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October 31, 2024

Understanding NERC CIP-015 Requirements

Learn about NERC CIP-015 and its internal network security monitoring requirements. Discover how to ensure compliance and enhance your security posture.
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
Daniel Simonds
Director of Operational Technology
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31
Oct 2024

Background: NERC CIP-015

In January of 2023 the Federal Energy Regulatory Commission (FERC) released FERC Order 887 which addresses a critical security gap in Critical Infrastructure Protection (CIP) standards, the lack of internal network security monitoring (INSM).

The current NERC CIP standards only require solutions that use traditional detection systems that identify malicious code based on known rules and signatures. The new legislation will now require electric cooperatives to implement INSMs to detect malicious activity in east-west network traffic. INSMs establish a baseline of network activity and detect anomalies that would bypass traditional detection systems, improving an organization’s ability to detect novel threats. Without INSM, organizations have limited visibility into malicious activities inside their networks, leaving them vulnerable if attackers breach initial defenses like firewalls and anti-virus software.

Implementation of NERC CIP-015

Once approved, Bulk Electronic Systems (BESs) will have 36 months to implement INSM, and medium-impact BESs with external routable connectivity (ERC) will have 60 months to do so.

While the approval of the NERC CIP-015 requirements have not been finalized, preparation on the part of electric cooperatives should start as soon as possible. Darktrace is committed to helping electric cooperatives meet the requirements for INSM and help reach compliance standards.

Why is internal network security monitoring important?

NERC CIP-015 aims to enhance the detection of anomalies or unauthorized network activity within CIP environments, underscoring the importance of monitoring East-West traffic within trust zones. This approach enables faster response and recovery times.

INSMs are essential to detecting threats that bypass traditional defenses. For example, insider threats, sophisticated new attack techniques, and threats that exploit compromised credentials—such as those obtained through phishing or other malicious activities—can easily bypass traditional firewalls and antivirus software. These threats either introduce novel methods or leverage legitimate access, making them difficult to detect.

INSMs don’t rely on rules and signatures to detect anomalous activity, they spot abnormalities in network traffic and create alerts based on this activity making them vital to detecting sophisticated threats. Additionally, INSM sits behind the firewall and provides detections utilizing the passive monitoring of east west and north south traffic within the enforcement boundary.

Buyers should be aware of the discrepancies between different INSMs. Some systems require constant tuning and updating, external connectivity forcing holes in segmentation or have intrusive deployments that put sensitive OT assets at risk.

What are the NERC CIP-015 requirements?

The goal of this directive is to ensure that cyber threats are identified early in the attack lifecycle by mandating implementation of security systems that detect and speed up mitigation of malicious activity.

The requirements are divided into three sections:

  • Network security monitoring
  • Data retention for anomalous activity
  • Data protection

NERC CIP-015 emphasizes the importance of having documented processes and evidence of implementation, with a focus on risk-based monitoring, anomaly detection, evaluation, retention of data, and protection against unauthorized access. Below is a breakdown of each requirement.

R1: Network Security Monitoring

The NERC CIP-015 requires the implementation of and a documented process for monitoring networks within Electronic Security Perimeters (ESPs) that contain high and medium impact BES Cyber Systems.

Key parts:

Part 1.1: Use a risk-based rationale to implement network data feeds that monitor connections, devices, and communications.

Part 1.2: Detect anomalous network activity using the data feeds.

Part 1.3: Evaluate the anomalous activity to determine necessary actions.

M1: Evidence for R1 Implementation: Documentation of processes, including risk-based rationale for data collection, detection events, configuration settings, and network baselines.

Incorporating automated solutions for network baselining is essential for effective internal monitoring, especially in diverse environments like substations and control centers. Each environment requires unique baselines—what’s typical for a substation may differ significantly from a control center, making manual monitoring impractical.

A continuous internal monitoring solution powered by artificial intelligence (AI) simplifies this challenge by instantly detecting all connected assets, dynamically learning the environment’s baseline behavior, and identifying anomalies in real-time. Unlike traditional methods, Darktrace’s AI-driven approach requires no external connectivity or repeated tuning, offering a seamless, adaptive solution for maintaining secure operations across all environments.

R2: Data Retention for Anomalous Activity

Documented processes must be in place to retain network security data related to detected anomalies until the required actions are completed.

Note: Data that does not relate to detected anomalies (Part 1.2) is not required to be retained.

M2: Evidence for Data Retention (R2): Documentation of data retention processes, system configurations, or reports showing compliance with R2.

R3: Data Protection: Implement documented processes to protect the collected security monitoring data from unauthorized deletion or modification.

M3: Evidence for Data Protection (R3): Documentation demonstrating how network security monitoring data is protected from unauthorized access or changes.

How to choose the right INSM for your organization?

Several vendors will offer INSM, but how do you choose the right solution for your organization?

Here are seven questions to help you get started evaluating potential INSM vendors:

  1. How does the solution help with ongoing compliance and reporting including CIP-015? Or any other regulations we comply with?
  2. Does the solution provide real-time monitoring of east-west traffic across critical systems? And what kind of threats has it proven capable of finding?
  3. How deep is the traffic visibility—does it offer Layer 7 (application) insights, or is it limited to Layers 3-4?
  4. Is the solution compatible with our existing infrastructure (firewalls, IDS/IPS, SIEM, OT networks)?
  5. Is this solution inline, passive, or hybrid? What impact will it have on network latency?
  6. Does the vendor have experience with electric utilities or critical infrastructure environments?
  7. Where and how are logs and monitoring data stored?

How Darktrace helps electric utilities with INSM requirements

Darktrace's ActiveAI Security Platform is uniquely designed to continuously monitor network activity and detect anomalous activity across both IT and OT environments successfully detecting insider threats and novel ransomware, while accelerating time to detection and incident reporting.

Most INSM solutions require repeated baselining, which creates more work and increases the likelihood of false positives, as even minor deviations trigger alerts. Since networks are constantly changing, baselines need to adjust in real time. Unlike these solutions, Darktrace does not depend on external connectivity or cloud access over the public internet. Our passive network analysis requires no agents or intrusive scanning, minimizing disruptions and reducing risks to OT systems.

Darktrace's AI-driven threat detection, asset management, and incident response capabilities can help organizations comply with the requirements of NERC CIP-015 for internal network security monitoring and data protection. Built specifically to deploy in OT environments, Darktrace / OT comprehensively manages, detects, evaluates, and protects network activity and anomalous events across IT and OT environments, facilitating adherence to regulatory requirements like data retention and anomaly management.

See how INSM with Darktrace can enhance your security operations, schedule a personalized demo today.

Disclaimer

The information provided in this blog is intended for informational purposes only and reflects Darktrace’s understanding of the NERC CIP-015 INSM requirements as of the publication date. While every effort has been made to ensure the accuracy and reliability of the content, Darktrace makes no warranties or representations regarding its accuracy, completeness, or applicability to specific situations. This blog does not constitute legal or compliance advice and readers are encouraged to consult with qualified professionals for guidance specific to their circumstances. Darktrace disclaims any liability for actions taken or not taken based on the information contained herein.

References

1.     https://www.nerc.com/pa/Stand/Reliability%20Standards/CIP-015-1.pdf

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
Daniel Simonds
Director of Operational Technology

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May 8, 2025

Anomaly-based threat hunting: Darktrace's approach in action

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What is threat hunting?

Threat hunting in cybersecurity involves proactively and iteratively searching through networks and datasets to detect threats that evade existing automated security solutions. It is an important component of a strong cybersecurity posture.

There are several frameworks that Darktrace analysts use to guide how threat hunting is carried out, some of which are:

  • MITRE Attack
  • Tactics, Techniques, Procedures (TTPs)
  • Diamond Model for Intrusion Analysis
  • Adversary, Infrastructure, Victims, Capabilities
  • Threat Hunt Model – Six Steps
  • Purpose, Scope, Equip, Plan, Execute, Feedback
  • Pyramid of Pain

These frameworks are important in baselining how to run a threat hunt. There are also a combination of different methods that allow defenders diversity– regardless of whether it is a proactive or reactive threat hunt. Some of these are:

  • Hypothesis-based threat hunting
  • Analytics-driven threat hunting
  • Automated/machine learning hunting
  • Indicator of Compromise (IoC) hunting
  • Victim-based threat hunting

Threat hunting with Darktrace

At its core, Darktrace relies on anomaly-based detection methods. It combines various machine learning types that allows it to characterize what constitutes ‘normal’, based on the analysis of many different measures of a device or actor’s behavior. Those types of learning are then curated into what are called models.

Darktrace models leverage anomaly detection and integrate outputs from Darktrace Deep Packet Inspection, telemetry inputs, and additional modules, creating tailored activity detection.

This dynamic understanding allows Darktrace to identify, with a high degree of precision, events or behaviors that are both anomalous and unlikely to be benign.  On top of machine learning models for detection, there is also the ability to change and create models showcasing the tool’s diversity. The Model Editor allows security teams to specify values, priorities, thresholds, and actions they want to detect. That means a team can create custom detection models based on specific use cases or business requirements. Teams can also increase the priority of existing detections based on their own risk assessments to their environment.

This level of dexterity is particularly useful when conducting a threat hunt. As described above, and in previous ‘Inside the SOC’ blogs such a threat hunt can be on a specific threat actor, specific sector, or a  hypothesis-based threat hunt combined with ‘experimenting’ with some of Darktrace’s models.

Conducting a threat hunt in the energy sector with experimental models

In Darktrace’s recent Threat Research report “AI & Cybersecurity: The state of cyber in UK and US energy sectors” Darktrace’s Threat Research team crafted hypothesis-driven threat hunts, building experimental models and investigating existing models to test them and detect malicious activity across Darktrace customers in the energy sector.

For one of the hunts, which hypothesised utilization of PerfectData software and multi-factor authentication (MFA) bypass to compromise user accounts and destruct data, an experimental model was created to detect a Software-as-a-Service (SaaS) user performing activity relating to 'PerfectData Software’, known to allow a threat actor to exfiltrate whole mailboxes as a PST file. Experimental model alerts caused by this anomalous activity were analyzed, in conjunction with existing SaaS and email-related models that would indicate a multi-stage attack in line with the hypothesis.

Whilst hunting, Darktrace researchers found multiple model alerts for this experimental model associated with PerfectData software usage, within energy sector customers, including an oil and gas investment company, as well as other sectors. Upon further investigation, it was also found that in June 2024, a malicious actor had targeted a renewable energy infrastructure provider via a PerfectData Software attack and demonstrated intent to conduct an Operational Technology (OT) attack.

The actor logged into Azure AD from a rare US IP address. They then granted Consent to ‘eM Client’ from the same IP. Shortly after, the actor granted ‘AddServicePrincipal’ via Azure to PerfectData Software. Two days later, the actor created a  new email rule from a London IP to move emails to an RSS Feed Folder, stop processing rules, and mark emails as read. They then accessed mail items in the “\Sent” folder from a malicious IP belonging to anonymization network,  Private Internet Access Virtual Private Network (PIA VPN) [1]. The actor then conducted mass email deletions, deleting multiple instances of emails with subject “[Name] shared "[Company Name] Proposal" With You” from the  “\Sent folder”. The emails’ subject suggests the email likely contains a link to file storage for phishing purposes. The mass deletion likely represented an attempt to obfuscate a potential outbound phishing email campaign.

The Darktrace Model Alert that triggered for the mass deletes of the likely phishing email containing a file storage link.
Figure 1: The Darktrace Model Alert that triggered for the mass deletes of the likely phishing email containing a file storage link.

A month later, the same user was observed downloading mass mLog CSV files related to proprietary and Operational Technology information. In September, three months after the initial attack, another mass download of operational files occurred by this actor, pertaining to operating instructions and measurements, The observed patience and specific file downloads seemingly demonstrated an intent to conduct or research possible OT attack vectors. An attack on OT could have significant impacts including operational downtime, reputational damage, and harm to everyday operations. Darktrace alerted the impacted customer once findings were verified, and subsequent actions were taken by the internal security team to prevent further malicious activity.

Conclusion

Harnessing the power of different tools in a security stack is a key element to cyber defense. The above hypothesis-based threat hunt and custom demonstrated intent to conduct an experimental model creation demonstrates different threat hunting approaches, how Darktrace’s approach can be operationalized, and that proactive threat hunting can be a valuable complement to traditional security controls and is essential for organizations facing increasingly complex threat landscapes.

Credit to Nathaniel Jones (VP, Security & AI Strategy, Field CISO at Darktrace) and Zoe Tilsiter (EMEA Consultancy Lead)

References

  1. https://spur.us/context/191.96.106.219

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About the author
Nathaniel Jones
VP, Security & AI Strategy, Field CISO

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May 6, 2025

Combatting the Top Three Sources of Risk in the Cloud

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With cloud computing, organizations are storing data like intellectual property, trade secrets, Personally Identifiable Information (PII), proprietary code and statistics, and other sensitive information in the cloud. If this data were to be accessed by malicious actors, it could incur financial loss, reputational damage, legal liabilities, and business disruption.

Last year data breaches in solely public cloud deployments were the most expensive type of data breach, with an average of $5.17 million USD, a 13.1% increase from the year before.

So, as cloud usage continues to grow, the teams in charge of protecting these deployments must understand the associated cybersecurity risks.

What are cloud risks?

Cloud threats come in many forms, with one of the key types consisting of cloud risks. These arise from challenges in implementing and maintaining cloud infrastructure, which can expose the organization to potential damage, loss, and attacks.

There are three major types of cloud risks:

1. Misconfigurations

As organizations struggle with complex cloud environments, misconfiguration is one of the leading causes of cloud security incidents. These risks occur when cloud settings leave gaps between cloud security solutions and expose data and services to unauthorized access. If discovered by a threat actor, a misconfiguration can be exploited to allow infiltration, lateral movement, escalation, and damage.

With the scale and dynamism of cloud infrastructure and the complexity of hybrid and multi-cloud deployments, security teams face a major challenge in exerting the required visibility and control to identify misconfigurations before they are exploited.

Common causes of misconfiguration come from skill shortages, outdated practices, and manual workflows. For example, potential misconfigurations can occur around firewall zones, isolated file systems, and mount systems, which all require specialized skill to set up and diligent monitoring to maintain

2. Identity and Access Management (IAM) failures

IAM has only increased in importance with the rise of cloud computing and remote working. It allows security teams to control which users can and cannot access sensitive data, applications, and other resources.

Cybersecurity professionals ranked IAM skills as the second most important security skill to have, just behind general cloud and application security.

There are four parts to IAM: authentication, authorization, administration, and auditing and reporting. Within these, there are a lot of subcomponents as well, including but not limited to Single Sign-On (SSO), Two-Factor Authentication (2FA), Multi-Factor Authentication (MFA), and Role-Based Access Control (RBAC).

Security teams are faced with the challenge of allowing enough access for employees, contractors, vendors, and partners to complete their jobs while restricting enough to maintain security. They may struggle to track what users are doing across the cloud, apps, and on-premises servers.

When IAM is misconfigured, it increases the attack surface and can leave accounts with access to resources they do not need to perform their intended roles. This type of risk creates the possibility for threat actors or compromised accounts to gain access to sensitive company data and escalate privileges in cloud environments. It can also allow malicious insiders and users who accidentally violate data protection regulations to cause greater damage.

3. Cross-domain threats

The complexity of hybrid and cloud environments can be exploited by attacks that cross multiple domains, such as traditional network environments, identity systems, SaaS platforms, and cloud environments. These attacks are difficult to detect and mitigate, especially when a security posture is siloed or fragmented.  

Some attack types inherently involve multiple domains, like lateral movement and supply chain attacks, which target both on-premises and cloud networks.  

Challenges in securing against cross-domain threats often come from a lack of unified visibility. If a security team does not have unified visibility across the organization’s domains, gaps between various infrastructures and the teams that manage them can leave organizations vulnerable.

Adopting AI cybersecurity tools to reduce cloud risk

For security teams to defend against misconfigurations, IAM failures, and insecure APIs, they require a combination of enhanced visibility into cloud assets and architectures, better automation, and more advanced analytics. These capabilities can be achieved with AI-powered cybersecurity tools.

Such tools use AI and automation to help teams maintain a clear view of all their assets and activities and consistently enforce security policies.

Darktrace / CLOUD is a Cloud Detection and Response (CDR) solution that makes cloud security accessible to all security teams and SOCs by using AI to identify and correct misconfigurations and other cloud risks in public, hybrid, and multi-cloud environments.

It provides real-time, dynamic architectural modeling, which gives SecOps and DevOps teams a unified view of cloud infrastructures to enhance collaboration and reveal possible misconfigurations and other cloud risks. It continuously evaluates architecture changes and monitors real-time activity, providing audit-ready traceability and proactive risk management.

Real-time visibility into cloud assets and architectures built from network, configuration, and identity and access roles. In this unified view, Darktrace / CLOUD reveals possible misconfigurations and risk paths.
Figure 1: Real-time visibility into cloud assets and architectures built from network, configuration, and identity and access roles. In this unified view, Darktrace / CLOUD reveals possible misconfigurations and risk paths.

Darktrace / CLOUD also offers attack path modeling for the cloud. It can identify exposed assets and highlight internal attack paths to get a dynamic view of the riskiest paths across cloud environments, network environments, and between – enabling security teams to prioritize based on unique business risk and address gaps to prevent future attacks.  

Darktrace’s Self-Learning AI ensures continuous cloud resilience, helping teams move from reactive to proactive defense.

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About the author
Pallavi Singh
Product Marketing Manager, OT Security & Compliance
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