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July 24, 2025

Untangling the web: Darktrace’s investigation of Scattered Spider’s evolving tactics

Learn about a recent Scattered Spider attack observed by Darktrace, comparing tactics with those seen in previous attacks. Widespread use of LOTL techniques alongside continued changes in TTPs such as their recent use of Ransomware-as-a-Service (RaaS) platforms can make it challenging for security teams to harden defenses.
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
Emma Foulger
Global Threat Research Operations Lead
man on computer doing work scattered spider cybersecurityDefault blog image
24
Jul 2025

What is Scattered Spider?

Scattered Spider is a native English-speaking group, also referred to, or closely associated with, aliases such as UNC3944, Octo Tempest and Storm-0875. They are primarily financially motivated with a clear emphasis on leveraging social engineering, SIM swapping attacks, exploiting legitimate tooling as well as using Living-Off-the-Land (LOTL) techniques [1][2].

In recent years, Scattered Spider has been observed employing a shift in tactics, leveraging Ransomware-as-a-Service (RaaS) platforms in their attacks. This adoption reflects a shift toward more scalable attacks with a lower barrier to entry, allowing the group to carry out sophisticated ransomware attacks without the need to develop it themselves.

While RaaS offerings have been available for purchase on the Dark Web for several years, they have continued to grow in popularity, providing threat actors a way to cause significant impact to critical infrastructure and organizations without requiring highly technical capabilities [12].

This blog focuses on the group’s recent changes in tactics, techniques, and procedures (TTPs) reported by open-source intelligence (OSINT) and how TTPs in a recent Scattered Spider attack observed by Darktrace compare.

How has Scattered Spider been reported to operate?

First observed in 2022, Scattered Spider is known to target various industries globally including telecommunications, technology, financial services, and commercial facilities.

Overview of key TTPs

Scattered Spider has been known to utilize the following methods which cover multiple stages of the Cyber Kill Chain including initial access, lateral movement, evasion, persistence, and action on objective:

Social engineering [1]:

Impersonating staff via phone calls, SMS and Telegram messages; obtaining employee credentials (MITRE techniques T1598,T1656), multi-factor authentication (MFA) codes such as one-time passwords, or convincing employees to run commercial remote access tools enabling initial access (MITRE techniques T1204,T1219,T1566)

  • Phishing using specially crafted domains containing the victim name e.g. victimname-sso[.]com
  • MFA fatigue: sending repeated requests for MFA approval with the intention that the victim will eventually accept (MITRE technique T1621)

SIM swapping [1][3]:

  • Includes hijacking phone numbers to intercept 2FA codes
  • This involves the actor migrating the victim's mobile number to a new SIM card without legitimate authorization

Reconnaissance, lateral movement & command-and-control (C2) communication via use of legitimate tools:

  • Examples include Mimikatz, Ngrok, TeamViewer, and Pulseway [1]. A more recently reported example is Teleport [3].

Financial theft through their access to victim networks: Extortion via ransomware, data theft (MITRE technique T1657) [1]

Bring Your Own Vulnerable Driver (BYOVD) techniques [4]:

  • Exploiting vulnerable drivers to evade detection from Endpoint Detection and Response (EDR) security products (MITRE technique T1068) frequently used against Windows devices.

LOTL techniques

LOTL techniques are also closely associated with Scattered Spider actors once they have gained initial access; historically this has allowed them to evade detection until impact starts to be felt. It also means that specific TTPs may vary from case-to-case, making it harder for security teams to prepare and harden defences against the group.

Prominent Scattered Spider attacks over the years

While attribution is sometimes unconfirmed, Scattered Spider have been linked with a number of highly publicized attacks since 2022.

Smishing attacks on Twilio: In August 2022 the group conducted multiple social engineering-based attacks. One example was an SMS phishing (smishing) attack against the cloud communication platform Twilio, which led to the compromise of employee accounts, allowing actors to access internal systems and ultimately target Twilio customers [5][6].

Phishing and social engineering against MailChimp: Another case involved a phishing and social engineering attack against MailChimp. After gaining access to internal systems through compromised employee accounts the group conducted further attacks specifically targeting MailChimp users within cryptocurrency and finance industries [5][7].

Social engineering against Riot Games: In January 2023, the group was linked with an attack on video game developer Riot Games where social engineering was once again used to access internal systems. This time, the attackers exfiltrated game source code before sending a ransom note [8][9].

Attack on Caesars & MGM: In September 2023, Scattered Spider was linked with attacked on Caesars Entertainment and MGM Resorts International, two of the largest casino and gambling companies in the United States. It was reported that the group gathered nearly six terabytes of stolen data from the hotels and casinos, including sensitive information of guests, and made use of the RaaS strain BlackCat [10].

Ransomware against Marks & Spencer: More recently, in April 2025, the group has also been linked to the alleged ransomware incident against the UK-based retailer Marks & Spencer (M&S) making use of the DragonForce RaaS [11].

How a recent attack observed by Darktrace compares

In May 2025, Darktrace observed a Scattered Spider attack affecting one of its customers. While initial access in this attack fell outside of Darktrace’s visibility, information from the affected customer suggests similar social engineering techniques involving abuse of the customer’s helpdesk and voice phishing (vishing) were used for reconnaissance.

Initial access

It is believed the threat actor took advantage of the customer’s third-party Software-as-a-Service (SaaS) applications, such as Salesforce during the attack.

Such applications are a prime target for data exfiltration due to the sensitive data they hold; customer, personnel, and business data can all prove useful in enabling further access into target networks.

Techniques used by Scattered Spider following initial access to a victim network tend to vary more widely and so details are sparser within OSINT. However, Darktrace is able to provide some additional insight into what techniques were used in this specific case, based on observed activity and subsequent investigation by its Threat Research team.

Lateral movement

Following initial access to the customer’s network, the threat actor was able to pivot into the customer’s Virtual Desktop Infrastructure (VDI) environment.

Darktrace observed the threat actor spinning up new virtual machines and activating cloud inventory management tools to enable discovery of targets for lateral movement.

In some cases, these virtual machines were not monitored or managed by the customer’s security tools, allowing the threat actor to make use of additional tooling such as AnyDesk which may otherwise have been blocked.

Tooling in further stages of the attack sometimes overlapped with previous OSINT reporting on Scattered Spider, with anomalous use of Ngrok and Teleport observed by Darktrace, likely representing C2 communication. Additional tooling was also seen being used on the virtual machines, such as Pastebin.

 Cyber AI Analyst’s detection of C2 beaconing to a teleport endpoint with hostname CUSTOMERNAME.teleport[.]sh, likely in an attempt to conceal the traffic.
Figure 1: Cyber AI Analyst’s detection of C2 beaconing to a teleport endpoint with hostname CUSTOMERNAME.teleport[.]sh, likely in an attempt to conceal the traffic.

Leveraging LOTL techniques

Alongside use of third-party tools that may have been unexpected on the network, various LOTL techniques were observed during the incident; this primarily involved the abuse of standard network protocols such as:

  • SAMR requests to alter Active Directory account details
  • Lateral movement over RDP and SSH
  • Data collection over LDAP and SSH

Coordinated exfiltration activity linked through AI-driven analysis

Multiple methods of exfiltration were observed following internal data collection. This included SSH transfers to IPs associated with Vultr, alongside significant uploads to an Amazon S3 bucket.

While connections to this endpoint were not deemed unusual for the network at this stage due to the volume of traffic seen, Darktrace’s Cyber AI Analyst was still able to identify the suspiciousness of this behavior and launched an investigation into the activity.

Cyber AI Analyst successfully correlated seemingly unrelated internal download and external upload activity across multiple devices into a single, broader incident for the customer’s security team to review.

Cyber AI Analyst Incident summary showing a clear outline of the observed activity, including affected devices and the anomalous behaviors detected.
Figure 2: Cyber AI Analyst Incident summary showing a clear outline of the observed activity, including affected devices and the anomalous behaviors detected.
Figure 3: Cyber AI Analyst’s detection of internal data downloads and subsequent external uploads to an Amazon S3 bucket.

Exfiltration and response

Unfortunately, as Darktrace was not configured in Autonomous Response mode at the time, the attack was able to proceed without interruption, ultimately escalating to the point of data exfiltration.

Despite this, Darktrace was still able to recommend several Autonomous Response actions, aimed at containing the attack by blocking the internal data-gathering activity and the subsequent data exfiltration connections.

These actions required manual approval by the customer’s security team and as shown in Figure 3, at least one of the recommended actions was subsequently approved.

Had Darktrace been enabled in Autonomous Response mode, these measures would have been applied immediately, effectively halting the data exfiltration attempts.

Further recommendations for Autonomous Response actions in Darktrace‘s Incident Interface, with surgical response targeting both the internal data collection and subsequent exfiltration.
Figure 4: Further recommendations for Autonomous Response actions in Darktrace‘s Incident Interface, with surgical response targeting both the internal data collection and subsequent exfiltration.

Scattered Spider’s use of RaaS

In this recent Scattered Spider incident observed by Darktrace, exfiltration appears to have been the primary impact. While no signs of ransomware deployment were observed here, it is possible that this was the threat actors’ original intent, consistent with other recent Scattered Spider attacks involving RaaS platforms like DragonForce.

DragonForce emerged towards the end of 2023, operating by offering their platform and capabilities on a wide scale. They also launched a program which offered their affiliates 80% of the eventual ransom, along with tools for further automation and attack management [13].

The rise of RaaS and attacker customization is fragmenting TTPs and indicators, making it harder for security teams to anticipate and defend against each unique intrusion.

While DragonForce appears to be the latest RaaS used by Scattered Spider, it is not the first, showcasing the ongoing evolution of tactics used the group.

In addition, the BlackCat RaaS strain was reportedly used by Scattered Spider for their attacks against Caesars Entertainment and MGM Resorts International [10].

In 2024 the group was also seen making use of additional RaaS strains; RansomHub and Qilin [15].

What security teams and CISOs can do to defend against Scattered Spider

The ongoing changes in tactics used by Scattered Spider, reliance on LOTL techniques, and continued adoption of evolving RaaS providers like DragonForce make it harder for organizations and their security teams to prepare their defenses against such attacks.

CISOs and security teams should implement best practices such as MFA, Single Sign-On (SSO), notifications for suspicious logins, forward logging, ethical phishing tests.

Also, given Scattered Spider’s heavy focus on social engineering, and at times using their native English fluency to their advantage, it is critical to IT and help desk teams are reminded they are possible targets.

Beyond social engineering, the threat actor is also adept at taking advantage of third-party SaaS applications in use by victims to harvest common SaaS data, such as PII and configuration data, that enable the threat actor to take on multiple identities across different domains.

With Darktrace’s Self-Learning AI, anomaly-based detection, and Autonomous Response inhibitors, businesses can halt malicious activities in real-time, whether attackers are using known TTPs or entirely new ones. Offerings such as Darktrace /Attack Surface Management enable security teams to proactively identify signs of malicious activity before it can cause an impact, while more generally Darktrace’s ActiveAI Security Platform can provide a comprehensive view of an organization’s digital estate across multiple domains.

Credit to Justin Torres (Senior Cyber Analyst), Emma Foulger (Global Threat Research Operations Lead), Zaki Al-Dhamari (Cyber Analyst), Nathaniel Jones (VP, Security & AI Strategy, FCISO), and Ryan Traill (Analyst Content Lead)

---------------------

The information provided in this blog post is for general informational purposes only and is provided "as is" without any representations or warranties, express or implied. While Darktrace makes reasonable efforts to ensure the accuracy and timeliness of the content related to cybersecurity threats such as Scattered Spider, we make no warranties or guarantees regarding the completeness, reliability, or suitability of the information for any purpose.

This blog post does not constitute professional cybersecurity advice, and should not be relied upon as such. Readers should seek guidance from qualified cybersecurity professionals or legal counsel before making any decisions or taking any actions based on the content herein.

No warranty of any kind, whether express or implied, including, but not limited to, warranties of performance, merchantability, fitness for a particular purpose, or non-infringement, is given with respect to the contents of this post.

Darktrace expressly disclaims any liability for any loss or damage arising from reliance on the information contained in this blog.

Appendices

References

[1] https://www.cisa.gov/news-events/cybersecurity-advisories/aa23-320a

[2] https://attack.mitre.org/groups/G1015/

[3] https://www.rapid7.com/blog/post/scattered-spider-rapid7-insights-observations-and-recommendations/

[4] https://www.crowdstrike.com/en-us/blog/scattered-spider-attempts-to-avoid-detection-with-bring-your-own-vulnerable-driver-tactic/

[5] https://krebsonsecurity.com/2024/06/alleged-boss-of-scattered-spider-hacking-group-arrested/?web_view=true

[6] https://www.cxtoday.com/crm/uk-teenager-accused-of-hacking-twilio-lastpass-mailchimp-arrested/

[7] https://mailchimp.com/newsroom/august-2022-security-incident/

[8] https://techcrunch.com/2023/02/02/0ktapus-hackers-are-back-and-targeting-tech-and-gaming-companies-says-leaked-report/

[9] https://www.pcmag.com/news/hackers-behind-riot-games-breach-stole-league-of-legends-source-code

[10] https://www.bbrown.com/us/insight/a-look-back-at-the-mgm-and-caesars-incident/

[11] https://cyberresilience.com/threatonomics/scattered-spider-uk-retail-attacks/

[12] https://www.crowdstrike.com/en-us/cybersecurity-101/ransomware/ransomware-as-a-service-raas/

[13] https://www.group-ib.com/blog/dragonforce-ransomware/
[14] https://blackpointcyber.com/wp-content/uploads/2024/11/DragonForce.pdf
[15] https://x.com/MsftSecIntel/status/1812932749314978191?lang=en

Select MITRE tactics associated with Scattered Spider

Tactic – Technique – Technique Name

Reconnaissance - T1598 -   Phishing for Information

Initial Access - T1566 – Phishing

Execution - T1204 - User Execution

Privilege Escalation - T1068 - Exploitation for Privilege Escalation

Defense Evasion - T1656 - Impersonation

Credential Access - T1621 - Multi-Factor Authentication Request Generation

Lateral Movement - T1021 - Remote Services

Command and Control - T1102 - Web Service

Command and Control - T1219 - Remote Access Tools

Command and Control - T1572 - Protocol Tunneling

Exfiltration - T1567 - Exfiltration Over Web Service

Impact - T1657 - Financial Theft

Select MITRE tactics associated with DragonForce

Tactic – Technique – Technique Name

Initial Access, Defense Evasion, Persistence, Privilege Escalation - T1078 - Valid Accounts

Initial Access, Persistence - T1133 - External Remote Services

Initial Access - T1190 - Exploit Public-Facing Application

Initial Access - T1566 – Phishing

Execution - T1047 - Windows Management Instrumentation

Privilege Escalation - T1068 - Exploitation for Privilege Escalation

Lateral Movement - T1021 - Remote Services

Impact - T1486 - Data Encrypted for Impact

Impact - T1657 - Financial Theft

Select Darktrace models

Compliance / Internet Facing RDP Server

Compliance / Incoming Remote Access Tool

Compliance / Remote Management Tool on Server

Anomalous File / Internet Facing System File Download

Anomalous Server Activity/ New User Agent from Internet Facing System

Anomalous Connection / Callback on Web Facing Device

Device / Internet Facing System with High Priority Alert

Anomalous Connection / Unusual Admin RDP

Anomalous Connection / High Priority DRSGetNCChanges

Anomalous Connection / Unusual Internal SSH

Anomalous Connection / Active Remote Desktop Tunnel

Compliance / Pastebin

Anomalous Connection / Possible Tunnelling to Rare Endpoint

Compromise / Beaconing Activity to External Rare

Device / Long Agent Connection to New Endpoint

Compromise / SSH to Rare External AWS

Compliance / SSH to Rare External Destination

Anomalous Server Activity / Outgoing from Server

Anomalous Connection / Large Volume of LDAP Download

Unusual Activity / Internal Data Transfer on New Device

Anomalous Connection / Download and Upload

Unusual Activity / Enhanced Unusual External Data Transfer

Compromise / Ransomware/Suspicious SMB Activity

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
Emma Foulger
Global Threat Research Operations Lead

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July 8, 2026

Securing AI: Analysis of the Complete Security Stack with Governance and Controls

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Why traditional cybersecurity approaches are not enough for AI

AI adoption outpaces most security programs’ ability to adapt.  That gap is now one of the most consequential sources of cyber risk facing enterprises. As organizations embed generative and agentic AI into development workflows, business operations, and security tooling itself, the question is no longer whether AI will introduce risk. The question is whether organizations understand where that risk actually lives and how to manage it operationally.  

Two recent pieces of guidance underscore this shift:

  1. The upcoming Cybersecurity Framework Profile for AI from NIST
  1. The Five Eyes government guidance on the careful adoption of agentic AI services

Taken together, they point to a critical conclusion. AI security cannot be reduced to model hardening or prompt filtering. It requires a defense in depth strategy that treats AI as both a new attack surface and a force multiplier for defense, while accounting for how AI fundamentally changes scale, speed, and autonomy.  

Recent threat research suggests that today's cyber risk is driven less by initial compromise and more by an adversary's ability to blend into normal operations over time. AI systems create the same exposure in a new form: more autonomy, more scale, and more opportunities for risky behavior to blend into normal operations.

How NIST defines the three core pillars of AI security

The NIST profile organizes AI risk across three inseparable focus areas that span all cybersecurity functions, Secure, Defend and Thwart. These areas are not sequential. They exist simultaneously and must be addressed together.

Secure

This treats AI as an attack surface. It includes models, prompts, agents, pipelines, training and inference data, retrieval augmented generation corpora, and the AI supply chain itself. AI systems are opaque, probabilistic, and non-deterministic by design. Some vulnerabilities are inherent in how models are trained or how data is sourced. Traditional patching does not fully mitigate these risks. This is also where many enterprises are weakest today and, critically, where many security programs stop.  

Defend

This is AI as a defensive force multiplier. AI can improve detection speed, scale, correlation, and response, but only if the right models are used and operationalized correctly. Machine-speed behavior-based detection, response and containment becomes critical in defending non-deterministic systems. Accuracy, explainability, governance, testing, validation, and integration into SOC workflows matter as much as capability. Without those controls, hallucination risk, over automation, and misplaced trust become security risks themselves.  

Thwart

This treats AI as an adversarial accelerant. Threat actors are already using AI to generate targeted social engineering attacks, deepfakes, malware, and autonomous attack agents. Asymmetric warfare is highlighting faster vulnerability discovery and exploitation with a lag on patch development, testing and deployment.  

How this looks in practice

Darktrace researchers observed scaled, automated exploitation of the React2Shell vulnerability within days of disclosure. A vulnerable cloud asset was exploited in under 120 seconds of being deployed. Darktrace research team observed an AI/LLM-generated malware sample used in exploitation activity tied to React2Shell. The significance isn't novelty. It is that AI lowers the barrier to producing usable offensive tooling and compresses the time between experimentation and deployment.  

Tactics are getting more and more creative in order to string together steps of an attack kill chain. This creates a dependency on behavior-based detection, autonomous investigation, autonomous containment, training, resilience investment, and recovery planning across the entire enterprise.

Why agentic AI fundamentally changes enterprise cyber risk

The Five Eyes guidance on agentic AI highlights material changes to the cyber risk profile of an organization. Unlike generative AI systems that produce content for human consumption, agentic AI systems reason, plan, and act autonomously across tools, data, and environments. That autonomy, combined with access to real systems, amplifies the impact of traditional cyber failures and introduces new system level risks that are difficult to predict, observe, and contain.  

Risk in agentic systems does not live in the model alone. It emerges from interactions between models, prompts, memory, tools, APIs, identities, privileges, inter-agent trust relationships, and human assumptions baked into design. Vulnerabilities are often introduced through data, connectors, natural language interfaces, protocols, and drift by design.

In supply-chain incidents, attackers did not need sophisticated exploits to scale impact. They abused trusted systems built for automation and implicit access. Agentic AI inherits that model. Once a system can act across tools, data, and workflows, compromise propagates through trust relationships that were never designed for machine autonomy.

The major agentic AI risk classes include the following:  

  • The identity control for non-human identities or autonomous agents makes it difficult to mitigate over-permissioning, limiting access, scope, and duration, as well as access hygiene
  • Agents are frequently over permissioned
  • Compromised tools inherit agent authority
  • Static secrets enable impersonation
  • Implicit trust between agents enables lateral movement

Design and configuration risks compound this, including privileges evaluated once at startup, poor segmentation, unvetted third party tools, reused authorization decisions outside their original context, and guardrail limitations.  

Behavioral risk  

Agents can optimize for goals in unsafe ways, misinterpret ambiguous intent, chain actions into unintended sequences, change behavior during evaluation, and exhibit deceptive or sycophantic responses.  

Structural risk  

Structural risk follows from agentic systems that are tightly coupled, multicomponent ecosystems. Failures can propagate across agents. Hallucinations cascade downstream. Resource exhaustion becomes systemic. Tool misuse enables indirect prompt injection and command execution. Rogue agents can poison peer agents through trust relationships.  

Accountability

Accountability becomes unclear as autonomy increases. Autonomous agents assume human identity permissions, and humans should have clear ownership of these agents, but they don’t, and this model is flawed. Decision paths are opaque and non-deterministic. Logs are fragmented and difficult to interpret. Reproducing an incident will be impossible without explicit design for observability and forensics. An agent compromise is functionally an insider threat, often with better access and fewer behavioral constraints than a human.  

What does defense in depth look like for AI?

Agentic AI runs on software, networks, identities, and data. It must be governed using the same foundational principles that have proven resilient under uncertainty, including secure by design, defense in depth, zero trust, least privilege, continuous monitoring, behavior-based advanced threat detection and containment, and incident response and recovery.

Core components to a Defense in depth Strategy for Securing the use of AI:

  • Strong, precise identity control plane to include an identity per agent (cryptographic, non‑shared)
    • Privilege monitoring and just‑in‑time access
  • Data Governance
  • Secure‑by‑default configurations
    • Security Posture Management  
    • Zero Trust principles  
  • Strong guardrails, deny‑by‑default policies, and isolation
  • Explicit instruction hierarchies and controlled context
  • Behavioral-based detection across entire enterprise to include inputs, tools, and outputs as well as AI used on the endpoint, across the network, cloud, SaaS, email, and OT
    • Runtime anomaly detection and goal‑drift detection
    • Autonomous containment to mitigate risk and minimize damage
  • Hard boundaries on autonomy and delegation
  • Testing, Evaluation, Validation and Verification  
    • Determine when autonomous action and when human in the loop
    • Adversarial training and agent‑specific testing
    • Simulation, red teaming, and chaos testing
  • Kill‑switches, rollback, and containment mechanisms
    • Forensics data captures, interpretability, autonomous containment, and remediation/recovery plans  

Until standards, tooling, and assurance methods mature, organizations should assume agentic AI systems will behave unexpectedly and design deployments around resilience, behavior-based detection, reversibility, and containment, not efficiency.

How security leaders should prepare for enterprise AI adoption

AI security is not model security alone. Data, pipelines, identities, and agents are first class assets. Many AI attacks succeed through standard cyber failures amplified by AI. Identity, data, and supply chain risk dominate. Behavior-based detection and response are critical, not optional. Logging, provenance, versioning, and forensics data capture of detections are mandatory because you cannot investigate or recover from AI incidents without them.  

Risk will often be visible in behavior before it is clearly defined in policy or guidance. The same pattern has been seen in pre-CVE disclosure detection, where abnormal activity appears before the industry has named or described the vulnerability. AI systems introduce that uncertainty by design.

Security leaders should prioritize controls before AI is fully deployed, avoid generic AI security checklists, integrate AI risk into existing cyber programs, and mitigate the risk of non-deterministic technology with continuous oversight, monitoring, behavior analytics, anomaly detection, autonomous investigation, and autonomous containment.

Visibility has a different connotation with AI. Previously, audit logging worked for software/people, but with Generative AI-based systems, interpretability and explainability is difficult to understand, you cannot "undo" what has been done, or see the logic or control a chain of events. This is why behavioral-based detections and containment becomes critical.  

What capabilities should every AI security program include?

If an organization asked “what must be in place before scaling AI?”:

  1. AI Risk board and approval workflow
  1. IAM + PAM for all AI services and agents
  1. AI asset inventory
  1. Prompt/output DLP with sanctioned AI access – This is not just pre- and post- filters, but behavior-based detections of semantic interface as well as behavior-based analysis of output with associated risk context.  
  1. Shadow AI identification
  1. Secure MLOps – This is an entire paper itself
  1. Runtime guardrails and tool restrictions
    • Including AI Gateway/SASE/Zero trust/
  1. Runtime security with behavior-based detections
    • Complete visibility, monitoring, behavior analytics, anomaly detection, risk/intent/context evaluation of anomalies, autonomous investigation and autonomous containment of all AI assets across endpoint, network, SaaS, SASE, cloud, OT, email, and messaging platforms
  1. Secure data pipelines and data governance
  1. SOC workflow changes from malicious classification workflows to behavior-based detection workflows
  1. Remediation plans for AI-related incidents  

Layered Governance and Security Stack for Securing AI  

The following outline considers governance and security tools that should be considered, well-integrated, deployed, tested, operationalized and embedded within security workflows. These tools and controls map to NIST’s CMF for AI.  

These considerations do not need to be implemented in order. Runtime Detect and Respond will help mitigate risk while Governance, Visibility, and Identity mature.

Category Tooling Controls
Governance & Visibility
  • AI asset inventory / AI CMDB
  • Shadow AI discovery
  • SaaS discovery
  • AI usage on non-endpoint managed systems via network or cloud telemetry
  • MCP server/client usage via protocols
  • Browser telemetry
  • Gateway or SASE telemetry
  • Establish a risk board to set up controls
  • Mandatory registration of AI systems
  • Owner, data classification, intended use, and risk tier
  • Supplier disclosure requirements
  • Risk mitigation plan for AI adoption, innovation, or development
Identity, Access & Agent Control

Non-human autonomous agents should not have the full permissions associated with a human user.

  • IAM with workload identities
  • PAM for AI service accounts
  • Secrets management with short-lived tokens
  • Zero Trust principles
  • Identity, permission, and token hygiene
  • Unique identities per model, agent, and pipeline
  • Least privilege for tools, data, and APIs
  • Explicit approval for autonomous actions
Data Security & Privacy
  • Data classification and labeling
  • Enterprise DLP across endpoint, email, network, cloud, and SaaS
  • Forensics data capture after risky detections
  • Prompt-level DLP through behavior-based semantic analysis with risk and intent context
  • Input/interface analysis for risky data requests
  • Output analysis for sensitive data
  • Data integrity evaluation
  • Retention and redaction policies for prompts and responses
Secure MLOps / LLMOps
  • Secure CI/CD with AI-specific gates
  • Model registries with approval workflows
  • Dependency, container, and artifact scanning
  • SBOM/AIBOM generation
  • IaC security scanning
  • Security posture management
  • Misconfiguration identification
  • Hardening recommendations
  • Signed models and prompts
  • Versioned datasets, configurations, logging, and controls
  • Securing data pipelines
  • Controlled promotion
  • Quality assurance
  • Adversarial testing
Runtime Security

Securing runtime goes beyond guardrails and model firewalls to include behavior-based detections, response, and containment.

  • Detection, monitoring, and SOC integration
  • Centralized visibility into prompts, outputs, and tool calls
  • AI-specific detections
  • Behavior-based detection for AI usage patterns
  • Model drift and behavior monitoring
  • Autonomous containment
  • Behavior-based detection of model inputs and outputs
  • Prompt injection detection
  • Model manipulation, including jailbreaking, poisoning, and related attacks
  • Sensitive data access attempts
  • Behavior-based detection across low-code agents, high-code agents, MCP clients and servers, endpoint, network, cloud, email, SaaS, SASE, IoT, and OT
  • Policy enforcement between users, models, tools, agents, SaaS models/tools, and MCP servers/clients
  • Risk, intent, and context evaluation for detections and response actions
Response & Recovery
  • Autonomous containment
  • AI-assisted playbooks
  • Forensics data capture for AI-related events
  • Model rollback mechanisms
  • Backup and restore for models and datasets
  • Kill switch for agents
  • Autonomous response to agents performing risky behaviors
  • Model and dataset rollback
  • Remediation plans
  • Tabletop exercises
  • Supplier coordination plans
  • Post-incident AI performance validation

AI security requires continuous visibility and behavioral detection

AI changes how fast systems move, how decisions are made, and how risk propagates. It does not change the fundamentals of security. Organizations that succeed will be the ones that apply those fundamentals rigorously, assume failure, and build systems that can detect, contain, and recover when AI behaves in ways they did not anticipate. Security is not what AI is allowed to do. It is whether the organization can understand, trust, and control what AI actually does in practice.  

Take this guidance to understand different initiatives that organizations should be considering. Securing AI is the most critical component to AI safety. As organizations invest more in AI adoption, they should be investing in security in order to mitigate the risk of AI adoption. Organizations should be evaluating their governance and security stack to include well-integrated tools that are deployed, tested, operationalized and embedded within security workflows. While organizations mature in governance, visibility and identity access management, they should be investing in behavior-based detection and autonomous containment to mitigate AI risk.  

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July 6, 2026

NIST Just Proved It: AI Security Can’t Be Solved With Rules

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Static AI guardrails are inherently limited

As organizations adopt generative AI, many still assume that the right set of guardrails will be enough. The problem is you can’t anticipate every way these systems might be misused, abused or attacked. What NIST has done is put a mathematical foundation under that intuition.

In recent research building on Gödel’s incompleteness theorems, which showed that any system built on a fixed set of rules will always have gaps, NIST demonstrates that there is no finite set of guardrails that can be universally robust against adversarial prompts. In plain terms, if your defense is based on a fixed set of rules, there will always be inputs that bypass them. Not because the rules are badly written, but because the problem space is bigger than static rules can ever cover.

This is not new in cybersecurity - detection rules have always had to live with this trade-off. What is different with GenAI is the scale and shape of that problem. These systems are built on human language, and human language is not bounded. It is fluid, contextual and deliberately ambiguous. The number of ways intent can be hidden is effectively limitless. You are not defending against a defined protocol or a fixed exploit chain. You are defending against the entire expressive capacity of people.

So attempting to create a complete set of rules is the wrong starting point. It assumes the problem can be deterministically described. NIST’s work shows that it cannot. Organizations still need a way to manage AI risk, but the traditional approach of defining allowed and disallowed patterns is always going to lag behind what is actually happening. The same input can be benign in one context and risky in another, and static rules struggle to capture that distinction.

The question then is what fills that gap?

AI security must shift from rules to behavior

What's required is a shift in what you are trying to understand. Rules try to describe what should and shouldn't happen. Behavior shows you what is happening. Or to put it another way, if inputs are unbounded and adversaries adapt, the only stable signal is behavior.

In a GenAI context, that means analyzing how an AI model is being used, how prompts evolve over time, how outputs are shaped, and where AI agent interactions start to drift from what is expected. It means moving from static definitions of bad to a more dynamic understanding of intent.

Instead of trying to predict every bad prompt, you focus on identifying when behavior starts to move outside expected norms. Instead of asking whether a single input matches a rule, you ask whether the overall pattern of activity makes sense for the system and how it’s being used.

Guardrails remain important but they are only one layer

This does not eliminate the need for guardrails. They still play a role. But they will never address the entire problem space and are simply one part of your defense in depth approach.

NIST’s proof is useful because it makes this explicit. It removes the assumption that with enough effort, a complete rule set is achievable. It isn’t.

Once you accept that, the shift becomes unavoidable. This is no longer a problem of writing better rules, but of understanding behavior in a space where the possible inputs are effectively unbounded.

For security leaders, that changes the nature of the problem. It is less about defining what should be allowed, and more about recognizing when something is no longer consistent with expected behavior.

That does not remove the need for guardrails, but it does change their role. They set boundaries, but they do not define understanding. The gap between the two is where risk now sits.

In the end, this is what “can’t be solved with rules” really means. Rules will always leave gaps, and those gaps are not theoretical. They show up in how systems actually behave Not what we expect them to do, or what we intended them to do, but what they are doing in practice. That is where the signal is, and increasingly, that is where the security problem sits.

References:

https://www.nist.gov/news-events/news/2026/06/nist-mathematical-proof-supports-transition-continuous-monitor-and-update

https://ieeexplore.ieee.org/document/11475847

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About the author
Andrew Hollister
Principal Solutions Engineer, Cyber Technician
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