collect and how long they retain it), and some logs are only available through undocumented APIs. This creates siloed views of attacker activity, making it difficult to piece together a coherent timeline. Now layer in SaaS apps, Kubernetes clusters, and shadow IT — suddenly you’re stitching together 20+ tools just to find out what happened. Analysts call it the ‘swivel-chair Olympics,’ and it’s burning hours they don’t have.
  3. SOC overload
    Analysts spend the bulk of their time manually gathering evidence and correlating logs rather than responding to threats. This slows down investigations and increases burnout. SOC teams are drowning in noise; they receive thousands of alerts a day, the majority of which never get touched. False positives eat hundreds of hours a month, and consequently burnout is rife.  
  4. Cost of delay
    The longer an investigation takes, the higher its cost. Breaches contained in under 200 days save an average of over $1M compared to those that linger (IBM Cost of a Data Breach 2025).

These challenges create a dangerous gap for threat actors to exploit. By the time evidence is collected, attackers may have already accessed or exfiltrated data, or entrenched themselves deeper into your environment.

What’s Needed: A New Approach to Cloud Investigations

It’s time to ditch the manual, reactive grind and embrace investigations that are automated, proactive, and built for the world you actually defend. Here’s what the next generation of cloud forensics must deliver:

  • Automated evidence acquisition
    Capture forensic-level data the moment a threat is detected and before assets disappear.
  • Unified multi-cloud visibility
    Stitch together logs, timelines, and context across AWS, Azure, GCP, and hybrid environments into a single unified view of the investigation.
  • Accelerated investigation workflows
    Reduce time-to-insight from hours or days to minutes with automated analysis of forensic data, enabling faster containment and recovery.
  • Empowered SOC teams
    Fully contextualised data and collaboration workflows between teams in the SOC ensure seamless handover, freeing up analysts from manual collection tasks so they can focus on what matters: analysis and response.

Attackers are already leveraging the cloud’s agility. Defenders must do the same — adopting solutions that match the speed and scale of modern infrastructure.

Cloud Changed Everything. It’s Time to Change Investigations.  

The cloud fundamentally reshaped how businesses operate. It’s time for security teams to rethink how they investigate threats.

Forensics can no longer be slow, manual, and reactive. It must be instant, automated, and cloud-first — designed to meet the demands of ephemeral infrastructure and multi-cloud complexity.

The future of incident response isn’t just faster. It’s smarter, more scalable, and built for the environments we defend today, not those of ten years ago.  

On October 9th, Darktrace is revealing the next big thing in cloud security. Don’t miss it – sign up for the webinar.

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Kellie Regan
Director, Product Marketing - Cloud Security

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September 22, 2025

Understanding the Canadian Critical Cyber Systems Protection Act

Canadian critical cyber systems protection actDefault blog imageDefault blog image

Introduction: The Canadian Critical Cyber Systems Protection Act

On 18 June 2025, the Canadian federal Government introduced Bill C-8 which, if adopted following completion of the legislative process, will enact the Critical Cyber Systems Protection Act (CCSPA) and give Canada its first federal, cross-sector and legally binding cybersecurity regime for designated critical infrastructure providers. As of August 2025, the Bill has completed first reading and stands at second reading in the Canadian House of Commons.

Political context

The measure revives most of the stalled 2022 Bill C-26 “An Act Respecting Cyber Security” which “died on Paper” when Parliament was prorogued in January 2025, in the wake of former Prime Minister Justin Trudeau’s resignation.

The new government, led by Mark Carney since March 2025, has re-tabled the package with the same two-part structure: (1) amendments to the Telecommunications Act that enable security directions to telecoms; and (2) a new CCSPA setting out mandatory cybersecurity duties for designated operators. This blog focuses on the latter.

If enacted, Canada will join fellow Five Eyes partners such as the United Kingdom and Australia, which already impose statutory cyber-security duties on operators of critical national infrastructure.

The case for new cybersecurity legislation in Canada

The Canadian cyber threat landscape has expanded. The country's national cyber authority, the Canadian Centre for Cybersecurity (Cyber Centre), recently assessed that the number of cyber incidents has “sharply increased” in the last two years, as has the severity of those incidents, with essential services providers among the targets. Likewise, in its 2025-2026 National Cyber Threat Assessment, the Cyber Centre warned that AI technologies are “amplifying cyberspace threats” by lowering barriers to entry, improving the speed and sophistication of social-engineering attacks and enabling more precise operations.

This context mirrors what we are seeing globally: adversaries, including state actors, are taking advantage of the availability and sophistication of AI tools, which they have leverage to amplify the effectiveness of their operations. In this increasingly complex landscape, regulation must keep pace and evolve in step with the risk.

What the Canadian Critical Cyber Systems Protection Act aims to achieve

  • If enacted, the CCSPA will apply to operators in federally regulated critical infrastructure sectors which are vital to national security and public safety, as further defined in “Scope” below (the “Regulated Entities”), to adopt and comply with a minimum standard of cybersecurity duties (further described below)  which align with those its Five Eyes counterparts are already adhering to.

Who does the CCSPA apply to

The CCSPA would apply to designated operators that deliver services or systems within federal jurisdiction in the following priority areas:

  • telecommunications services
  • interprovincial or international pipeline and power line systems, nuclear energy systems, transportation systems
  • banking and clearing  
  • settlement systems

The CCSPA would also grant the Governor in Council (Federal Cabinet) with powers to add or remove entities in scope via regulation.

Scope of the CCSPA

The CCSPA introduces two key instruments:

First, it strengthens cyber threat information sharing between responsible ministers, sector regulators, and the Communications Security Establishment (through the Cyber Centre).

Second, it empowers the Governor in Council (GIC) to issue Cyber Security Directions (CSDs) - binding orders requiring a designated operator to implement specified measures to protect a critical cyber system within defined timeframes.

CSDs may be tailored to an individual operator or applied to a class of operators and can address technology, process, or supplier risks. To safeguard security and commercial confidentiality, the CCSPA restricts disclosure of the existence or content of a CSD except as necessary to carry it out.

Locating decision-making with the GIC ensures that CSDs are made with a cross-government view that weighs national security, economic priorities and international agreement.

New obligations for designated providers

The CCSPA would impose key cybersecurity compliance and obligations on designated providers. As it stands, this includes:

  1. Establishing and maintaining cybersecurity programs: these will need to be comprehensive, proportionate and developed proactively. Once implemented, they will need to be continuously reviewed
  2. Mitigating supply chain risks: Regulated Entities will be required to assess their third-party products and services by conducting a supply chain analysis, and take active steps to mitigate any identified risks
  3. Reporting incidents:  Regulated Entities will need to be more transparent with their reporting, by making the Communications Security Establishment (CSE) aware of any incident which has, or could potentially have, an impact on a critical system. The reports must be made within specific timelines, but in any event within no more than 72 hours;
  4. Compliance with cybersecurity directions:  the government will, under the CCSPA, have the authority to issue cybersecurity directives in an effort to remain responsive to emerging threats, which Regulated Entities will be required to follow once issued
  5. Record keeping: this shouldn’t be a surprise to many of those Regulated Entities which fall in scope, which are already likely to be subject to record keeping requirements. Regulated Entities should expect to be maintaining records and conducting audits of their systems and processes against the requirements of the CCSPA

It should be noted, however, that this may be subject to change, so Regulated Entities should keep an eye on the progress of the Bill as it makes its way through parliament.

Enforcement of the Act would be carried out by sector-specific regulators identified in the Act such as the Office of the Superintendent of Financial Institutions, Minister of Transport, Canada Energy Regulator, Canadian Nuclear Safety Commission and the Ministry of Industry.

What are the penalties for CCSPA non-compliance?

When assessing the penalties associated with non-compliance with the requirements of the CCSPA, it is clear that such non-compliance will be taken seriously, and the severity of the penalties follows the trend of those applied by the European Union to key pieces of EU legislation. The “administrative monetary penalties” (AMPs) set by regulation could see fines being applied of up to C$1 million for individuals and up to C$15 million for organizations.

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