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July 17, 2024

What you need to know about the new SEC Cybersecurity rules

In July 2023, the U.S. Securities and Exchange Commission (SEC) adopted new rules concerning cybersecurity incidents and disclosures. This blog describes the new rules and demonstrates how Darktrace can help organizations achieve compliance with these standards.
Inside the SOC
Darktrace cyber analysts are world-class experts in threat intelligence, threat hunting and incident response, and provide 24/7 SOC support to thousands of Darktrace customers around the globe. Inside the SOC is exclusively authored by these experts, providing analysis of cyber incidents and threat trends, based on real-world experience in the field.
Written by
Kendra Gonzalez Duran
Principal Analyst
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17
Jul 2024

What is new in 2023 to SEC cybersecurity rules?

Form 8-K Item 1.05: Requiring the timely disclosure of material cybersecurity incidents.

Regulation S-K item 106: requiring registrants’ annual reports on Form 10-K to address cybersecurity risk management, strategy, and governance processes.

Comparable disclosures are required for reporting foreign private issuers on Forms 6-K and 20-F respectively.

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

Form 8-K Item 1.05 requires the following to be reported within four business days from when an incident is determined to be “material” (1), unless extensions are granted by the SEC under certain qualifying conditions:

“If the registrant experiences a cybersecurity incident that is determined by the registrant to be material, describe the material aspects of the nature, scope, and timing of the incident, and the material impact or reasonably likely material impact on the registrant, including its financial condition and results of operations.” (2, 3)

How does the SEC define cybersecurity incident?

Cybersecurity incident defined by the SEC means an unauthorized occurrence, or a series of related unauthorized occurrences, on or conducted through a registrant’s information systems that jeopardizes the confidentiality, integrity, or availability of a registrant’s information systems or any information residing therein. (4)

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

Accelerate reporting

Darktrace’s Cyber AI Analyst generates automated reports that synthesize discrete data points potentially indicative of cybersecurity threats, forming reports that provide an overview of the evolution and impact of a threat.

Thus, when a potential threat is identified by Darktrace, AI Analyst can quickly compile information that organizations might include in their disclosure of an occurrence they determined to be material, including the following: incident timelines, incident events, incident summary, related model breaches, investigation process (i.e., how Darktrace’s AI conducted the investigation), linked incident events, and incident details. The figure below illustrates how Darktrace compiles and presents incident information and insights in the UI.

Overview of information provided in an ‘AI Analyst Report’ that could be relevant to registrants reporting a material cybersecurity incident to the SEC
Figure 1: Overview of information provided in an ‘AI Analyst Report’ that could be relevant to registrants reporting a material cybersecurity incident to the SEC

It should be noted that Instruction 4 to the new Form 8-K Item 1.05 specifies the “registrant need not disclose specific or technical information about its planned response to the incident or its cybersecurity systems, related networks and devices, or potential system vulnerabilities in such detail as would impede the registrant’s response or remediation of the incident” (5).

As such, the incident report generated by Darktrace may provide more information, including technical details, than is needed for the 8-K disclosure. In general, users should take appropriate measures to ensure that the information they provide in SEC reports meets the requirements outlined by the relevant regulations. Darktrace cannot recommend that an incident should be reported, nor report an incident itself.

Determine if a cybersecurity incident is material

Item 1.05 requires registrants to determine for themselves whether cybersecurity incidents qualify as ‘material’. This involves considerations such as ‘the nature scope and timing of the incident, and the material impact or reasonably likely material impact on the registrant, including its financial condition and results of operations.’

While it is up to the registrant to determine, consistent with existing legal standards, the materiality of an incident, Darktrace’s solution can provide relevant information which might aid in this evaluation. Darktrace’s Threat Visualizer user interface provides a 3-D visualization of an organization’s digital environment, allowing users to assess the likely degree to which an attack may have spread throughout their digital environment. Darktrace Cyber AI Analyst identifies connections among discrete occurrences of threatening activity, which can help registrants quickly assess the ‘scope and timing of an incident'.

Furthermore, in order to establish materiality it would be useful to understand how an attack might extend across recipients and environments. In the image below, Darktrace/Email identifies how a user was impacted across different platforms. In this example, Darktrace/Email identified an attacker that deployed a dual channel social engineering attack via both email and a SaaS platform in an effort to acquire login credentials. In this case, the attacker useding a legitimate SharePoint link that only reveals itself to be malicious upon click. Once the attacker gained the credentials, it proceeded to change email rules to obfuscate its activity.

Darktrace/Email presents this information in one location, making such investigations easier for the end user.

Darktrace/Email indicating a threat across SaaS and email
Figure 2: Darktrace/Email indicating a threat across SaaS and email

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

The new rules add Item 106 to Regulation S-K requiring registrants to disclose certain information regarding their risk management, strategy, and governance relating to cybersecurity in their annual reports on Form 10-K. The new rules add Item 16K to Form 20-F to require comparable disclosure by [foreign private issuers] in their annual reports on Form 20-F. (6)

SEC cybersecurity rules: Risk management

Specifically, with respect to risk management, Item 106(b) and Item 16K(b) require registrants to describe their processes, if any, for assessing, identifying, and managing material risks from cybersecurity threats, as well as whether any risks from cybersecurity threats, including as a result of any previous cybersecurity incidents, have materially affected or are reasonably likely to materially affect them. The new rules include a non-exclusive list of disclosure items registrants should provide based on their facts and circumstances. (6)

SEC cybersecurity rules: Governance

With respect to governance, Item 106 and Item 16K require registrants to describe the board of directors’ oversight of risks from cybersecurity threats (including identifying any board committee or subcommittee responsible for such oversight) and management’s role in assessing and managing material risks from cybersecurity threats. (6)

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

Impact scores

Darktrace End-to-End (E2E) leverages AI to understand the complex relationships across users and devices to model possible attack paths, giving security teams a contextual understanding of risk across their digital environments beyond isolated CVEs or CVSS scores. Additionally, teams can prioritize risk management actions to increase their cyber resilience through the E2E Advisory dashboard.

Attack paths consider:

  • Potential damages: Both the potential consequences if a given device was compromised and its immediate implications on other devices.
  • Exposure: Devices' level of interactivity and accessibility. For example, how many emails does a user get via mailing lists and from what kind of sources?
  • Impact: Where a user or asset sits in terms of the IT or business hierarchy and how they communicate with each other. Darktrace can simulate a range of possible outcomes for an uncertain event.
  • Weakness: A device’s patch latency and difficulty, a composite metric that looks at attacker MITRE methods and our own scores to determine how hard each stage of compromise is to achieve.

Because the SEC cybersecurity rules require “oversight of risks from cybersecurity threats” and “management’s role in assessing and managing material risks from cybersecurity threats” (6), the scores generated by Darktrace E2E can aid end-user’s ability to identify risks facing their organization and assign responsibilities to address those risks.

E2E attack paths leverage a deep understanding of a customer’ digital environment and highlight potential attack routes that an attacker could leverage to reach critical assets or entities. Difficulty scores (see Figure 5) allow security teams to measure potential damage, exposure, and impact of an attack on a specific asset or entity.

An example of an attack path in a digital environment
Figure 3: An example of an attack path in a digital environment

Automatic executive threat reports

Darktrace’s solution automatically produces Executive Threat Reports that present a simple visual overview of model breaches (i.e., indicators of unusual and threatening behaviors) and activity in the network environment. Reports can be customized to include extra details or restricted to high level information.

These reports can be generated on a weekly, quarterly, and yearly basis, and can be documented by registrants in relation to Item 106(b) to document parts of their efforts toward assessing, identifying, and managing material risks from cybersecurity threats.

Moreover, Cyber AI Analyst incident reports (described above) can be leveraged to document key details concerning significant previous incidents identified by the Darktrace solution that the registrant determined to be ‘material’.

While the disclosures required by Item 106(c) relate to the governance processes by which the board of directors, the management, and other responsible bodies within an organization oversee risks resulting from cybersecurity threats, the information provided by Darktrace’s Executive Threat Reports and Cyber AI Analyst incident reports can also help relevant stakeholders communicate more effectively regarding the threat landscape and previous incidents.

DISCLAIMER

The material above is provided for informational purposes only. This summary does not constitute legal or compliance advice, recommendations, or guidance. Darktrace encourages you to verify the contents of this summary with your own advisors.

References

  1. Note that the rule does not set forth any specific timeline between the incident and the materiality determination, but the materiality determination should be made without unreasonable delay.
  2. https://www.sec.gov/files/form8-k.pdf
  3. https://www.sec.gov/news/press-release/2023-139
  4. https://www.ecfr.gov/current/title-17/chapter-II/part-229
  5. https://www.sec.gov/files/form8-k.pdf
  6. https://www.sec.gov/corpfin/secg-cybersecurity
Inside the SOC
Darktrace cyber analysts are world-class experts in threat intelligence, threat hunting and incident response, and provide 24/7 SOC support to thousands of Darktrace customers around the globe. Inside the SOC is exclusively authored by these experts, providing analysis of cyber incidents and threat trends, based on real-world experience in the field.
Written by
Kendra Gonzalez Duran
Principal Analyst

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April 30, 2026

Mythos vs Ethos: Defending in an Era of AI‑Accelerated Vulnerability Discovery

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Anthropic’s Mythos and what it means for security teams

Recent attention on systems such as Anthropic Mythos highlights a notable problem for defenders. Namely that disclosure’s role in coordinating defensive action is eroding.

As AI systems gain stronger reasoning and coding capability, their usefulness in analyzing complex software environments and identifying weaknesses naturally increases. What has changed is not attacker motivation, but the conditions under which defenders learn about and organize around risk. Vulnerability discovery and exploitation increasingly unfold in ways that turn disclosure into a retrospective signal rather than a reliable starting point for defense.

Faster discovery was inevitable and is already visible

The acceleration of vulnerability discovery was already observable across the ecosystem. Publicly disclosed vulnerabilities (CVEs) have grown at double-digit rates for the past two years, including a 32% increase in 2024 according to NIST, driven in part by AI even prior to Anthropic’s Mythos model. Most notably XBOW topped the HackerOne US bug bounty leaderboard, marking the first time an autonomous penetration tester had done so.  

The technical frontier for AI capabilities has been described elsewhere as jagged, and the implication is that Mythos is exceptional but not unique in this capability. While Mythos appears to make significant progress in complex vulnerability analysis, many other models are already able to find and exploit weaknesses to varying degrees.  

What matters here is not which model performs best, but the fact that vulnerability discovery is no longer a scarce or tightly bounded capability.

The consequence of this shift is not simply earlier discovery. It is a change in the defender-attacker race condition. Disclosure once acted as a rough synchronization point. While attackers sometimes had earlier knowledge, disclosure generally marked the moment when risk became visible and defensive action could be broadly coordinated. Increasingly, that coordination will no longer exist. Exploitation may be underway well before a CVE is published, if it is published at all.

Why patch velocity alone is not the answer

The instinctive response to this shift is to focus on patching faster, but treating patch velocity as the primary solution misunderstands the problem. Most organizations are already constrained in how quickly they can remediate vulnerabilities. Asset sprawl, operational risk, testing requirements, uptime commitments, and unclear ownership all limit response speed, even when vulnerabilities are well understood.

If discovery and exploitation now routinely precede disclosure, then patching cannot be the first line of defense. It becomes one necessary control applied within a timeline that has already shifted. This does not imply that organizations should patch less. It means that patching cannot serve as the organizing principle for defense.

Defense needs a more stable anchor

If disclosure no longer defines when defense begins, then defense needs a reference point that does not depend on knowing the vulnerability in advance.  

Every digital environment has a behavioral character. Systems authenticate, communicate, execute processes, and access resources in relatively consistent ways over time. These patterns are not static rules or signatures. They are learned behaviors that reflect how an organization operates.

When exploitation occurs, even via previously unknown vulnerabilities, those behavioral patterns change.

Attackers may use novel techniques, but they still need to gain access, create processes, move laterally, and will ultimately interact with systems in ways that diverge from what is expected. That deviation is observable regardless of whether the underlying weakness has been formally named.

In an environment where disclosure can no longer be relied on for timing or coordination, behavioral understanding is no longer an optional enhancement; it becomes the only consistently available defensive signal.

Detecting risk before disclosure

Darktrace’s threat research has consistently shown that malicious activity often becomes visible before public disclosure.

In multiple cases, including exploitation of Ivanti, SAP NetWeaver, and Trimble Cityworks, Darktrace detected anomalous behavior days or weeks ahead of CVE publication. These detections did not rely on signatures, threat intelligence feeds, or awareness of the vulnerability itself. They emerged because systems began behaving in ways that did not align with their established patterns.

This reflects a defensive approach grounded in ‘Ethos’, in contrast to the unbounded exploration represented by ‘Mythos’. Here, Mythos describes continuous vulnerability discovery at speed and scale. Ethos reflects an understanding of what is normal and expected within a specific environment, grounded in observed behavior.

Revisiting assume breach

These conditions reinforce a principle long embedded in Zero Trust thinking: assume breach.

If exploitation can occur before disclosure, patching vulnerabilities can no longer act as the organizing principle for defense. Instead, effective defense must focus on monitoring for misuse and constraining attacker activity once access is achieved. Behavioral monitoring allows organizations to identify early‑stage compromise and respond while uncertainty remains, rather than waiting for formal verification.

AI plays a critical role here, not by predicting every exploit, but by continuously learning what normal looks like within a specific environment and identifying meaningful deviation at machine speed. Identifying that deviation enables defenders to respond by constraining activity back towards normal patterns of behavior.

Not an arms race, but an asymmetry

AI is often framed as fueling an arms race between attackers and defenders. In practice, the more important dynamic is asymmetry.

Attackers operate broadly, scanning many environments for opportunities. Defenders operate deeply within their own systems, and it’s this business context which is so significant. Behavioral understanding gives defenders a durable advantage. Attackers may automate discovery, but they cannot easily reproduce what belonging looks like inside a particular organization.

A changed defensive model

AI‑accelerated vulnerability discovery does not mean defenders have lost. It does mean that disclosure‑driven, patch‑centric models no longer provide a sufficient foundation for resilience.

As vulnerability volumes grow and exploitation timelines compress, effective defense increasingly depends on continuous behavioral understanding, detection that does not rely on prior disclosure, and rapid containment to limit impact. In this model, CVEs confirm risk rather than define when defense begins.

The industry has already seen this approach work in practice. As AI continues to reshape both offense and defense, behavioral detection will move from being complementary to being essential.

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About the author
Andrew Hollister
Principal Solutions Engineer, Cyber Technician

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April 29, 2026

Darktrace Malware Analysis: Jenkins Honeypot Reveals Emerging Botnet Targeting Online Games

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DDoS Botnet discovery

To observe adversary behavior in real time, Darktrace operates a global honeypot network known as “CloudyPots”, designed to capture malicious activity across a wide range of services, protocols, and cloud platforms. These honeypots provide valuable insights into the techniques, tools, and malware actively targeting internet‑facing infrastructure.

How attackers used a Jenkins honeypot to deploy the botnet

One such software honeypotted by Darktrace is Jenkins, a CI build system that allows developers to build code and run tests automatically. The instance of Jenkins in Darktrace’s honeypot is intentionally configured with a weak password, allowing attackers to obtain remote code execution on the service.

In one instance observed by Darktrace on March 18, 2026, a threat actor seemingly attempted to target Darktrace’s Jenkins honeypot to deploy a distributed denial-of-service (DDoS) botnet. Further analysis by Darktrace’s Threat Research team revealed the botnet was intended to specifically target video game servers.

How the Jenkins scriptText endpoint was used for remote code execution

The Jenkins build system features an endpoint named scriptText, which enables users to programmatically send new jobs, in the form of a Groovy script. Groovy is a programming language with similar syntax to Java and runs using the Java Virtual Machine (JVM). An attacker can abuse the scriptText endpoint to run a malicious script, achieving code execution on the victim host.

Request sent to the scriptText endpoint containing the malicious script.
Figure 1: Request sent to the scriptText endpoint containing the malicious script.

The malicious script is sent using the form-data content type, which results in the contents of the script being URL encoded. This encoding can be decoded to recover the original script, as shown in Figure 2, where Darktrace Analysts decoded the script using CyberChef,

The malicious script decoded using CyberChef.
Figure 2: The malicious script decoded using CyberChef.

What happens after Jenkins is compromised

As Jenkins can be deployed on both Microsoft Windows and Linux systems, the script includes separate branches to target each platform.

In the case of Windows, the script performs the following actions:

  • Downloads a payload from 103[.]177.110.202/w.exe and saves it to C:\Windows\Temp\update.dat.
  • Renames the “update.dat” file to “win_sys.exe” (within the same folder)
  • Runs the Unblock-File command is used to remove security restrictions typically applied to files downloaded from the internet.
  • Adds a firewall allow rule is added for TCP port 5444, which the payload uses for command-and-control (C2) communications.

On Linux systems, the script will instead use a Bash one-liner to download the payload from 103[.]177.110.202/bot_x64.exe to /tmp/bot and execute it.

Why this botnet uses a single IP for delivery and command and control

The IP 103[.]177.110.202 belongs to Webico Company Limited, specifically its Tino brand, a Vietnamese company that offers domain registrar services and server hosting. Geolocation data indicates that the IP is located in Ho Chi Minh City. Open-source intelligence (OSINT) analysis revealed multiple malicious associations tied to the IP [1].

Darktrace’s analysis found that the IP 103[.]177.110.202 is used for multiple stages of an attack, including spreading and initial access, delivering payloads, and C2 communication. This is an unusual combination, as many malware families separate their spreading servers from their C2 infrastructure. Typically, malware distribution activity results in a high volume of abuse complaints, which may result in server takedowns or service suspension by internet providers. Separate C2 infrastructure ensures that existing infections remain controllable even if the spreading server is disrupted.

How the malware evades detection and maintains persistence

Analysis of the Linux payload (bot _x64)

The sample begins by setting the environmental variables BUILD_ID and JENKINS_NODE_COOKIE to “dontKillMe”. By default, Jenkins terminates long-running scripts after a defined timeout period; however, setting these variables to “dontKillMe” bypasses this check, allowing the script to continue running uninterrupted.

The script then performs several stealth behaviors to evade detection. First, it deletes the original executable from disk and then renames itself to resemble the legitimate kernel processes “ksoftirqd/0” or “kworker”, which are found on Linux installations by default. It then uses a double fork to daemonize itself, enabling it to run in the background, before redirecting standard input, standard output, and standard error to /dev/null, hiding any logging from the malware. Finally, the script creates a signal handler for signals such as SIGTERM, causing them to be ignored and making it harder to stop the process.

Stealth component of the main function
Figure 3: Stealth component of the main function

How the botnet communicates with command and control (C2)

The sample then connects to the C2 server and sends the detected architecture of the system on which the agent was installed. The malware then enters a loop to handle incoming commands.

The sample features two types of commands, utility commands used to manage the malware, and commands to trigger attacks. Three special commands are defined: “PING” (which replies with PONG as a keep-alive mechanism), “!stop” which causes the malware to exit, and “!update”, which triggers the malware to download a new version from the C2 server and restart itself.

Initial connection to the C2 sever.
Figure 4: Initial connection to the C2 sever.

What DDoS attack techniques this botnet uses

The attack commands consist of the following:

Many of these commands invoke the same function despite appearing to be different attack techniques. For example, specialized attacks such as Cloudflare bypass (cfbypass, uam) use the exact same function as a standard HTTP attack. This may indicate the threat actor is attempting to make the botnet look like it has more capabilities than it actually has, or it could suggest that these commands are placeholders for future attack functionality that has yet to be implemented

All the commands take three arguments: IP, port to attack, and the duration of the attack.

attack_udp and attack_udp_pps

The attack_udp and attack_udp_pps functions both use a basic loop and sendto system call to send UDP packets to the victim’s IP, either targeting a predetermined port or a random port. The attack_udp function sends packets with 1,450 bytes of data, aimed at bandwidth saturation, while the attack_udp_pps function sends smaller 64-byte packets. In both cases, the data body of the packet consists of entirely random data.

Code for the UDP attack method
Figure 5: Code for the UDP attack method

attack_dayz

The attack_dayz function follows a similar structure to the attack_udp function; however, instead of sending random data, it will instead send a TSource Engine Query. This command is specific to Valve Source Engine servers and is designed to return a large volume of data about the targeted server. By repeatedly flooding this request, an attacker can exhaust the resources of a server using a comparatively small amount of data.

The Valve Source Engine server, also called Source Engine Dedicated server, is a server developed by video game company Valve that enables multiplayer gameplay for titles built using the Source game engine, which is also developed by Valve. The Source engine is used in games such as Counterstrike and Team Fortress 2. Curiously, the function attack_dayz, appears to be named after another popular online multiplayer game, DayZ; however, DayZ does not use the Valve Source Engine, making it unclear why this name was chosen.

The code for the “attack_dayz” attack function.
Figure 6: The code for the attack_dayz” attack function.

attack_tcp_push

The attack_tcp_push function establishes a TCP socket with the non-blocking flag set, allowing it to rapidly call functions such as connect() and send() without waiting for their completion. For the duration of the attack, it enters a while loop in which it repeatedly connects to the victim, sends 1,024 bytes of random data, and then closes the connection. This process repeats until the attack duration ends. If the mode flag is set to 1, the function also configures the socket with TCP no-delay enabled, allowing for packets to be sent immediately without buffering, resulting in a higher packet rate and a more effective attack.

The code for the TCP attack function.
Figure 7: The code for the TCP attack function.

attack_http

Similar to attach_tcp_push, attack_http configures a socket with no-delay enabled and non-blocking set. After establishing the connection, it sends 64 HTTP GET requests before closing the socket.

The code for the HTTP attack function.
Figure 8: The code for the HTTP attack function.

attack_special

The attack_special function creates a UDP socket and sets the port and payload based on the value of the mode flag:

  • Mode 0: Port 53 (DNS), sending a 10-byte malformed data packet.
  • Mode 1: Port 27015 (Valve Source Engine), sending the previously observed TSource Engine Query packet.
  • Mode 2: Port 123 (NTP), sending the start of an NTP control request.
The code for the attack_special function.
Figure 9: The code for the attack_special function.

What this botnet reveals about opportunistic attacks on internet-facing systems

Jenkins is one of the less frequently exploited services honeypotted by Darktrace, with only a handful campaigns observed. Nonetheless, the emergence of this new DDoS botnet demonstrates that attackers continue to opportunistically exploit any internet-facing misconfiguration at scale to grow the botnet strength.

While the hosts most commonly affected by these opportunistic attacks are usually “lower-value” systems, this distinction is largely irrelevant for botnets, where numbers alone are more important to overall effectiveness

The presence of game-specific DoS techniques further highlights that the gaming industry continues to be extensively targeted by cyber attackers, with Cloudflare reporting it as the fourth most targeted industry [2]. This botnet has likely already been used against game servers, serving as a reminder for server operators to ensure appropriate mitigations are in place.

Credit to Nathaniel Bill (Malware Research Engineer)
Edited by Ryan Traill (Content Manager)

Indicators of Compromise (IoCs)

103[.]177.110.202 - Attacker and command-and-control IP

F79d05065a2ba7937b8781e69b5859d78d5f65f01fb291ae27d28277a5e37f9b – bot_x64

References

[1] https://www.virustotal.com/gui/url/86db2530298e6335d3ecc66c2818cfbd0a6b11fcdfcb75f575b9fcce1faa00f1/detection

[2] - https://blog.cloudflare.com/ddos-threat-report-2025-q4/

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About the author
Nathaniel Bill
Malware Research Engineer
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