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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
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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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September 23, 2025

It’s Time to Rethink Cloud Investigations

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Cloud Breaches Are Surging

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

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

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

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

4 Reasons Cloud Investigations Are Broken

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

Here’s why:

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

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

What’s Needed: A New Approach to Cloud Investigations

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

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

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

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

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

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

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

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

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Kellie Regan
Director, Product Marketing - Cloud Security

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September 22, 2025

Understanding the Canadian Critical Cyber Systems Protection Act

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Introduction: The Canadian Critical Cyber Systems Protection Act

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

Political context

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

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

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

The case for new cybersecurity legislation in Canada

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

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

What the Canadian Critical Cyber Systems Protection Act aims to achieve

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

Who does the CCSPA apply to

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

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

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

Scope of the CCSPA

The CCSPA introduces two key instruments:

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

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

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

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

New obligations for designated providers

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

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

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

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

What are the penalties for CCSPA non-compliance?

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

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