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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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September 9, 2025

The benefits of bringing together network and email security

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In many organizations, network and email security operate in isolation. Each solution is tasked with defending its respective environment, even though both are facing the same advanced, multi-domain threats.  

This siloed approach overlooks a critical reality: email remains the most common vector for initiating cyber-attacks, while the network is the primary stage on which those attacks progress. Without direct integration between these two domains, organizations risk leaving blind spots that adversaries can exploit.  

A modern security strategy needs to unify email and network defenses, not just in name, but in how they share intelligence, conduct investigations, and coordinate response actions. Let’s take a look at how this joined-up approach delivers measurable technical, operational, and commercial benefits.

Technical advantages

Pre-alert intelligence: Gathering data before the threat strikes

Most security tools start working when something goes wrong – an unusual login, a flagged attachment, a confirmed compromise. But by then, attackers may already be a step ahead.

By unifying network and email security under a single AI platform (like the Darktrace Active AI Security Platform), you can analyze patterns across both environments in real time, even when there are no alerts. This ongoing monitoring builds a behavioral understanding of every user, device, and domain in your ecosystem.

That means when an email arrives from a suspicious domain, the system already knows whether that domain has appeared on your network before – and whether its behavior has been unusual. Likewise, when new network activity involves a domain first spotted in an email, it’s instantly placed in the right context.

This intelligence isn’t built on signatures or after-the-fact compromise indicators – it’s built on live behavioral baselines, giving your defenses the ability to flag threats before damage is done.

Alert-related intelligence: Connecting the dots in real time

Once an alert does fire, speed and context matter. The Darktrace Cyber AI Analyst can automatically investigate across both environments, piecing together network and email evidence into a single, cohesive incident.

Instead of leaving analysts to sift through fragmented logs, the AI links events like a phishing email to suspicious lateral movement on the recipient’s device, keeping the full attack chain intact. Investigations that might take hours – or even days – can be completed in minutes, with far fewer false positives to wade through.

This is more than a time-saver. It ensures defenders maintain visibility after the first sign of compromise, following the attacker as they pivot into network infrastructure, cloud services, or other targets. That cross-environment continuity is impossible to achieve with disconnected point solutions or siloed workflows.

Operational advantages

Streamlining SecOps across teams

In many organizations, email security is managed by IT, while network defense belongs to the SOC. The result? Critical information is scattered between tools and teams, creating blind spots just when you need clarity.

When email and network data flow into a single platform, everyone is working from the same source of truth. SOC analysts gain immediate visibility into email threats without opening another console or sending a request to another department. The IT team benefits from the SOC’s deeper investigative context.

The outcome is more than convenience: it’s faster, more informed decision-making across the board.

Reducing time-to-meaning and enabling faster response

A unified platform removes the need to manually correlate alerts between tools, reducing time-to-meaning for every incident. Built-in AI correlation instantly ties together related events, guiding analysts toward coordinated responses with higher confidence.

Instead of relying on manual SIEM rules or pre-built SOAR playbooks, the platform connects the dots in real time, and can even trigger autonomous response actions across both environments simultaneously. This ensures attacks are stopped before they can escalate, regardless of where they begin.

Commercial advantages

While purchasing “best-of-breed" for all your different tools might sound appealing, it often leads to a patchwork of solutions with overlapping costs and gaps in coverage. However good a “best-in-breed" email security solution might be in the email realm, it won't be truly effective without visibility across domains and an AI analyst piecing intelligence together. That’s why we think “best-in-suite" is the only “best-in-breed" approach that works – choosing a high-quality platform ensures that every new capability strengthens the whole system.  

On top of that, security budgets are under constant pressure. Managing separate vendors for email and network defense means juggling multiple contracts, negotiating different SLAs, and stitching together different support models.

With a single provider for both, procurement and vendor management become far simpler. You deal with one account team, one support channel, and one unified strategy for both environments. If you choose to layer on managed services, you get consistent expertise across your whole security footprint.

Even more importantly, an integrated AI platform sets the stage for growth. Once email and network are under the same roof, adding coverage for other attack surfaces – like cloud or identity – is straightforward. You’re building on the same architecture, not bolting on new point solutions that create more complexity.

Check out the white paper, The Modern Security Stack: Why Your NDR and Email Security Solutions Need to Work Together, to explore these benefits in more depth, with real-world examples and practical steps for unifying your defenses.

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About the author
Mikey Anderson
Product Marketing Manager, Network Detection & Response

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September 9, 2025

Unpacking the Salesloft Incident: Insights from Darktrace Observations

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Introduction

On August 26, 2025, Google Threat intelligence Group released a report detailing a widespread data theft campaign targeting the sales automation platform Salesloft, via compromised OAuth tokens used by the third-party Drift AI chat agent [1][2].  The attack has been attributed to the threat actor UNC6395 by Google Threat Intelligence and Mandiant [1].

The attack is believed to have begun in early August 2025 and continued through until mid-August 2025 [1], with the threat actor exporting significant volumes of data from multiple Salesforce instances [1]. Then sifting through this data for anything that could be used to compromise the victim’s environments such as access keys, tokens or passwords. This had led to Google Threat Intelligence Group assessing that the primary intent of the threat actor is credential harvesting, and later reporting that it was aware of in excess of 700 potentially impacted organizations [3].

Salesloft previously stated that, based on currently available data, customers that do not integrate with Salesforce are unaffected by this campaign [2]. However, on August 28, Google Threat Intelligence Group announced that “Based on new information identified by GTIG, the scope of this compromise is not exclusive to the Salesforce integration with Salesloft Drift and impacts other integrations” [2]. Google Threat Intelligence has since advised that any and all authentication tokens stored in or connected to the Drift platform be treated as potentially compromised [1].

This campaign demonstrates how attackers are increasingly exploiting trusted Software-as-a-Service (SaaS) integrations as a pathway into enterprise environment.

By abusing these integrations, threat actors were able to exfiltrate sensitive business data at scale, bypassing traditional security controls. Rather than relying on malware or obvious intrusion techniques, the adversaries leveraged legitimate credentials and API traffic that resembled legitimate Salesforce activity to achieve their goals. This type of activity is far harder to detect with conventional security tools, since it blends in with the daily noise of business operations.

The incident underscores the escalating significance of autonomous coverage within SaaS and third-party ecosystems. As businesses increasingly depend on interconnected platforms, visibility gaps become evident that cannot be managed by conventional perimeter and endpoint defenses.

By developing a behavioral comprehension of each organization's distinct use of cloud services, anomalies can be detected, such as logins from unexpected locations, unusually high volumes of API requests, or unusual document activity. These indications serve as an early alert system, even when intruders use legitimate tokens or accounts, enabling security teams to step in before extensive data exfiltration takes place

What happened?

The campaign is believed to have started on August 8, 2025, with malicious activity continuing until at least August 18. The threat actor, tracked as UNC6395, gained access via compromised OAuth tokens associated with Salesloft Drift integrations into Salesforce [1]. Once tokens were obtained, the attackers were able to issue large volumes of Salesforce API requests, exfiltrating sensitive customer and business data.

Initial Intrusion

The attackers first established access by abusing OAuth and refresh tokens from the Drift integration. These tokens gave them persistent access into Salesforce environments without requiring further authentication [1]. To expand their foothold, the threat actor also made use of TruffleHog [4], an open-source secrets scanner, to hunt for additional exposed credentials. Logs later revealed anomalous IAM updates, including unusual UpdateAccessKey activity, which suggested attempts to ensure long-term persistence and control within compromised accounts.

Internal Reconnaissance & Data Exfiltration

Once inside, the adversaries began exploring the Salesforce environments. They ran queries designed to pull sensitive data fields, focusing on objects such as Cases, Accounts, Users, and Opportunities [1]. At the same time, the attackers sifted through this information to identify secrets that could enable access to other systems, including AWS keys and Snowflake credentials [4]. This phase demonstrated the opportunistic nature of the campaign, with the actors looking for any data that could be repurposed for further compromise.

Lateral Movement

Salesloft and Mandiant investigations revealed that the threat actor also created at least one new user account in early September. Although follow-up activity linked to this account was limited, the creation itself suggested a persistence mechanism designed to survive remediation efforts. By maintaining a separate identity, the attackers ensured they could regain access even if their stolen OAuth tokens were revoked.

Accomplishing the mission

The data taken from Salesforce environments included valuable business records, which attackers used to harvest credentials and identify high-value targets. According to Mandiant, once the data was exfiltrated, the actors actively sifted through it to locate sensitive information that could be leveraged in future intrusions [1]. In response, Salesforce and Salesloft revoked OAuth tokens associated with Drift integrations on August 20 [1], a containment measure aimed at cutting off the attackers’ primary access channel and preventing further abuse.

How did the attack bypass the rest of the security stack?

The campaign effectively bypassed security measures by using legitimate credentials and OAuth tokens through the Salesloft Drift integration. This rendered traditional security defenses like endpoint protection and firewalls ineffective, as the activity appeared non-malicious [1]. The attackers blended into normal operations by using common user agents and making queries through the Salesforce API, which made their activity resemble legitimate integrations and scripts. This allowed them to operate undetected in the SaaS environment, exploiting the trust in third-party connections and highlighting the limitations of traditional detection controls.

Darktrace Coverage

Anomalous activities have been identified across multiple Darktrace deployments that appear associated with this campaign. This included two cases on customers based within the United States who had a Salesforce integration, where the pattern of activities was notably similar.

On August 17, Darktrace observed an account belonging to one of these customers logging in from the rare endpoint 208.68.36[.]90, while the user was seen active from another location. This IP is a known indicator of compromise (IoC) reported by open-source intelligence (OSINT) for the campaign [2].

Cyber AI Analyst Incident summarizing the suspicious login seen for the account.
Figure 1: Cyber AI Analyst Incident summarizing the suspicious login seen for the account.

The login event was associated with the application Drift, further connecting the events to this campaign.

Advanced Search logs showing the Application used to login.
Figure 2: Advanced Search logs showing the Application used to login.

Following the login, the actor initiated a high volume of Salesforce API requests using methods such as GET, POST, and DELETE. The GET requests targeted endpoints like /services/data/v57.0/query and /services/data/v57.0/sobjects/Case/describe, where the former is used to retrieve records based on a specific criterion, while the latter provides metadata for the Case object, including field names and data types [5,6].

Subsequently, a POST request to /services/data/v57.0/jobs/query was observed, likely to initiate a Bulk API query job for extracting large volumes of data from the Ingest Job endpoint [7,8].

Finally, a DELETE request to remove an ingestion job batch, possibly an attempt to obscure traces of prior data access or manipulation.

A case on another US-based customer took place a day later, on August 18. This again began with an account logging in from the rare IP 208.68.36[.]90 involving the application Drift. This was followed by Salesforce GET requests targeting the same endpoints as seen in the previous case, and then a POST to the Ingest Job endpoint and finally a DELETE request, all occurring within one minute of the initial suspicious login.

The chain of anomalous behaviors, including a suspicious login and delete request, resulted in Darktrace’s Autonomous Response capability suggesting a ‘Disable user’ action. However, the customer’s deployment configuration required manual confirmation for the action to take effect.

An example model alert for the user, triggered due to an anomalous API DELETE request.
Figure 3: An example model alert for the user, triggered due to an anomalous API DELETE request.
Figure 4: Model Alert Event Log showing various model alerts for the account that ultimately led to an Autonomous Response model being triggered.

Conclusion

In conclusion, this incident underscores the escalating risks of SaaS supply chain attacks, where third-party integrations can become avenues for attacks. It demonstrates how adversaries can exploit legitimate OAuth tokens and API traffic to circumvent traditional defenses. This emphasizes the necessity for constant monitoring of SaaS and cloud activity, beyond just endpoints and networks, while also reinforcing the significance of applying least privilege access and routinely reviewing OAuth permissions in cloud environments. Furthermore, it provides a wider perspective into the evolution of the threat landscape, shifting towards credential and token abuse as opposed to malware-driven compromise.

Credit to Emma Foulger (Global Threat Research Operations Lead), Calum Hall (Technical Content Researcher), Signe Zaharka (Principal Cyber Analyst), Min Kim (Senior Cyber Analyst), Nahisha Nobregas (Senior Cyber Analyst), Priya Thapa (Cyber Analyst)

Appendices

Darktrace Model Detections

·      SaaS / Access / Unusual External Source for SaaS Credential Use

·      SaaS / Compromise / Login From Rare Endpoint While User Is Active

·      SaaS / Compliance / Anomalous Salesforce API Event

·      SaaS / Unusual Activity / Multiple Unusual SaaS Activities

·      Antigena / SaaS / Antigena Unusual Activity Block

·      Antigena / SaaS / Antigena Suspicious Source Activity Block

Customers should consider integrating Salesforce with Darktrace where possible. These integrations allow better visibility and correlation to spot unusual behavior and possible threats.

IoC List

(IoC – Type)

·      208.68.36[.]90 – IP Address

References

1.     https://cloud.google.com/blog/topics/threat-intelligence/data-theft-salesforce-instances-via-salesloft-drift

2.     https://trust.salesloft.com/?uid=Drift+Security+Update%3ASalesforce+Integrations+%283%3A30PM+ET%29

3.     https://thehackernews.com/2025/08/salesloft-oauth-breach-via-drift-ai.html

4.     https://unit42.paloaltonetworks.com/threat-brief-compromised-salesforce-instances/

5.     https://developer.salesforce.com/docs/atlas.en-us.api_rest.meta/api_rest/resources_query.htm

6.     https://developer.salesforce.com/docs/atlas.en-us.api_rest.meta/api_rest/resources_sobject_describe.htm

7.     https://developer.salesforce.com/docs/atlas.en-us.api_asynch.meta/api_asynch/get_job_info.htm

8.     https://developer.salesforce.com/docs/atlas.en-us.api_asynch.meta/api_asynch/query_create_job.htm

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About the author
Emma Foulger
Global Threat Research Operations Lead
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