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.
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
John Allen
SVP, Field CISO
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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
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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Boosting Security with Azure Virtual Network TAP Traffic Mirroring
We are thrilled to announce that Darktrace is a launch partner for the Public Preview of Microsoft Azure Virtual Network Terminal Access Point (TAP). As Microsoft's 2024 UK Partner of the Year, we continue to innovate alongside Microsoft to deliver proactive cyber protection tailored to every organization.
Enhanced Defense Across the Modern Network
Modern networks are expanding far beyond on-premises into virtual environments, cloud and hybrid networks. More than 50% of incidents will come from cloud network activity by 2029, meaning defenders need a solution that can level the playing field against complex attacks that traverse multiple areas of a digital estate, including north-south and east-west traffic.
With Azure Virtual Network TAP, Darktrace’s self-learning AI gains seamless access to granular packet data in hybrid environments. This integration helps our Cyber AI platform build a comprehensive understanding of a customers’ Azure network. Microsoft's recent enhancement allows Virtual Network TAP to mirror the full throughput of VMs without impacting VM bandwidth, enabling agentless Cyber AI defense across these instances.
Darktrace's Cyber AI provides real-time visibility and adaptive, autonomous defense for your Microsoft security strategy. Our platform continuously learns the normal behavior of every user, device, and workload in your environment. This deep understanding of usual 'patterns of life' enables Darktrace to detect subtle deviations that indicate threats, from account takeovers to critical misconfigurations.
Our bespoke, real-time knowledge of usual activity allows Darktrace to identify unknown and unpredictable threats that bypass policy-based defenses—without relying on rules, signatures, or prior assumptions. This approach is a powerful compliment to Microsoft’s unprecedented threat intelligence.
Expanding Azure Virtual Network TAP
Azure Virtual Network TAP allows continuous streaming of virtual machine network traffic, which customers can leverage for Darktrace’s AI-driven threat detection and investigation. Darktrace / NETWORK passively ingests traffic from on-premises, virtual, cloud, hybrid environments, and remote devices, analyzing both encrypted and decrypted packets to uncover unusual activity in real-time. Unlike other NDR vendors that process data in the cloud, our industry-leading Self-Learning AI is deployed locally and trained solely on your data, ensuring tailored security outcomes without compromising privacy.
Benefits to Darktrace Customers
Darktrace customers will experience enhanced security through deeper insights into network traffic, enabling more accurate threat detection and response. The ability to mirror full VM throughput without affecting bandwidth ensures optimal performance, while agentless defense reduces barrier to entry and simplifies management. Customers benefit from proactive protection by continuously monitoring and analyzing traffic to identify and mitigate threats before they cause harm. Additionally, seamless integration with existing Azure environments leverages the power of Darktrace’s AI for enhanced security.
MFA Under Attack: AiTM Phishing Kits Abusing Legitimate Services
In late 2024 and early 2025, the Darktrace Security Operations Center (SOC) investigated alerts regarding separate cases of Software-as-a-Service (SaaS) account compromises on two customer environments that presented several similarities, suggesting they were part of a wider phishing campaign.
This campaign was found to leverage the project collaboration and note-taking application, Milanote, and the Tycoon 2FA phishing kit.
Legitimate services abused
As highlighted in Darktrace's 2024 Annual Threat Report [1], threat actors are abusing legitimate services, like Milanote, in their phishing campaigns. By leveraging these trusted platforms and domains, malicious actors can bypass traditional security measures, making their phishing emails appear benign and increasing the likelihood of successful attacks.
Darktrace categorizes these senders and platforms as free content senders. These services allow users to send emails containing custom content (e.g., files) from fully validated, fixed service address belonging to legitimate corporations. Although some of these services permit full body and subject customization by attackers, the structure of these emails is generally consistent, making it challenging to differentiate between legitimate and malicious emails.
What is Tycoon 2FA?
Tycoon 2FA is an Adversary-in-the-Middle (AitM) phishing kit, first seen in August 2023 and distributed via the Phishing-as-a-Service (PhaaS) model [2]. It targets multi-factor authentication (MFA) by intercepting credentials and MFA tokens during authentication on fake Microsoft or Google login pages. The attacker captures session cookies after MFA is completed, allowing them to replay the session and access the user account, even if credentials are reset. The rise in MFA use has increased the popularity of AitM phishing kits like Tycoon 2FA and Mamba 2FA, another AiTM phishing kit investigated by Darktrace.
Initial access via phishing email
At the beginning of 2025, Darktrace observed phishing emails leveraging Milanote being sent to multiple internal recipients in an organization. In this attack, the same email was sent to 19 different users, all of which were held by Darktrace.
The subject line of the emails mentioned both a legitimate internal user of the company, the company name, as well as a Milanote board regarding a “new agreement” in German. It is a common social engineering technique to mention urgent matters, such as unpaid invoices, expired passwords, or awaiting voicemails, in the subject line to prompt immediate action from the user. However, this tactic is now widely covered in phishing awareness training, making users more suspicious of such emails. In this case, while the subject mentioned a “new agreement,” likely raising the recipient’s curiosity, the tone remained professional and not overly alarming. Additionally, the mention of a colleague and the standardized language typical of free content sender emails further helped dispel concerns regarding the email.
These emails were sent by the legitimate address support@milanote[.]com and referenced "Milanote" in the personal field of the header but originated from the freemail address “ahnermatternk.ef.od.13@gmail[.]com”. Darktrace / EMAIL recognized that none of the recipients had previously received a file share email from Milanote, making this sender unfamiliar in the customer's email environment
The emails contained several benign links to legitimate Milanote endpoints (including an unsubscribe link) which were not flagged by Darktrace. However, they also included a malicious link designed to direct recipients to a pre-filled credential harvesting page hosted on Milanote, prompting them to register for an account. Despite not blocking the legitimate Milanote links in the same email, Darktrace locked the malicious link, preventing users from visiting the credential harvester.
Figure 1: Credential harvesting page sent to recipients, as seen in. sandbox environment.
Around one minute later, one recipient received a legitimate email from Milanote confirming their successful account registration, indicating they had accessed the phishing page. This email had a lower anomaly score and was not flagged by Darktrace / EMAIL because, unlike the first email, it did not contain any suspicious links and was a genuine account registration notification. Similarly, in the malicious Milanote email, only the link leading to the phishing page was blocked, while the benign and legitimate Milanote links remained accessible, demonstrating Darktrace’s precise and targeted actioning.
Figure 2: A legitimate and a malicious Milanote email received by one recipient.
Around the same time, Darktrace / NETWORK observed the same user’s device making DNS query for the domain name “lrn.ialeahed[.]com” , which has been flagged as a Tycoon 2FA domain [2], suggesting the use of this phishing platform.
Once the user had entered their details in the credential harvester, it is likely that they were presented a document hosted on Milanote that contained the final payload link – likely hidden behind text instructing users to access a “new agreement” document.
External research indicates that the user was likely directed to a Cloudflare Turnstile challenge meant to reroute unwanted traffic, such as automated security scripts and penetration testing tools [2] [3]. After these checks and other background processes are completed, the user is directed to the final landing page. In this case, it was likely a fake login prompt hosted on the attacker’s server, where the user is asked to authenticate to their account using MFA. By burrowing malicious links and files in this manner, threat actors can evade analysis by traditional security email gateways, effectively bypassing their protection.
Darktrace’s analysis of the structure and word content of the phishing emails resulted in an 82% probability score that the email was malicious, and the email further received a 67% phishing inducement score, representing how closely the structure and word content of the emails compared to typical phishing emails.
All these unusual elements triggered multiple alerts in Darktrace / EMAIL, focusing on two main suspicious aspects: a new, unknown sender with no prior correspondence with the recipients or the environment, and the inclusion of a link to a previously unseen file storage solution.
Figure 3: Milanote phishing email as seen within Darktrace / EMAIL.
After detecting the fifth email, the “Sender Surge” model alert was triggered in Darktrace / EMAIL due to a significant number of recipients being emailed by this new suspicious sender in a short period. These recipients were from various departments across the customer’s organization, including sales, marketing, purchasing, and production. Darktrace / EMAIL determined that the emails were sent to a highly unusual group of internal recipients, further raising doubts about the business legitimacy.
Darktrace / EMAIL suggested actions to contain the attack by holding all Milanote phishing emails back from recipient’s inboxes, except for the detailed email with locked links. However, autonomous actions were not enabled at the time, allowing the initial email to reach recipients' inboxes, providing a brief window for interaction. Unfortunately, during this window, one recipient clicked on the Milanote payload link, leading to the compromise of their account.
SaaS account takeover
About three minutes after the malicious Milanote email was received, Darktrace / IDENTITY detected an unusual login to the email recipient’s SaaS account. The SaaS actor was observed accessing files from their usual location in Germany, while simultaneously, a 100% rare login occurred from a location in the US that had never been seen in the customer’s environment before. This login was also flagged as suspicious by Microsoft 365, triggering a 'Conditional Access Policy' that required MFA authentication, which was successfully completed.
Figure 4: Tycoon 2FA adnimistration panel login page dated from October 2023 [3].
Despite the successful authentication, Darktrace / IDENTITY recognized that the login from this unusual location, coupled with simultaneous activity in another geographically distant location, were highly suspicious. Darktrace went on to observe MFA-validated logins from three separate US-based IP addresses: 89.185.80[.]19, 5.181.3[.]68, and 38.242.7[.]252. Most of the malicious activity was performed from the latter, which is associated with the Hide My Ass (HMA) VPN network [5].
Figure 5: Darktrace’s detection of the suspicious login from the US while the legitimate user was logged in from Germany.
Figure 6: Darktrace’s detection of the suspicious login following successful MFA authentication.
Following this, the malicious actor accessed the user’s inbox and created a new mailbox rule named “GTH” that deleted any incoming email containing the string “milanote” in the subject line or body. Rules like this are a common technique used by attackers to leverage compromised accounts for launching phishing campaigns and concealing replies to phishing emails that might raise suspicions among legitimate account holders. Using legitimate, albeit compromised, accounts to send additional phishing emails enhances the apparent legitimacy of the malicious emails. This tactic has been reported as being used by Tycoon 2FA attackers [4].
The attacker accessed over 140 emails within the legitimate user’s inbox, including both the inbox and the “Sent Items” folder. Notably, the attacker accessed five emails in the “Sent Items” folder and modified their attachments. These emails were mainly related to invoices, suggesting the threat actor may have been looking to hijack those email threads to send fake invoices or replicate previous invoice emails.
Darktrace’s Cyber AI AnalystTM launched autonomous investigations into the individual events surrounding this suspicious activity. It connected these separate events into a single, broad account takeover incident, providing the customer with a clearer view of the ongoing compromise.
Figure 7: Cyber AI Analyst’s detection of unusual SaaS account activities in a single incident.
Figure 8: Cyber AI Analyst investigation of suspicious activities performed by the attacker.
Darktrace's response
Within three minutes of the first unusual login alert, Darktrace’s Autonomous Response intervened, disabling the compromised user account for two hours.
As the impacted customer was subscribed to the Managed Threat Detection Service, Darktrace’s SOC team investigated the activity further and promptly alerted the customer’s security team. With the user’s account still disabled by Autonomous Response, the attack was contained, allowing the customer’s security team valuable time to investigate and remediate. Within ten minutes of receiving the alert from Darktrace’s SOC, they reset the user’s password, closed all active SaaS sessions, and deleted the malicious email rule. Darktrace’s SOC further supported the customer through the Security Operations Service Support service by providing information about the data accessed and identifying any other affected users.
Figure 9: Autonomous Response actions carried out by Darktrace / IDENTITY to contain the malicious activity.
A wider Milanote phishing campaign?
Around a month before this compromise activity, Darktrace alerted another customer to similar activities involving two compromised user accounts. These accounts created new inbox rules named “GFH” and “GVB” to delete all incoming emails containing the string “milanote” in their subject line and/or body.
The phishing emails that led to the compromise of these user accounts were similar to the ones discussed above. Specifically, these emails were sent via the Milanote platform and referenced a “new agreement” (in Spanish) being shared by a colleague. Additionally, the payload link included in the phishing emails showed the same UserPrincipalName (UPN) attribute (i.e., click?upn=u001.qLX9yCzR), which has been seen in other Milanote phishing emails leveraging Tycoon 2FA reported by OSINT sources [6]. Interestingly, in some cases, the email also referenced a “new agreement” in Portuguese, indicating a global campaign.
Based on the similarities in the rule’s naming convention and action, as well as the similarities in the phishing email subjects, it is likely that these were part of the same campaign leveraging Milanote and Tycoon 2FA to compromise user accounts. Since its introduction, the Tycoon 2FA phishing kit has undergone several enhancements to increase its stealth and obfuscation methods, making it harder for security tools to detect. For example, the latest versions contain special source code to obstruct web page analysis by defenders, prevent users from copying meaningful text from the phishing webpages, and disable the right-click menu to prevent offline analysis [4].
Conclusion
Threat actors are continually employing new methods to bypass security detection tools and measures. As highlighted in this blog, even robust security mechanisms like MFA can be compromised using AitM phishing kits. The misuse of legitimate services such as Milanote for malicious purposes can help attackers evade traditional email security solutions by blurring the distinction between legitimate and malicious content.
This is why security tools based on anomaly detection are crucial for defending against such attacks. However, user awareness is equally important. Delays in processing can impact the speed of response, making it essential for users to be informed about these threats.
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