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October 30, 2024

Post-Exploitation Activities on Fortinet Devices: A Network-Based Analysis

This blog explores recent findings from Darktrace's Threat Research team on active exploitation campaigns targeting Fortinet appliances. This analysis focuses on the September 2024 exploitation of FortiManager via CVE-2024-47575, alongside related malicious activity observed in June 2024.
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
Adam Potter
Senior Cyber Analyst
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30
Oct 2024

Introduction: Uncovering active exploitation of Fortinet vulnerabilities

As part of the Darktrace Threat Research team's routine analysis of October's Patch Tuesday vulnerabilities, the team began searching for signs of active exploitation of a critical vulnerability (CVE-2024-23113) affecting the FortiGate to FortiManager (FGFM) protocol.[1]

Although the investigation was prompted by an update regarding CVE 2024-23113, results of the inquiry yielded evidence of widespread exploitation of Fortinet devices in both June and September 2024 potentially via multiple vulnerabilities including CVE 2024-47575. Analysts identified two clusters of activity involving overlapping indicators of compromise (IoCs), likely constituting unique campaigns targeting Fortinet appliances.

This blog will first highlight the finding and analysis of the network-based indicators of FortiManager post-exploitation activity in September, likely involving CVE 2024-47575. The article will then briefly detail a similar pattern of malicious activity observed in June 2024 that involved similar IoCs that potentially comprises a distinct campaign targeting Fortinet perimeter devices.

Fortinet CVE Disclosures

FortiManager devices allow network administrators to manage Fortinet devices on organizations’ networks.[2] One such subset of devices managed through this method are Fortinet firewalls known as FortiGate. These manager and firewall devices communicate with each other via a custom protocol known as FortiGate to FortiManager (FGFM), whereby devices can perform reachability tests and configuration-related actions and reporting.[3] By default, FortiManager devices operate this protocol via port 541.[4]

Fortinet Product Security Incident Response Team released multiple announcements revealing vulnerabilities within the daemon responsible for implementing operability of the FGFM service. Specifically, CVE 2024-23113 enables attackers to potentially perform arbitrary remote command execution through the use of a specially crafted format string to a FortiGate device running the “fgfm daemon”.[5][6]  Similarly, the exploitation of CVE 2024-47575  could also allow remote command execution due to a missing authentication mechanism when targeting specifically FortiManager devices.[7][8]  Given how prolific both FortiGate and FortiManager devices are within the global IT security ecosystem, Darktrace analysts hypothesized that there may have been specific targeting of such devices within the customer base using these vulnerabilities throughout mid to late 2024.

Campaign Analysis

In light of these vulnerability disclosures, Darktrace’s Threat Research team began searching for signs of active exploitation by investigating file download, lateral movement or tooling activity from devices that had previously received suspicious connections on port 541. The team first noticed increases in suspicious activity involving Fortinet devices particularly in mid-September 2024. Further analysis revealed a similar series of activities involving some overlapping devices identified in June 2024. Analysis of these activity clusters revealed a pattern of malicious activity against likely FortiManager devices, including initial exploitation, payload retrieval, and exfiltration of probable configuration data.

Below is an overview of malicious activity we have observed by sector and region:

Sector and region affected by malicious activity on fortigate devices
The sectors of affected customers listed above are categorized according to the United Kingdom’s Standard Industrial Classification (SIC).

Initial Exploitation of FortiManager Devices

Across many of the observed cases in September, activity began with the initial exploitation of FortiManager devices via incoming connectivity over TLS/SSL. Such activity was detected due to the rarity of the receiving devices accepting connections from external sources, particularly over destination port 541. Within nearly all investigated incidents, connectivity began with the source IP, 45.32.41[.]202, establishing an SSL session with likely FortiManager devices.  Device types were determined through a combination of the devices’ hostnames and the noted TLS certificate issuer for such encrypted connections.

Due to the encrypted nature of the connection, it was not possible to ascertain the exploit used in the analyzed cases. However, given the similarity of activities targeting FortiManager devices and research conducted by outside firms, attackers likely utilized CVE 2024-47575.[9] For example, the source IP initiating the SSL sessions also has been referenced by Mandiant as engaging in CVE 2024-47575 exploitation. In addition to a consistent source IP for the connections, a similar JA3 hash was noted across multiple examined accounts, suggesting a similarity in source process for the activity.

In most cases observed by Darktrace, the incoming connectivity was followed by an outgoing connection on port 443 to the IP 45.32.41[.]202. Uncommon reception of encrypted connections over port 541, followed by the initiation of outgoing SSL connections to the same endpoint would suggest probable successful exploitation of FortiManager CVEs during this time.

Model alert logs highlighting the incoming connectivity over port 541 to the FortiManager devices followed by outgoing connection to the external IP.
Figure 1: Model alert logs highlighting the incoming connectivity over port 541 to the FortiManager devices followed by outgoing connection to the external IP.

Payload Retrieval

Investigated devices commonly retrieved some form of additional content after incoming connectivity over port 541. Darktrace’s Threat Research team noted how affected devices would make HTTP GET requests to the initial exploitation IP for the URI: /dom.js. This URI, suggestive of JavaScript content retrieval, was then validated by the HTTP response content type. Although Darktrace could see the HTTP content of the connections, usage of destination port 443 featured prominently during these HTTP requests, suggesting an attempt at encryption of the session payload details.

Figure 2: Advanced Search HTTP log to the exploitation IP noting the retrieval of JavaScript content using the curl user agent.

Cyber AI Analyst investigation into the initial exploitation activity. This incident emphasizes the rare external connectivity over port 443 requesting JavaScript content following the incoming connections over port 541.
Figure 3: Cyber AI Analyst investigation into the initial exploitation activity. This incident emphasizes the rare external connectivity over port 443 requesting JavaScript content following the incoming connections over port 541.

The operators of the campaign also appear to have used a consistent user agent for payload retrieval: curl 8.4.0. Usage of an earlier version of the curl (version 7 .86.0) was only observed in one instance. The incorporation of curl utility to establish HTTP connections therefore suggests interaction with command-line utilities on the inspected Fortinet hosts. Command-line interaction also adds validity to the usage of exploits such as CVE 2024-47575 which enable unauthenticated remote command execution. Moreover, given the egress of data seen by the devices receiving this JavaScript content, Darktrace analysts concluded that this payload likely resulted in the configuration aggregation activity noted by external researchers.

Data Exfiltration

Nearly all devices investigated during the September time period performed some form of data exfiltration using the HTTP protocol. Most frequently, devices would initiate these HTTP requests using the same curl user agent already observed during web callback activity.  Again, usage of this tool heavily suggests interaction with the command-line interface and therefore command execution.

The affected device typically made an HTTP POST request to one or both of the following two rare external IPs: 104.238.141[.]143 and 158.247.199[.]37. One of the noted IPs, 104.238.141[.]143, features prominently within external research conducted by Mandiant during this time. These HTTP POST requests nearly always sent data to the /file endpoint on the destination IPs. Analyzed connections frequently noted an HTTP mime type suggestive of compressed archive content. Some investigations also revealed specific filenames for the data sent externally: “.tm”. HTTP POST requests occurred without a specified hostname. This would suggest the IP address may have already been cached locally on the device from a running process or the IP address was hardcoded into the details of unwarranted code running on the system. Moreover, many such POSTs occurred without a GET request, which can indicate exfiltration activity.

Model alert logs noting both the connection to the IP 158.247.199[.]37 over port 443 without a hostname, and the unusual activity metric describing how the request was made without a prior HTTP GET request. Such activity can indicate malicious data exfiltration.
Figure 4: Model alert logs noting both the connection to the IP 158.247.199[.]37 over port 443 without a hostname, and the unusual activity metric describing how the request was made without a prior HTTP GET request. Such activity can indicate malicious data exfiltration.

Interestingly, in many investigations, analysts noticed a lag period between the initial access and exploitation, and the exfiltration of data via HTTP. Such a pause, sometimes over several hours to over a day, could reflect the time needed to aggregate data locally on the host or as a strategic pause in activity to avoid detection. While not present within every compromise activity logs inspected, the delay could represent slight adjustments in behavior during the campaign by the threat actor.

Figure 5: Advanced search logs showing both the payload retrieval and exfiltration activity, emphasizing the gap in time between payload retrieval and exfiltration via HTTP POST request.

HTTP and file identification details identified during this time also directly correspond to research conducted by Mandiant. Not only do we see overlap in IPs identified as receiving the posted data (104.238.141[.]143) we also directly observed an overlap in filenames for the locally aggregated configuration data. Moreover, the gzip mime type identified in multiple customer investigations also corresponds directly to exfiltration activity noted by Mandiant researchers.

Advanced search logs noting the filename and URL of the posted data to one of the exfiltration IPs. The .tm filename corresponds to the locally stored file on affected FortiManager devices analyzed by external researchers.
Figure 6: Advanced search logs noting the filename and URL of the posted data to one of the exfiltration IPs. The .tm filename corresponds to the locally stored file on affected FortiManager devices analyzed by external researchers.

Activity detected in June 2024

Common indicators

Analysts identified a similar pattern of activity between June 23 and June 25. Activity in this period involved incoming connections from the aforementioned IP 45.32.41[.]202 on either port 541 or port 443 followed by an outgoing connection to the source. This behavior was then followed by HTTP POSTs to the previously mentioned IP address 158.247.199[.]37 in addition to the novel IP: 195.85.114[.]78  using same URI ‘/file’ noted above. Given the commonalties in indicators, time period, and observed behaviors, this grouping of exploitation attempts appears to align closely with the campaign described by Mandiant and may represent exploitation of CVE 2024-47575 in June 2024. The customers targeted in June fall into the same regions and sectors as seen those in the September campaign.

Deviations in behavior

Notably, Darktrace detected a different set of actions during the same June timeframe despite featuring the same infrastructure. This activity involved an initial incoming connection from 158.247.199[.]37 to an internal device on either port 541 or port 443. This was then followed by an outgoing HTTP connection to 158.247.199[.]37 on port 443 with a URI containing varying external IPs. Upon further review, analysts noticed the IPs listed may be the public IPs of the targeted victim, suggesting a potential form device registration by the threat actor or exploit validation. While the time period and infrastructure closely align with the previous campaign described, the difference in activity may suggest another threat actor sharing infrastructure or the same threat actor carrying out a different campaign at the same time. Although the IP 45.32.41[.]202 was contacted, paralleling activity seen in September, analysts did notice a different payload received from the external host, a shell script with the filename ver.sh.

Figure 7: AI Analyst timeline noting the suspicious HTTP behavior from a FortiManager device involving the IP 158.247.199[.] 37.

Darktrace's depth of detection and investigation

Darktrace detected spikes in anomalous behavior from Fortinet devices within the customer base between September 22 and 23, 2024. Following an in-depth investigation into affected accounts and hosts, Darktrace identified a clear pattern where one, or multiple, threat actors leveraged CVEs affecting likely FortiManager devices to execute commands on the host, retrieve malicious content, and exfiltrate sensitive data. During this investigation, analysts then identified possibly related activity in June 2024 highlighted above.

The gathering and exfiltration of configuration data from network security management or other perimeter hosts is a technique that can enable future access by threat actors. This parallels activity previously discussed by Darktrace focused on externally facing devices, such as Palo Alto Networks firewall devices.  Malicious entities could utilize stolen configuration data and potentially stored passwords/hashes to gain initial access in the future, irrespective of the state of device patching. This data can also be potentially sold by initial access brokers on illicit sites. Moreover, groups can leverage this information to establish persistence mechanisms within devices and host networks to enable more impactful compromise activity.

Uncover threat pattens before they strike your network

Network and endpoint management services are essential tools for network administrators and will remain a critical part of IT infrastructure. However, these devices are often configured as internet-facing systems, which can unintentionally expose organizations networks' to attacks. Internet exposure provides malicious groups with novel entry routes into target environments. Although threat actors can swap vulnerabilities to access target networks, the exploitation process leaves behind unusual traffic patterns, making their presence detectable with the right network detection tools.

By detecting the unusual patterns of network traffic which inevitably ensue from exploitation of novel vulnerabilities, Darktrace’s anomaly-based detection and response approach can continue to identify and inhibit such intrusion activities irrespective of exploit used. Eulogizing the principle of least privilege, configuration and asset management, and maintaining the CIA Triad across security operations will continue to help security teams boost their defense posture.

See how anomaly-based detection can enhance your security operations—schedule a personalized demo today.

Get a demo button for Darktrace

Credit to Adam Potter (Senior Cyber Analyst), Emma Foulger (Principal Cyber Analyst), Nahisha Nobregas (Senior Cyber Analyst), Hyeongyung Yeom (Principal Cyber Analyst & Analyst Team Lead, East Asia), Sam Lister (Senior Cyber Analyst)

Appendix

Model Alerts

  • Anomalous Connection / Posting HTTP to IP without Hostname
  • Anomalous Connection / Callback on Web Facing Device
  • Anomalous Server Activity / New Internet Facing Server
  • Anomalous Server Activity / Outgoing from Server

Cyber AI Analyst Incidents

  • Possible HTTP Command and Control
  • Possible HTTP Command and Control to Multiple Endpoints

IoCs

Indicator – Type - Description

104.238.141[.]143 -  IP Address  - C2 infrastructure

158.247.199[.]37 - IP Address - C2 infrastructure

45.32.41[.]202 - IP Address - C2 infrastructure

104.238.141[.]143/file – URL - C2 infrastructure

158.247.199[.]37/file  - URL - C2 infrastructure

45.32.41[.]202/dom.js – URL - C2 infrastructure

.tm – Filename - Gzip file

MITRE Attack Framework

  • Initial Access
    T1190 Exploiting Public-Facing Application
  • Execution:
    T1059 Command and Scripting Interpreter  (Sub-Techniques: T1059.004 Unix Shell, T1059.008 Network Device CLI)
  • Discovery:
    T1083 File and System Discovery
    T1057 Process Discovery
  • Collection:
    T1005 Data From Local System
  • Command and Control:
    T1071 Application Layer Protocols (Sub-Technique:
    T1071.001 Web Protocols)
    T1573  Encrypted Channel
    T1573.001  Symmetric Cryptography
    T1571 Non-Standard Port
    T1105 Ingress Tool Transfer
    T1572 Protocol Tunnelling 
  • Exfiltration:
    T1048.003 Exfiltration Over Unencrypted Non-C2 Protocol

References

{1} https://cloud.google.com/blog/topics/threat-intelligence/fortimanager-zero-day-exploitation-cve-2024-47575/

{2} https://docs.fortinet.com/document/fortimanager/6.4.0/ports-and-protocols/606094/fortigate-fortimanager-protocol#:~:text=The%20FortiGate%2DFortiManager%20(FGFM),by%20using%20the%20FGFM%20protocol.

{3)https://docs.fortinet.com/document/fortigate/6.4.0/ports-and-protocols/373486/fgfm-fortigate-to-fortimanager-protocol
{4} https://www.fortiguard.com/psirt/FG-IR-24-029
{5} https://www.fortiguard.com/psirt/FG-IR-24-423
{6}https://www.fortinet.com/content/dam/fortinet/assets/data-sheets/fortimanager.pdf

{7} https://doublepulsar.com/burning-zero-days-fortijump-fortimanager-vulnerability-used-by-nation-state-in-espionage-via-msps-c79abec59773

{8} https://darktrace.com/blog/post-exploitation-activities-on-pan-os-devices-a-network-based-analysis

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
Adam Potter
Senior Cyber Analyst

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July 7, 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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