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August 29, 2023

Analyzing Post-Exploitation on Papercut Servers

Dive into our analysis covering post-exploitation activity on PaperCut servers. Learn the details and impact of this attack and how to keep yourself safe!
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
Sam Lister
Specialist Security Researcher
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29
Aug 2023

Introduction

Malicious cyber actors are known to exploit vulnerabilities in Internet-facing systems and services to gain entry to organizations’ digital environments. Keeping track of the vulnerabilities which malicious actors are exploiting is seemingly futile, with malicious actors continually finding new avenues of exploitation.  

In mid-April 2023, Darktrace, along with the wider security community, observed malicious cyber actors gaining entry to networks through exploitation of a critical vulnerability in the print management system, PaperCut. Darktrace observed two types of attack chain within its customer base, one involving the deployment of payloads to facilitate crypto-mining, and the other involving the deployment of a payload to facilitate Tor-based command-and-control (C2) communication.

Walking Through the Front Door

One of the most widely abused Initial Access methods attackers use to gain entry to an organization’s digital environment is the exploitation of vulnerabilities in Internet-facing systems and services [1]. The public disclosure of a critical vulnerability in a widely used, Internet-facing service, along with a proof of concept (POC) exploit for such vulnerability, provides malicious cyber actors with a key to the front door of countless organizations. Once malicious actors are in possession of such a key, security teams are in a race against time to patch all their vulnerable systems and services. But until organizations accomplish this, the doors are left open.

This year, the security community has seen malicious actors gaining entry to networks through the exploitation of vulnerabilities in a range of services. These services include familiar suspects, such as Microsoft Exchange and ManageEngine, along with less familiar suspects, such as PaperCut. PaperCut is a system for managing and tracking printing, copying, and scanning activity within organizations. In 2021, PaperCut was used in more than 50,000 sites across over 100 countries [2], making PaperCut a widely used print management system.

In January 2023, Trend Micro’s Zero Day Initiative (ZDI) notified PaperCut of a critical RCE vulnerability, namely CVE-2023–27350, in certain versions of PaperCut NG (PaperCut’s ‘print only’ variant) and PaperCut MF (PaperCut’s ‘extended feature’ variant) [3,4]. In March 2023, PaperCut released versions of PaperCut NG and PaperCut MF containing a fix for CVE-2023–27350 [4]. Despite this, security teams observed a surge in cases of malicious actors exploiting CVE-2023–27350 to compromise PaperCut servers in April 2023 [4-10]. This trend was mirrored in Darktrace’s customer base, where a surge in compromises of PaperCut servers was observed in April 2023.

Observed Attack Chains

In mid-April 2023, Darktrace identified two related clusters of attack chains. The attack chains within the first of these clusters involved Internet-facing PaperCut servers downloading payloads with crypto-mining capabilities from the external location, 50.19.48[.]59. While the attack chains within the second of the clusters involved Internet-facing PaperCut servers downloading payloads with Tor-based C2 capabilities from 192.184.35[.]216. The attack chains within the first cluster, which were observed on April 22, 2023, will be referred to as ‘50.19.48[.]59 chains’ and the attack chains in the second cluster, observed on April 24, 2023, will be called ‘192.184.35[.]216 chains’.

Both attack chains started with highly unusual external endpoints contacting the '/SetupCompleted' endpoint of an Internet-facing PaperCut server. These requests to the ‘/SetupCompleted’ endpoint likely represented attempts to exploit CVE-2023–27350 [10].  50.19.48[.]59 chains started with exploit connections from the external endpoint, 85.106.112[.]60, whereas 192.184.35[.]216 chains started with exploit connections from Tor nodes, such as 185.34.33[.]2.

Figure 1: Darktrace’s Advanced Search data showing likely CVE-2023-27350 exploitation activity from the suspicious, external endpoint, 85.106.112[.]60.

After the exploitation step, the two attack chains took different paths. In the 50.19.48[.]59 chains, the exploitation step was followed by the affected PaperCut server making HTTP GET requests over port 82 to the rare external endpoint, 50.19.48[.]59. In the 192.184.35[.]216 chains, the exploitation step was followed by the affected PaperCut server making an HTTP GET request over port 443 to 192.184.35[.]216.

The HTTP GET requests to 50.19.48[.]59 had Target URIs such as ‘/me1.bat’, ‘/me2.bat’, ‘/dom.zip’, ‘/mazar.bat’, and ‘/mazar.zip’, whilst the HTTP GET requests to 192.184.35[.]216 had the Target URI ‘/4591187629.exe’. The User-Agent header of the GET requests to 192.184.35[.]216 indicated that that the malicious file transfers were initiated through Microsoft’s pre-installed Background Intelligent Transfer Service (BITS).

Figure 2: Darktrace’s Advanced Search data showing a PaperCut server downloading Batch and ZIP files from 50.19.48[.]59 straight after receiving likely exploit connections from 85.106.112[.]60.
Figure 3: Darktrace’s Event Log data showing a PaperCut server downloading an executable file from 192.184.35[.]216 immediately after receiving a likely exploit connection from the Tor node, 185.34.33[.]2.

Downloads from 50.19.48[.]59 were followed by cURL GET requests to 138.68.61[.]82 and then connections to external endpoints associated with the cryptocurrency miner, Mimu (as seen in Fig 4). Downloads from 192.184.35[.]216 were followed by Python-urllib GET requests to api.ipify[.]org and long connections to Tor nodes (as seen in Fig 5).  

These facts suggest that the actor behind the 50.19.48[.]59 chains were seeking to drop cryptocurrency miners on PaperCut servers, with the intention of abusing the customer’s network to carry out resource intensive and costly cryptocurrency mining activity. Meanwhile, the actors behind the 192.184.35[.]216 chains were likely attempting to establish a Tor-based C2 channel with PaperCut servers to allow actors to further communicate with compromised devices.

Figure 4: Darktrace's Event Log data showing a PaperCut contacting 50.19.48[.]59 to download payloads, and then making a cURL request to 138.68.61[.]82 before contacting a Mimu crypto-mining endpoint.
Figure 5: Darktrace’s Event Log data showing a PaperCut server contacting 192.184.35[.]216 to download a payload, and then making connections to api.ipify[.]org and several Tor nodes.

The activities ensuing from both attack chains were varied, making it difficult to ascertain whether the activities were steps of separate attack chains, or steps of the existing 50.19.48[.]59 and 192.184.35[.]216 chains. A wide variety of activities ensued from observed 50.19.48[.]59 and 192.184.35[.]216 chains, including the abuse of pre-installed tools, such as cURL, CertUtil, and PowerShell to transfer further payloads to PaperCut servers, Cobalt Strike C2 communication, Ngrok usage, Mimikatz usage, AnyDesk usage, and in one case, detonation of the LockBit ransomware strain.

Figure 6: Diagram representing the steps of observed 50.19.48[.]59 chains.
Figure 7: Diagram representing the steps of observed 192.184.35[.]215 chains.

As the PaperCut servers that were targeted by malicious actors are Internet-facing, they regularly receive connections from unusual external endpoints. The exploit connections in the 50.19.48[.]59 and 192.184.35[.]216 chains, which originated from unusual external endpoints, were therefore not detected by Darktrace DETECT™, which relies on anomaly-based methods to detect network-based steps of an intrusion.

On the other hand, the post-exploitation steps of the 50.19.48[.]59 and 192.184.35[.]216 chains yielded ample anomaly-based detections, given that they consisted of PaperCut servers displaying highly unusual behaviors. As such Darktrace DETECT was able to successfully identify multiple chains of suspicious activity, including unusual file downloads from external endpoints and beaconing activity to rare external locations.

The file downloads from 50.19.48[.]59 observed in the 50.19.48[.]59 chains caused the following Darktrace DETECT models to breach:

- Anomalous Connection / Application Protocol on Uncommon Port

- Anomalous File / Internet Facing System File Download

- Anomalous File / Script from Rare External Location

- Anomalous File / Zip or Gzip from Rare External Location

- Device / Internet Facing Device with High Priority Alert

Figure 8: Darktrace’s Event Log data showing a PaperCut server breaching several models immediately after contacting 50.19.48[.]59.

The file downloads from 192.184.35[.]216 observed in the 192.184.35[.]216 chains caused the following Darktrace DETECT models to breach:

- Anomalous File / EXE from Rare External Location

- Anomalous File / Numeric File Download

- Device / Internet Facing Device with High Priority Alert

Figure 9: Darktrace’s Event Log data showing a PaperCut server breaching several models immediately after contacting 192.184.35[.]216.

Subsequent C2, beaconing, and crypto-mining connections in the 50.19.48[.]59 chains caused the following Darktrace DETECT models to breach:

- Anomalous Connection / New User Agent to IP Without Hostname

- Anomalous Server Activity / New User Agent from Internet Facing System

- Anomalous Server Activity / Rare External from Server

- Compromise / Crypto Currency Mining Activity

- Compromise / High Priority Crypto Currency Mining

- Compromise / High Volume of Connections with Beacon Score

- Compromise / Large Number of Suspicious Failed Connections

- Compromise / SSL Beaconing to Rare Destination

- Device / Initial Breach Chain Compromise

- Device / Large Number of Model Breaches

Figure 10: Darktrace’s Event Log data showing a PaperCut server breaching models as a result of its connections to a Mimu crypto-mining endpoint.

Subsequent C2, beaconing, and Tor connections in the 192.184.35[.]216 chains caused the following Darktrace DETECT models to breach:

- Anomalous Connection / Application Protocol on Uncommon Port

- Compromise / Anomalous File then Tor

- Compromise / Beaconing Activity To External Rare

- Compromise / Possible Tor Usage

- Compromise / Slow Beaconing Activity To External Rare

- Compromise / Uncommon Tor Usage

- Device / Initial Breach Chain Compromise

Figure 11: Darktrace’s Event Log data showing a PaperCut server breaching several models as a result of its connections to Tor nodes.

Darktrace RESPOND

Darktrace RESPOND™ was not active in any of the networks affected by 192.184.35[.]216 activity, however, RESPOND was active in some of the networks affected by 50.19.48[.]59 activity.  In those environments where RESPOND was enabled in autonomous mode, observed malicious activities resulted in intervention from RESPOND, including autonomous actions like blocking connections to specific external endpoints, blocking all outgoing traffic, and restricting affected devices to a pre-established pattern of behavior.

Figure 12: Darktrace’s Event Log data showing Darktrace RESPOND automatically performing inhibitive actions on a device in response to the device’s connection to 50.19.48[.]59.
Figure 13: Darktrace’s Event Log data showing Darktrace RESPOND automatically performing inhibitive actions on a device in response to the device’s connections to a Mimu crypto-mining endpoint.

Darktrace Cyber AI Analyst

Cyber AI Analyst autonomously investigated model breaches caused by events within these 50.19.48[.]59 and 192.184.35[.]216 chains. Cyber AI Analyst created user-friendly and detailed descriptions of these events, and then linked together these descriptions into threads representing the attack chains. Darktrace DETECT thus uncovered the individual steps of the attack chains, while Cyber AI Analyst was able to piece together the individual steps and uncover the attack chains themselves.  

Figure 14: An AI Analyst Incident entry showing the first event in a 50.19.48[.]59 chain uncovered by Cyber AI Analyst.
Figure 15: An AI Analyst Incident entry showing the second event in a 50.19.48[.]59 chain uncovered by Cyber AI Analyst.
Figure 16: An AI Analyst Incident entry showing the third event in a 50.19.48[.]59 chain uncovered by Cyber AI Analyst.
Figure 17: An AI Analyst Incident entry showing the first event in a 192.184.35[.]216 chain uncovered by Cyber AI Analyst.
Figure 18: An AI Analyst Incident entry showing the second event in a 192.184.35[.]216 chain uncovered by Cyber AI Analyst.

Conclusion

The existence of critical vulnerabilities in third-party software leaves organizations at constant risk of malicious actors breaching the perimeters of their networks. This risk can be mitigated through attack surface management and regular patching. However, this does not eliminate cyber risk entirely, meaning that organizations must be prepared for the eventuality of malicious actors getting inside their digital estate.

In April 2023, Darktrace observed malicious actors breaching the perimeters of several customer networks through exploitation of a critical vulnerability in PaperCut. Darktrace DETECT observed actors exploiting PaperCut servers to conduct a wide variety of post-exploitation activities, including downloading malicious payloads associated with cryptocurrency mining or payloads with Tor-based C2 capabilities. Darktrace DETECT created numerous model breaches based on this activity which alerted then customer’s security teams early in their development, providing them with ample time to take mitigative steps.

The successful detection of this payload delivery activity, along with the crypto-mining, beaconing, and Tor C2 activities which followed, elicited Darktrace RESPOND to take autonomous inhibitive action against the ongoing activity in those environments where it was operating in autonomous response mode.

If left to unfold, these intrusions developed in a variety of ways, in some cases leading to Cobalt Strike and ransomware activity. The detection of these intrusions in their early stages thus played a vital role in preventing malicious cyber actors from causing significant disruption.

Credit to: Sam Lister, Senior SOC Analyst, Zoe Tilsiter, Senior Cyber Analyst.

Appendices

MITRE ATT&CK Mapping

Initial Access techniques:

- Exploit Public-Facing Application (T1190)

Execution techniques:

- Command and Scripting Interpreter: PowerShell (T1059.001)

Discovery techniques:

- System Network Configuration Discovery (T1016)

Command and Control techniques

- Application Layer Protocol: Web Protocols (T1071.001)

- Encrypted Channel: Asymmetric Cryptography (T1573.002)

- Ingress Tool Transfer (T1105)

- Non-Standard Port (T1571)

- Protocol Tunneling (T1572)

- Proxy: Multi-hop Proxy (T1090.003)

- Remote Access Software (T1219)

Defense Evasion techniques:

- BITS Jobs (T1197)

Impact techniques:

- Data Encrypted for Impact (T1486)

List of Indicators of Compromise (IoCs)

IoCs from 50.19.48[.]59 attack chains:

- 85.106.112[.]60

- http://50.19.48[.]59:82/me1.bat

- http://50.19.48[.]59:82/me2.bat

- http://50.19.48[.]59:82/dom.zip

- 138.68.61[.]82

- update.mimu-me[.]cyou • 102.130.112[.]157

- 34.195.77[.]216

- http://50.19.48[.]59:82/mazar.bat

- http://50.19.48[.]59:82/mazar.zip

- http://50.19.48[.]59:82/prx.bat

- http://50.19.48[.]59:82/lol.exe  

- http://77.91.85[.]117/122.exe

- windows.n1tro[.]cyou • 176.28.51[.]151

- 77.91.85[.]117

- 91.149.237[.]76

- kernel-mlclosoft[.]site • 104.21.29[.]206

- tunnel.us.ngrok[.]com • 3.134.73[.]173

- 212.113.116[.]105

- c34a54599a1fbaf1786aa6d633545a60 (JA3 client fingerprint of crypto-mining client)

IoCs from 192.184.35[.]216 attack chains:

- 185.56.83[.]83

- 185.34.33[.]2

- http://192.184.35[.]216:443/4591187629.exe

- api.ipify[.]org • 104.237.62[.]211

- www.67m4ipctvrus4cv4qp[.]com • 192.99.43[.]171

- www.ynbznxjq2sckwq3i[.]com • 51.89.106[.]29

- www.kuo2izmlm2silhc[.]com • 51.89.106[.]29

- 148.251.136[.]16

- 51.158.231[.]208

- 51.75.153[.]22

- 82.66.61[.]19

- backmainstream-ltd[.]com • 77.91.72[.]149

- 159.65.42[.]223

- 185.254.37[.]236

- http://137.184.56[.]77:443/for.ps1

- http://137.184.56[.]77:443/c.bat

- 45.88.66[.]59

- http://5.8.18[.]237/download/Load64.exe

- http://5.8.18[.]237/download/sdb64.dll

- 140e0f0cad708278ade0984528fe8493 (JA3 client fingerprint of Tor-based client)

References

[1] https://www.cisa.gov/news-events/cybersecurity-advisories/aa22-137a

[2] https://www.papercut.com/kb/Main/PaperCutMFSolutionBrief/

[3] https://www.zerodayinitiative.com/advisories/ZDI-23-233/

[4] https://www.papercut.com/kb/Main/PO-1216-and-PO-1219

[5] https://www.trendmicro.com/en_us/research/23/d/update-now-papercut-vulnerability-cve-2023-27350-under-active-ex.html

[6] https://www.huntress.com/blog/critical-vulnerabilities-in-papercut-print-management-software

[7] https://news.sophos.com/en-us/2023/04/27/increased-exploitation-of-papercut-drawing-blood-around-the-internet/

[8] https://twitter.com/MsftSecIntel/status/1651346653901725696

[9] https://twitter.com/MsftSecIntel/status/1654610012457648129

[10] https://www.cisa.gov/news-events/cybersecurity-advisories/aa23-131a

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
Sam Lister
Specialist Security Researcher

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May 27, 2026

How to Evaluate AI Vendors: 5 Key categories for AI Adoption

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Understanding the AI buyers’ market

AI adoption has become a central topic of discussion in boardrooms, drawing growing interest from business leaders. Ultimately, organizations hope that an investment in AI technology will have tremendous returns. However, the process of buying an AI solution is not as straight forward as it appears on the surface.  

While business leaders may be eager to improve productivity across their operations, practitioners responsible for evaluating and selecting AI solutions may not always have the visibility or technical understanding needed to make the right decisions for their business. What is typically marketed as a holistic solution to their most critical problems is usually followed by uncertainty when AI tools are finally operationalized in real environments.

This guide is intended to support security leaders who are under growing pressure to adopt AI tools while navigating complex terminology, vendor claims, and increasingly crowded buying cycles. Ultimately, the goal is to help organizations evaluate and adopt AI in a safe, effective, and well-governed way. To support this, we’ve structured the evaluation framework across five key categories:

  1. Governance, safety, and data controls
  1. Data gathering and training
  1. Model and technique choice
  1. Performance and accuracy validation    
  1. Interpretability, adjustability, and transparency    

What buying AI looks like in cybersecurity

While investing in AI can bring immense benefits to your security team, first-time buyers of AI cybersecurity solutions may not know where to start. They will have to determine the type of tool they want, know the options available, and evaluate vendors. Research and understanding are critical to ensure purchases are worth the investment.  

With acceleration in AI adoption, accompanied by the recent boom in agentic AI and autonomous agents, CISOs must look “beneath the hood" of these tools to understand how they work, how they are governed, and to ensure the system is secure and compliant with internal policies.

Challenges in the AI buyers’ marketplace  

The AI security software market is buzzing with hype and flashy promises, which, understandably, needs to be addressed with due diligence. Potential buyers, especially in the cybersecurity space, are hesitant when it comes to allowing AI autonomous capabilities across their workflows, and a lack of vendor transparency can exacerbate those feelings.  

Reinforcing this sentiment, research from this year's Darktrace’s State of AI Cybersecurity report shows where confidence and hesitancy emerge amongst potential buyers. On the one hand, security professionals agree that they have good visibility into the logic and reasoning processes their AI solutions use. However, they lack the explainability and trust to allow AI to take independent remedial action.

  • 89% say they have good visibility into the reasoning behind the outputs generated by AI solutions
  • 92% say they need to understand how a defensive AI tool makes decisions before they can trust it
  • Only 14% say they allow AI to act independently, performing autonomous actions without human approval
  • 74% say they are limiting the autonomy of AI taking action in their SOC until explainability improves

Given the desire for trust and explainability we are seeing from buyers, it's important for them to be equipped with the right questions to ask vendors during an assessment or POV of AI tools in order to demystify marketing hype from real operational outcomes.

Below is a list of categories in which buyers can assess AI vendors or AI Service Providers (AISPs) to help reach safe adoption and maximize their ROI.  

5 categories of AI vendor assessment

Darktrace groups these AI-related questions into 5 categories: governance, data and training, model and technique choice, performance validation, and interpretability and adjustability. By asking questions regarding each of these 5 categories, buyers can gain a deeper understanding of how an AISP’s systems work and whether they suit their business requirements.

Governance, safety, and data controls

Governance of AI systems is critical for all AISPs. Whether their platform is based around a single model, or is a more complex, composite AI solution, strong governance is essential to ensure the system is safe, robust, and reliable.

A simple question you could ask is:

What AI governance policies and frameworks do you follow, and/or certifications do you currently maintain?

For more questions you can ask vendors, download the full guide here.

Darktrace is certified to the ISO/IEC 42001 standard, the world’s first AI Management System (AIMS) standard. ISO/IEC 42001 addresses the unique ethical and technical challenges AI poses by setting out a structured way to manage risks such as transparency, accuracy, and misuse. This includes a commitment to ethical AI development, and effective management and monitoring of AI systems both prior to and continually after release.

Data gathering and training

Accurate, meaningful, and unbiased data gathering is the first important step in producing any AI system. An AI model trained using inaccurate, unbalanced, or poor-quality training data will fail to perform optimally.

To alleviate concerns regarding training data quality, a question you could ask is:

What steps do you take to prevent bias in your AI models and training data?

For more questions, download the full guide here.

AISPs should be able to provide information about the steps taken, workflows followed, and auditing performed to reduce AI bias where appropriate. While it’s sometimes impossible to fully remove bias from an AI model, appropriate actions should be taken to mitigate or reduce bias where relevant.

Model and technique choice

Different AI techniques are optimal for different tasks. For example, research from Gartner suggests that relying on a single “one-size-fits-all" model can lead to data gaps, especially in highly specialized domains.

To achieve more accurate and robust AI solutions, AI leaders should move beyond using just one model or technique, embrace composite AI practices, and adopt a holistic AI system perspective.

A straightforward question you could ask is simply:

What type(s) of AI model(s) do you utilize in your solution?

For more questions, download the full guide here.

While specific detailed information about custom systems used by AISPs is likely proprietary, buyers should expect vendors to be able to provide an overview of the broad techniques used. This will allow you as a buyer to determine if the type of model is appropriate for your use case.

Performance and accuracy validation  

Testing and evaluation of performance is essential for all AI systems. Performance analysis should be performed both before release and continually after release to identify potential data or model drift.  

A question you could ask to understand an AISPs testing workflow is:

How do you audit, test, evaluate, verify, and validate your AI model outputs?

For more questions, download the full guide here.

Testing workflows will likely vary depending on the type of model – measurements relevant to one system may not always be relevant to others. Assessment of systems should also extend beyond these standard accuracy and robustness tests, and should also feature physical performance, such as latency and resource consumption.  

Interpretability, adjustability, and transparency  

AI systems are typically a black box, simply providing an output without an explanation of how that output was attained. Interpretability and transparency are critical to ensure that both SOC teams and end-users trust the outputs of a system to be accurate and meaningful.

A question you could ask is:

How do you promote a trust relationship between human analysts and AI outputs?

For more questions, download the full guide here.

In the context of cybersecurity, trust and interpretability are even more essential. This is particularly relevant for generative AI-based systems (including most AI Agents), where the risk of hallucination can reduce trust in responses.

Cybersecurity systems often need to perform autonomous actions to block incoming threats – an email filtering system may hold potentially dangerous emails; a firewall may block malicious inbound connections. If SOC teams can’t trust these systems to perform accurately, these systems may be limited or disabled, critically reducing their defensive power.

Darktrace as an AI-native cybersecurity vendor

Darktrace has been building and applying AI in cybersecurity for over a decade, developing its capabilities alongside an increasingly complex and fast‑moving threat landscape. This experience has resulted in a mature, multi-layered approach to AI, which continuously learns the normal patterns of each organization to understand behavior, interpret context, and identify meaningful deviations — without relying on predefined rules or known attack signatures. Over time, this has enabled a proven behavioral understanding that helps uncover subtle signals of risk that may otherwise be missed.

With the backing of our ISO/IEC 42001 certification, stakeholders, customers, and partners can be confident that Darktrace is responsibly, ethically, and safely developing its AI systems, and managing the use of AI in day-to-day operations in a compliant and secure manner.  

Explore the principles behind Darktrace’s responsible AI approach, informed by collaboration with global experts in academia and governments, detailing how accountability, explainability, and continuous validation are built into its cybersecurity technology.

How Darktrace secures AI systems

Darktrace now brings these capabilities to monitor and respond to risk generated from AI systems across organizations with Darktrace / SECURE AI. This solution analyzes how prompts, agents, and systems are used within the context of each organization, bringing every AI interaction into a single view. This unique approach helps teams understand intent, assess risk, protect sensitive data, and enforce policy across both human and AI agent activity.

Stay up to date

Sign up for the Secure AI Readiness Program here: This gives you exclusive access to the latest news on the latest AI threats, updates on emerging approaches shaping AI security, and insights into the latest innovations, including Darktrace’s ongoing work in this area.

Ready to talk with a Darktrace expert on securing AI? Register here to receive practical guidance on the AI risks that matter most to your business, paired with clarity on where to focus first across governance, visibility, risk reduction, and long-term readiness.  

Further Reading on AI in cybersecurity

When deciding to invest in an AI solution, it’s important to understand what this means for you and your organization. The questions presented here are only a starting point in understanding an AI solution and whether it is appropriate for your use case.  

Gain deeper knowledge on applications of AI in cybersecurity and Darktrace’s multi-layered AI in the AI Arsenal White Paper.

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May 26, 2026

The CIP-015 Countdown: What Utilities Should Be Doing Before October 2028

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CIP-015 what you need to know

The electric sector already knows CIP-015 is coming. The better question is whether utilities are using the time before October 1, 2028 to build an Internal Network Security Monitoring program that is defensible, auditable, and operationally useful.

I have spent most of my OT cybersecurity career around the power sector, from early NERC CIP program work as an asset owner, to consulting with utilities ranging from small municipalities and rural cooperatives to some of the largest power companies in the country, to now working with technology that helps organizations improve visibility and detection across IT and OT. One lesson has been consistent across all of those roles: compliance is not just about having a control in place. It is about being able to prove the control works.

That is where CIP-015 becomes important.

The standard is not simply asking utilities to deploy a tool inside the Electronic Security Perimeter and call the job done. CIP-015 is about improving the probability of detecting anomalous or unauthorized network activity so that organizations can improve response and recovery from an attack. That purpose is directly stated in the standard itself. (NERC)

The real work between now and October 2028 is not just buying technology. It is building an INSM capability that can collect the right data, detect meaningful activity, support evaluation, retain the right evidence, and protect that evidence from unauthorized deletion or modification.

Why CIP-015 exists

CIP-015 exists because perimeter security alone does not solve the internal visibility problem.

For years, many CIP controls have focused heavily on access management, segmentation, patching, logging, training, and other security practices that help reduce the likelihood of unauthorized access. Those controls still matter. But they do not fully answer what happens after an attacker, insider, compromised vendor account, misused credential, or malicious activity is already operating inside a trusted environment.

NERC’s technical rationale explains that Internal Network Security Monitoring focuses on the collection and analysis of network communications inside a “trust zone,” such as an ESP. In other words, CIP-015 is not only about defending the edge. It is about understanding what is happening inside the environment once traffic is already within the trusted zone. (NERC)

That is the internal visibility gap utilities need to close.

Why traditional security monitoring does not fully satisfy CIP-015

One mistake utilities should avoid is assuming that existing security event monitoring automatically solves CIP-015.

Many organizations already have logging programs tied to CIP-007, SIEM use cases, host-level security events, authentication logs, malware alerts, and incident response workflows. Those capabilities remain valuable, but they are not the same as Internal Network Security Monitoring.

Security event monitoring often tells you what happened on or to a system. INSM is intended to help show what is happening between systems, across network communications, devices, connections, and internal traffic patterns. That distinction is especially important in OT environments where adversaries may use legitimate pathways, valid credentials, native protocols, remote access, engineering workstations, or trusted systems to move inside the environment.

CIP-015 pushes utilities toward a different level of visibility: not just “did a system log something,” but “can we see and evaluate anomalous or unauthorized activity occurring inside the ESP?”

What CIP-015 requires

At a high level, CIP-015-1 requires three core capabilities.

Requirement R1: Monitoring internal network activity  

First, under Requirement R1, Responsible Entities must implement, using a risk-based rationale, network data feeds to monitor network activity, including connections, devices, and network communications. They must also implement one or more methods to detect anomalous network activity using those feeds, and one or more methods to evaluate detected anomalous activity to determine further actions.

Requirement R2: Retaining INSM data for investigations

Second, under Requirement R2, entities must retain INSM data associated with anomalous network activity at least until the related evaluation and action are complete. The standard also notes that entities are not required to retain INSM data that is not relevant to detected anomalous activity.

Requirement R3: Protecting monitoring data from tampering

Third, under Requirement R3, entities must protect INSM data collected for R1 and retained for R2 from unauthorized deletion or modification.

Those requirements may sound straightforward, but implementation is where the challenge begins.

What should utilities be asking themselves for CIP-015?

  • Where are we collecting network data inside the ESP, and why are those feeds defensible?
  • What methods are we using to detect anomalous network activity?
  • How do we distinguish meaningful anomalous behavior from normal operational change?
  • Who evaluates detections, and how are decisions documented?
  • What data is retained, and how is it protected from unauthorized deletion or modification?
  • Can we produce evidence that proves this process has worked over time?

Those answers matter because auditors will not be looking for marketing claims. They will be looking for evidence.

Why anomaly detection is central to CIP-015 compliance

One of the most important parts of CIP-015 is also one of the easiest to oversimplify: the word anomalous.

NERC’s technical rationale provides useful context. It explains that, as used in CIP-015, “anomalous” refers to unexpected, undesired, unusual, or undetermined network traffic. It also makes clear that the term does not refer to any single proprietary technology commonly marketed as “anomaly detection.”

Understanding static baselines vs true anomaly detection

A static baseline is not the same thing as meaningful anomaly detection. If a platform observes traffic for a limited period of time, assumes that observed behavior is “normal,” and then flags future deviations without deeper context, the result can be noisy, brittle, and operationally frustrating.

In real OT environments, “normal” is not fixed. Maintenance windows, vendor access, failovers, engineering changes, testing activity, backup jobs, and operational shifts can all change behavior. Detection has to keep learning and understand context. Otherwise, the organization may end up with alerts that are technically anomalous but not practically useful.

CIP-015 is not just about producing anomalies. It is about producing meaningful detections that can be evaluated, documented, and acted upon.

What should utilities consider when looking for anomaly detection tools

Some technologies were built around behavioral analysis and anomaly detection long before CIP-015 existed. What practitioners should look for is if the technology behind the phrase can identify meaningful deviations, provide context, reduce noise, and support the evaluation and evidence expectations of the standard.

Utilities should be cautious of vendor positioning that treats “anomaly” as a simple compliance keyword. This is especially important when evaluating tools historically built around signature-based, threat-based, or rule-based detection methods that are now being positioned as anomaly detection because CIP-015 uses the term.

A platform does not solve CIP-015 simply because it can baseline traffic or generate alerts when something changes.

The question is not: Can this tool create alerts?

The question is: Can this tool identify meaningful anomalous activity with enough context, prioritization, and evidence to support evaluation and response?

Why evidence and audit readiness matter for CIP-015

In NERC CIP, the control is only part of the story. Evidence is the part that proves the control existed, worked, and was followed.

That is why CIP-015 readiness should not be treated as a simple deployment project. It should be treated as a compliance operations and evidence program.

What auditors will expect utilities to prove

For R1, examples of evidence include documentation of network data feeds and the risk-based rationale for selecting them, anomalous network detection events, INSM configuration settings, communication baselines or other detection methods, methods used to evaluate anomalous activity, and actions taken in response to detected anomalies.

For R2, evidence may include documentation of the retention process, system configurations, or system-generated reports showing retention timelines sufficient to support evaluation. For R3, evidence may include documentation showing how INSM data is protected from unauthorized deletion or modification.

Common evidence gaps that can create compliance risk

If an entity implements a platform that generates noisy detections, lacks context, does not retain the right data, cannot demonstrate how data is protected, or cannot produce useful audit evidence, the issue may not become obvious until much later. By then, an organization may discover during an audit that it cannot prove what it thought it had implemented.

That is a bad place to be.

CIP evidence gaps can create exposure that goes back over time, not just to the day the audit finding is discovered. This is why utilities need to validate the process early. Do not wait until an audit cycle to find out whether your INSM approach can stand up to scrutiny.

How utilities should prepare for CIP-015 before 2028

October 2028 may sound far away, but in utility planning terms, it is not.

Utilities should already be moving through a structured readiness process.

Assessing internal network visibility across trusted environments

Start with scope. Identify the applicable High and Medium Impact BES Cyber Systems, the relevant ESPs, and the environments where INSM requirements will apply. Then map current visibility. Where do you already have useful network monitoring? Where are you relying mostly on logs, perimeter controls, or assumptions? Where do you have limited east-west visibility inside trusted environments?

Building a defensible network data feed strategy

Next, define the network data feed strategy. CIP-015 requires a risk-based rationale, so the organization should be able to explain why specific feeds were selected and how they support detection of anomalous activity across relevant connections, devices, and communications.

Validating anomaly detection workflows

Then validate the detection method. This is where utilities need to go deeper than vendor claims. Ask how the platform identifies anomalous activity. Ask how it reduces noise. Ask what context is provided for evaluation. Ask how it handles changes in normal operations. Ask what evidence is retained and how that evidence can be produced.

Testing evidence retention and protection processes

After that, build the evaluation workflow. Who reviews detections? How are anomalies classified as benign, abnormal but not suspicious, suspicious, or potentially malicious? When does an event move into CIP-008 incident response? What documentation is created during that process?

Finally, test evidence production. Utilities should be able to show detection records, configuration settings, evaluation notes, response actions, retention records, and data protection controls before an auditor asks for them.

Where Darktrace Fits into CIP-015

This is where technology matters, but only as part of the broader program.

Darktrace was built on self-learning anomaly detection long before CIP-015 created a new compliance driver around anomalous network activity. Its value is rooted in continuous behavioral understanding, multiple analytical techniques, and the ability to identify meaningful deviations across complex IT and OT environments. That matters because CIP-015 requires more than basic alerting. It requires detection that supports evaluation, evidence, and action.

This IT and OT visibility is especially important in power utility environments. High and Medium Impact environments are not made up only of industrial protocols and field devices. Control centers, operational workstations, engineering workstations, servers, remote access systems, domain services, printers, and other enterprise-class assets often sit inside or adjacent to critical operational environments. A useful INSM capability should understand a wide range of communications across both IT and OT, not only traditional industrial protocols like Modbus, DNP3, or IEC 61850.

That distinction matters because “protocol support” can mean very different things. Identifying that a protocol is present is not the same as performing deeper packet analysis that can provide behavioral context, richer protocol understanding, and meaningful detection across the communications actually used inside the environment. For CIP-015, utilities should be asking whether a platform can help evaluate activity across both enterprise and industrial communications, because real power utility environments are rarely “OT-only.”

This is also why utilities should look carefully at how vendors use the word “anomaly.” Some platforms were designed around behavioral understanding and anomaly detection long before CIP-015 created a new compliance driver. Others may now be adopting the language because the standard uses the term. The difference matters. Utilities should ask whether the platform’s detection approach is foundational to the technology, or simply a new label applied to existing signature-based, threat-based, or rule-based methods.

In OT environments, detection quality matters. Utilities do not need more noise. They need visibility into internal communications, confidence in what is normal, context when something changes, and prioritization that helps security and operations teams focus on what matters.

A strong INSM program should help utilities move from raw monitoring to operational confidence. It should support east-west visibility, better anomaly evaluation, defensible evidence retention, protection of monitoring data, and alignment between compliance and security outcomes.

That is the right way to think about CIP-015.

Not as “deploy a tool and move on.”But as “build a capability that can be trusted, operated, and proven.”

CIP-015 is about proving your INSM capability works

The CIP-015 countdown is real, but the countdown itself is not the whole story.

The real story is what utilities do with the time that remains.

Organizations that treat CIP-015 as a checkbox may be able to say they deployed something. But organizations that treat it as an opportunity to close the internal visibility gap will gain something much more valuable: better detection, better response, better evidence, and stronger operational resilience.

The question utilities should be asking now is not whether they can produce more alerts before October 2028.

The question is whether they can prove their INSM capability actually works.

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About the author
Jeffrey Macre
Principal Industrial Security Solutions Architect
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