Explore the key aspects of the NIS2 Directive, the latest EU cyber security legislation coming into effect in 2024. Learn how it impacts AI and security teams.
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
John Allen
SVP, Field CISO
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The NIS2 Directive requires member states to adopt laws that will improve the cyber resilience of organizations within the EU. It impacts organizations that are “operators of essential services”. Under NIS 1, EU member states could choose what this meant. In an effort to ensure more consistent application, NIS2 has set out its own definition. It eliminates the distinction between operators of essential services and digital service providers from NIS1, instead defining a new list of sectors:
Energy (electricity, district heating and cooling, gas, oil, hydrogen)
Transport (air, rail, water, road)
Banking (credit institutions)
Financial market infrastructures
Health (healthcare providers and pharma companies)
Drinking water (suppliers and distributors)
Digital infrastructure (DNS, TLD registries, telcos, data center providers, etc.)
ICT service providers (B2B): MSSPs and managed service providers
Public administration (central and regional government institutions, as defined per member state)
Space
Postal and courier services
Waste management
Chemicals
Food
Manufacturing of medical devices
Computers and electronics
Machinery and equipment
Motor vehicles, trailers and semi-trailers and other transport equipment
Digital providers (online market places, online search engines, and social networking service platforms) and research organizations.
With these updates, it becomes harder to try and find industry segments not included within the scope. NIS2 represents legally binding cyber security requirements for a significant region and economy. Standout features that have garnered the most attention include the tight timelines associated with notification requirements. Under NIS 2, in-scope entities must submit an initial report or “early warning” to the competent national authority or computer security incident response team (CSIRT) within 24 hours from when the entity became aware of a significant incident. This is a new development from the first iteration of the Directive, which used more vague language of the need to notify authorities “without undue delay”.
Another aspect gaining attention is oversight and regulation – regulators are going to be empowered with significant investigation and supervision powers including on-site inspections.
The stakes are now higher, with the prospect of fines that are capped at €10 million or 2% of an offending organization’s annual worldwide turnover – whichever is greater. Added to that, the NIS2 Directive includes an explicit obligation to hold members of management bodies personally responsible for breaches of their duties to ensure compliance with NIS2 obligations – and members can be held personally liable.
The risk management measures introduced in the Directive are not altogether surprising – they reflect common best practices. Many organizations (especially those that are newly in scope for NIS2) may have to expand their cyber security capabilities, but there’s nothing controversial or alarming in the required measures. For organizations in this situation, there are various tools, best practices, and frameworks they can leverage. Darktrace in particular provides capabilities in the areas of visibility, incident handling, and reporting that can help.
NIS2 and Cyber AI
The use of AI is not an outright requirement within NIS2 – which may be down to lack of knowledge and expertise in the area, and/or the immaturity of the sector. The clue to this might be in the timing: the provisional agreement on the NIS2 text was reached in May 2022 – six months before ChatGPT and other open-source Generative AI tools propelled broader AI technology into the forefront of public consciousness. If the language were drafted today, it's not far-fetched to imagine AI being mentioned much more prominently and perhaps even becoming a requirement.
NIS2 does, however, very clearly recommend that “member states should encourage the use of any innovative technology, including artificial intelligence”[1]. Another section speaks directly to essential and important entities, saying that they should “evaluate their own cyber security capabilities, and where appropriate, pursue the integration of cyber security enhancing technologies, such as artificial intelligence or machine learning systems…”[2]
One of the recitals states that “member states should adopt policies on the promotion of active cyber protection”. Where active cyber protection is defined as “the prevention, detection, monitoring, analysis and mitigation of network security breaches in an active manner.”[3]
From a Darktrace perspective, our self-learning Cyber AI technology is precisely what enables our technology to deliver active cyber protection – protecting organizations and uplifting security teams at every stage of an incident lifecycle – from proactively hardening defenses before an attack is launched, to real-time threat detection and response, through to recovering quickly back to a state of good health.
The visibility provided by Darktrace is vital to understanding the effectiveness of policies and ensuring policy compliance. NIS2 also covers incident handling and business continuity, which Darktrace HEAL addresses through AI-enabled incident response, readiness reports, simulations, and secure collaborations.
Reporting is integral to NIS2 and organizations can leverage Darktrace’s incident reporting features to present the necessary technical details of an incident and provide a jump start to compiling a full report with business context and impact.
What’s next for NIS2
We don’t yet know the details for how EU member states will transpose NIS2 into national law – they have until 17th October 2024 to work this out. The Commission also commits to reviewing the functioning of the Directive every three years. Given how much our overall understanding and appreciation for not only the dangers of AI but also its power (perhaps even necessity in the realm of cyber security) is changing, we may see many member states will leverage the recitals’ references to AI in order to make a strong push if not a requirement that essential and important organizations within their jurisdiction leverage AI.
Organizations are starting to prepare now to meet the forthcoming legislation related to NIS2. Download our CISO’s Guide to NIS2 Preparedness, which includes everything you need to know to get ahead of the directive.
[1] (51) on page 11 [2] (89) on page 17 [3] (57) on page 12
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.
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Hola VPN Abuse: From Proxy Traffic to Malware and Cryptomining
Introduction
In enterprise environments, non-compliant software traffic can introduce unexpected exposure by creating unmanaged paths for outbound connectivity. Hola VPN is a notable example because of its peer-to-peer design, which can effectively turn user devices into routing or exit nodes for other parties’ traffic, shifting the risk profile from that of a traditional virtual private network (VPN) to something closer to a distributed proxy.
As a result, the appearance of Hola-related activity, whether from prior installation or unintended background connections, should be treated with caution. Such activity may provide a foothold for malicious behavior, including lateral movement or command-and-control communication.
This blog explores how Hola-associated activity appeared as part of broader patterns of suspicious behavior observed across the Darktrace customer base.
The campaign
In February and March 2026, Darktrace observed similar anomalous activity across multiple customer environments, with affected devices showing consistent behavioral patterns. These included connections to multiple *.hola[.]org endpoints using Hola-related user agents, suggesting interaction with Hola infrastructure rather than isolated or incidental traffic.
Following these connections, affected customer environments showed downloads of suspicious executable files from rare external endpoints 188.241.219[.]55 and 184.241.218[.]111. Both endpoints have been flagged as potentially malicious by open-source intelligence (OSINT) [1][2].
These downloads were conducted using consistent user agents across impacted customers, specifically ‘Hola svc_js_win32/1.249.408’ and ‘Hola svc_js_win32/1.251.389’, suggesting a possible association with Hola-related activity.
Notably, this pattern aligns with recent reporting that, in some cases, Hola distributed an undeclared executable component, me[.]exe, which was later assessed to be a likely Monero-mining binary introduced via a compromised delivery pipeline [3].
Case Study 1
Darktrace first observed a new device on January 19, 2026, within a customer environment based in the Europe, Middle East, and Africa (EMEA) region. On the same day it appeared on the network, the device communicated with multiple pieces of Hola VPN-linked infrastructure before downloading a binary from a hola[.]org subdomain.
Figure 1: Cyber AI Analyst investigation highlighting Hola VPN service activity potentially associated with subsequent HTTP command-and-control (C2) connections.
Subsequent Darktrace telemetry revealed a recurring pattern of activity from the day the device was first observed through to March 4, 2026. During this period, the device repeatedly issued HTTP GET requests to the URI /bwfile?size=1048576, each returning a 200 OK response, indicating successful file retrieval.
This behavior was accompanied by a POST request to /bwfile, followed by an additional GET request for a significantly larger file at /bwfile?size=26214400, suggesting a deliberate and structured file transfer pattern.
Notably, the binary download activity was not tied to a single static host. Instead, it was observed across multiple URLs that changed over time while remaining within the same hola[.]org domain. This pattern suggests the use of rotating or distributed delivery infrastructure rather than a fixed endpoint.
Figure 2: Variation in URLs over time within the same hola[.]org domain, indicating the use of dynamically changing endpoints.
Across these events, the activity was consistently associated with the user agent Hola svc_js_win32/1.249.408, further linking the traffic to Hola-related service components. Amid these persistent and unusual connections, on February 22, Darktrace observed the device connecting to 188.241.219[.]55/proxy-peer-windows-amd64[.]exe, resulting in the download of an executable file.
Figure 3: File transfer event showing the download of an executable from the rare external endpoint 188.241.219[.]55.
Based on its file hash, the downloaded file was assessed as a likely Trojan downloader [4], with import hash (imphash) values showing similarities to samples linked to Vidar, Rhadamanthys, and Stealc according to OSINT [5]. Overall, this sequence of activity suggests that Hola-related connectivity may have been leveraged as part of a broader malware delivery chain.
Darktrace’s Autonomous Response
Due to the highly unusual activity observed, Darktrace Autonomous Response was triggered by the device’s behavior. However, as the customer deployment was configured in “Human Confirmation” mode, manual approval was required before any action could be taken.
Had the deployment been set to “Fully Autonomous” mode, Darktrace would have automatically:
Blocked connections to the associated ports and external endpoints
Prevented all outgoing network connections from the device
Enforced the device’s established ‘pattern of life’, allowing normal activity to continue while restricting any anomalous behavior
Figure 4: Example of a Darktrace Autonomous Response model highlighting the action that would have been taken, demonstrating how the system identifies anomalous behavior and applies targeted containment measures to restrict suspicious network activity.
Case Study 2
While the first case focused on anomalous activity from a newly observed device, Darktrace also identified cases in which devices had already been communicating with Hola-related endpoints prior to the suspected campaign. This may suggest pre-existing Hola usage within the environment, potentially increasing exposure and creating an avenue for subsequent suspicious activity.
One case involved three devices within a customer network based in the Americas (AMS). In this instance, a different payload was identified: me[.]exe, a potentially malicious cryptocurrency miner also referred to as HolaMonitorService[.]exe [6][7]. The downloads were observed from infrastructure similar to that seen in Case 1, including an IP address within the same 188.241.0.0/16 subnet.
Connections to *.hola[.]org, alongside the use of potential Hola-related user agents consistent with those in Case 1, were also identified, further suggesting a link between the observed activity and Hola-associated infrastructure.
Darktrace observed activity indicative of unusual VPN usage on the first affected device on February 2, followed by telemetry suggesting potential Tor usage. This was later followed by the download of me[.]exe on March 10 from 188.241.218[.]111. Notably, this device was the earliest among the three within the deployment to exhibit the presence of the suspicious executable.
Figure 5: Cyber AI Analyst detection highlighting the download of a suspicious executable from a similar external endpoint in a separate deployment.
On March 5, 2026, the second affected device exhibited a slightly different progression, initiating connections to http-test1[.]hola[.]org using the user agent ‘hola_get’. This activity was followed by the download of me[.]exe from the same endpoint on March 13, consistent with the broader pattern of Hola-related downloads observed across the environment.
Figure 6: Example of Hola VPN-related connectivity observed on the network prior to the suspected campaign, indicating pre-existing usage that may have contributed to subsequent activity.
The final affected device within this customer’s network demonstrated a more limited but related pattern, also downloading me[.]exe on March 17 using the same ‘hola_get’ user agent.
While the earlier Hola VPN usage observed across the deployment may not have been directly related to the suspected malware campaign, it may nonetheless have contributed to reduced visibility. The presence of pre-existing Hola-related traffic could have obscured malicious activity, making it more difficult to distinguish legitimate usage from attacker-driven behavior and, in turn, hindering the timely identification of the emerging compromise.
Darktrace’s Autonomous Response
For this deployment, the customer had their Autonomous Response capability configured in “Fully Autonomous” mode, allowing Darktrace to take action without human intervention. As a result, the system was able to autonomously disrupt the activity as soon as relevant events were identified through model detections.
Figure 7: Darktrace Autonomous Response actions taken against suspicious activity linked to Hola VPN.
Suspected cryptomining activity
As previously noted, some of the observed executable payloads appear to be linked to cryptomining malware. Across a subset of affected customer environments, this assessment was further supported by subsequent device activity consistent with Monero mining. Affected devices established follow-on connections to multiple external endpoints aligned with known mining infrastructure, indicating post-download execution.
Considering the broader sequence of activity, this pattern may point to a wider form of abuse in which legitimate VPN-related traffic is used to mask or facilitate malicious behavior following compromise.
On several devices, the download of executable files, including a newly observed peer[.]exe, was followed by alerts indicative of cryptocurrency mining activity. Mining-related credentials such as ‘x’ were observed using the Minergate protocol to communicate with endpoints within the 89.125.255.0/24 subnet and 188.241.218[.]111, the same endpoint involved in earlier download activity. Additional credentials appeared to reflect device-specific CPU identifiers, for example ‘12th Gen Intel(R) Core (TM) i5-1235U’.
Observed mining methods included login, submit, and job, consistent with active participation in a pool-based mining workflow rather than passive or incidental contact. The login method indicates that the host authenticated to the mining service as a worker, job reflects the assignment of computational tasks, and submit shows completed work being returned to the pool [8]. This sequence suggests that affected devices were actively contributing processing resources as part of an unauthorized distributed mining operation.
The presence of unauthorized cryptominers can lead to degraded system performance and reduced device stability. Beyond the immediate resource impact, such activity often serves as an indicator of a broader compromise rather than an isolated issue. This may increase the risk of further malware deployment, persistence mechanisms, and lateral movement, particularly in environments where the initial intrusion has not been fully contained.
Conclusion
Across affected environments, detections such as unusual VPN usage, connections to Hola infrastructure, anomalous HTTP activity, suspicious file downloads, and subsequent cryptomining behavior were linked into a single, evolving incident narrative. This aggregation provided a clearer view of attack progression, enabling security teams to understand not just isolated alerts, but the full sequence of compromise from initial contact through to post-exploitation.
Ultimately, these activities show that the risk posed by non-compliant software such as Hola VPN can extend far beyond simple policy violations. What began as traffic to Hola-related infrastructure was, in multiple cases, followed by behavior suggesting deliberate misuse, including suspicious executable downloads using Hola-related user agents and, in some instances, evidence of active cryptomining. These were not isolated anomalies, but elements of a broader pattern in which seemingly benign proxy or VPN-related communications may have created a pathway for malicious delivery and unauthorized resource exploitation.
The significance of this activity lies not only in the downloads or mining, but in what it reveals about an attacker’s ability to blend malicious operations into traffic associated with software that may already have a foothold in the environment. When unapproved software operates within an enterprise, it can reduce visibility, blur the distinction between legitimate and malicious traffic, and create opportunities to extend compromise in ways that are persistent and difficult to detect. Darktrace’s anomaly-based approach enables these behavioral distinctions to be identified, regardless of whether the device is new or long established within the network.
Credit to Min Kim (Associate Principal Analyst), Priya Thapa (Senior Cyber Analyst) Edited by Ryan Traill (Content Manager)
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![File transfer event showing the download of an executable from the rare external endpoint 188.241.219[.]55.](https://cdn.prod.website-files.com/626ff4d25aca2edf4325ff97/6a304c2468d20aeff16a2721_Screenshot%202026-06-15%20at%2012.01.53%E2%80%AFPM.png)
