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Threats Unmasked

2021 Cyber Threat


Intelligence Report
Foreword
Accenture Cyber Threat Intelligence (Accenture CTI) has been creating
relevant, actionable threat intelligence for more than 20 years. But the
rapid pace of cyber threat evolution means that intelligence needs to
be timely to be relevant. As a result, we are changing our annual Cyber
Threatscape report to a more frequent review, to help decision makers
plan and act faster.
In this inaugural issue we highlight early The SolarWinds and Colonial Pipeline
2021 cyber threat trends and expert incidents and the large-scale disruptions and
perspectives on threats to the operational cost of ransomware operations, illustrate the
technology (OT) landscape. In an era growing impact of cyber threat activity on
of unprecedented uncertainty, with so enterprise risk across all industry segments.
many devices scattered throughout This risk is increasingly difficult to control and
enterprise networks, it’s challenging mitigate across both IT and OT environments.
for security professionals to keep pace
with security demands.

2021 Cyber Threat Intelligence Report 2


While running industrial The global ransomware crisis has Enterprise risk management is a team
entered a new phase, as threat actors sport that requires a variety of capabilities,
systems is eased by adopt stronger pressure tactics and new a cohesive team, excellent execution
virtualization in the targets—in particular, manufacturing and of the basics and a willingness to adapt
critical infrastructure. Ransom impact to changing conditions.
cloud and the advance of is more widespread, with attacks often
Security leaders must demonstrate to the
Internet-connected devices, highlighting weaknesses in a company’s
security posture. Yet, despite Colonial C-suite and the board not only that they
these technologies are also Pipeline’s recent admission of a US$4.4M understand the criticality of the continuity
payout,1 victims cannot assume paying of operations, but also the importance
introducing operational a ransom will restore data or prevent of working in partnership with the whole
environments to new leaks2 and it seems they recognize that— business to effectively manage risk.
median ransom payments have fallen
vulnerabilities and risks. from US$110,532 in September 2020
For more, take a look at our larger security
library through our Threat Intelligence,
to US$$78,398 in March 2021.3
Cyber Defense, and OT Security blogs
As we have seen with the SolarWinds and our recent Operation: Next
compromise, software supply chain OT security summit.
security and third-party compromise
vectors are in the spotlight. More generally,
ransomware deployment is faster and more
Howard Marshall
diverse, making pre-infection defense Howard Marshall
extremely difficult. Managing Director, Accenture Security

2021 Cyber Threat Intelligence Report 3


Key trends
Following analysis in the first half of 2021, Accenture CTI
identified four trends that are affecting the IT and OT landscape:

1 2 3 4

Ransomware actors test Cobalt Strike is on the rise Commodity malware can Dark Web actors challenge
new extortion methods invade OT from IT space IT and OT networks

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Ransomware
actors test new
extortion methods
Ransomware actors are expanding data leak extortion,
devising new methods to pressure victims.4 Their creative
approaches are hitting home as they place operational
resilience—already tested by the disruptive forces of
the pandemic—under increased pressure.

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Threat actors are targeting new What’s happening?
industries, using higher-pressure
tactics to escalate infection Targets are shifting Tactics are toughening
consequences and deploying Small manufacturers remain typical targets,5 Ransomware actors generally promise
payloads faster to render but cases in the first months of 2021 targeted to decrypt their victims’ systems and
trusted detection methods critical infrastructure—the May 2021 Colonial destroy stolen data after receiving
too slow. Response options are Pipeline ransomware paralyzed fuel distribution ransoms,8 but these promises are unreliable.
becoming more complicated. in much of the southeastern United States— Ransomware negotiator Coveware reported
and upstream providers, such as data-rich multiple cases in late 2020 where data
Organizations should focus insurance companies.6 Ransomware operators was destroyed rather than just encrypted,
on preparation, prevention disrupt production in organizations that preventing data retrieval even after ransom
and pre-encryption defenses. cannot afford downtime and feel pressure payment.9 But, one group extorted their
to pay ransoms. One group exploited victims and posted stolen data without
a cloud provider’s product to breach even deploying ransomware—apparently
legal, transportation, geophysical and viewing exposure as more intimidating
logistics entities.7 to its victim than “bricking” machines.10

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Where next?
Extortion is becoming personal stolen victim data with anti-establishment To help tackle the impact of ransomware:
New exposure tactics, pioneered in 2020, activist communities.21 After the fallout
have gathered speed, compounding data leak from the Colonial Pipeline hack led major • Nip attacks in the bud: Organizations
extortion damage, adding reputation damage underground forum administrators to focusing on preparation, prevention,
to victim liability lists. In what one report ban talk of ransomware, Babuk announced and pre-encryption defense can more
has dubbed “quadruple extortion,” groups a new platform where anyone can publish effectively face the ransomware crisis.25 26
are not only encrypting files and threatening to their stolen data.22 Segregation and zero-trust measures
leak data, but also threatening non-payers with can limit threat actor movements
distributed denial-of-service (DDoS) attacks11 12 13 Tactics, Techniques, and Procedures if breaches occur.
or contacting victims’ customers or business (TTPs) are more advanced
Ransomware actors are developing new • Collaborate and report:
partners, urging them to pressure victims
tools and exploits rapidly. Actors exploit Collaborate with industry partners,
to pay ransoms.14 15 16 17 DarkSide, the group
new vulnerabilities—for example, alternative consortiums and law enforcement
whose ransomware the FBI has said was
delivery mechanisms such as third-party for greater threat awareness.
responsible for the Colonial attack,18 is one
of the first to offer all four services as part hosting;23 Accenture CTI identified notable
• Update risk and mitigation plans:
of its affiliate service.19 Clop actors focused defense evasion tactics with Hades
Apply an appropriate risk mitigation
on top executives’ information, seeking ransomware operators using tooling
strategy that includes aspects such
blackmail material.20 Babuk ransomware and hands-on-keyboard actions to
as controls deployment or secure
operators have joined Clop and Snatch disable endpoint defenses.24
data transmission mechanisms.
actors in gaining broader exposure for their

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Cobalt Strike
is on the rise
Testing services have proven themselves as
an effective way to assess systems, enabling
organizations to address and mitigate risk to
their critical production environment. So, it is
unsurprising that threat actors continuously
seek cost-efficient ways to evade detection
and complicate attribution. One of these ways
is to integrate open source and commercial
tools into their arsenal.

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Since at least December 2020, Accenture The framework’s “Beacon” backdoor What’s happening?
CTI has observed, from internal research contains commercial watermarks,
and public reporting,27 a notable increase which enable analysts to monitor Cobalt Strike is proliferating
in threat actors adopting pirated versions campaigns and target trends about Although in use for more than a decade,
of the commercial penetration testing locations of cracked or pirated Cobalt the number of Cobalt Strike-enabled
framework Cobalt Strike. Strike deployments. attacks reportedly increased by 163%
between 2019 and 2020.29 The emergence
This pirated software has enabled Public discussions around the prolific of pirated Cobalt Strike being abused
highly impactful campaigns, including success of a malicious tool can often as a preeminent commodity alternative to
the recently discovered SolarWinds-based result in the development of new malware has occurred for numerous reasons.
compromises, as well as prolific security detection techniques, leading
“name-and-shame” ransomware attacks. threat actors to retool. However, due to In addition to being increasingly
numerous factors such as increased accessible, recent Cobalt Strike versions
Accenture CTI invests significant customization, the current high profile are more customizable than previous
resources in tooling that identifies, success of Cobalt Strike abuse means versions. As Accenture CTI observed
decrypts and tracks Cobalt Strike the pirated tool’s popularity is actually in the recent SolarWinds breach,30 threat
configurations in the wild.28 growing—a trend that will almost actors are exploiting Cobalt Strike’s malleable
certainly continue through 2021. command-and-control features to customize
default settings of the framework’s Beacon
backdoor and defeat detection.

Organizations need to adopt new defensive


tools that can counter this growing threat.

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Where next?
Attack tools are evolving the newly identified cyber espionage To help tackle the impact of threats
Threat actors are evolving their own group HAFNIUM.33 HAFNIUM reportedly to testing frameworks:
custom loaders to deliver Cobalt Strike. used zero-day exploits against critical
Notably, attackers developed several Microsoft Exchange vulnerabilities, which • Undertake network analysis: Monitor for
custom Cobalt Strike loaders to facilitate Microsoft publicly disclosed in March 2021.34 discovered Beacon watermarks in Cobalt
the SolarWinds campaign.31 Accenture CTI Strike samples to find and understand
has seen the popularity of the tool surge Malware is merging emerging Cobalt Strike campaigns and
in the first three months of 2021. Accenture CTI has identified overlaps better defend against trending TTPs.
between the infrastructure of the
Beyond the intensifying use of Cobalt Strike by information-stealing malware EvilGrab and • Get familiar with Cobalt Strike
opportunistic “name and shame” ransomware Cobalt Strike Beacon in early 2021 activity.35 activity: Learn how past experiences
groups such as REvil (also known as Sodinokibi) There is a realistic possibility the observed can help to tackle the threat.
and Egregor, Hades ransomware operators overlaps between EvilGrab and Cobalt Strike
• Strengthen your defense posture:
have also abused the tool to deploy their are precursors for sophisticated groups that
Employ new defense tools to keep
ransomware.32 These ransomware attacks have used EvilGrab in the past adopting
pace with evolving challenges.
affected multiple victims between Cobalt Strike against new target sets in
December 2020 and March 2021. the remainder of 2021.

Accenture CTI also observed a Cobalt Strike


Beacon-type payload in malware hosted
on infrastructure, likely associated with

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Commodity
malware can invade
OT from IT space
Commodity malware, perhaps better termed “high-volume
crimeware,” presents a unique and universal challenge due to
its availability and scale. It is a danger at the endpoint, enabling
further intrusions within a victim network and can threaten
both IT and OT systems.

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QakBot, IcedID, DoppelDridex, and What’s happening?
Hancitor are examples of commodity
malware threats active in February First-stage commodity malware is The embedded malicious macros from
and March 2021. Accenture CTI’s a notable threat because it enables the the Excel documents download crimeware
underground reconnaissance team deployment of further malware at the from URLs with paths that end with “[0-9]
has seldom, if ever, seen threat endpoint. Threat actors’ use of follow-on {5},[0-9]{9,10}.dat.” In a sample activity set,
actors sell these malware types on commodity malware or tools, such as Accenture CTI analysts saw the download
the Dark Web because relevant threat pirated and abused Cobalt Strike instances, of both Qakbot and IcedID payloads during
actors hold onto the malware closely, increases the risk of an infection spreading these campaigns. A high percentage of the
reducing opportunities to identify throughout an organization’s infrastructure payloads were Qakbot, an enduring malware
spam campaigns early. and even to OT assets. that dates back to 2007 that can act as
a backdoor. The IcedID Gziploader DLL
Organizations need to Here are some of the active malware sends information from the victim system
campaigns observed by Accenture CTI:
consider prevention, rather to its C2 server along with the IcedID HTTP
than response, as the most cookie parameters “__gads” and “_gat”,
Qakbot and IcedID
and the C2 server sends back the IcedID
effective defense against According to Accenture CTI research,
main payload, which is a banking Trojan
commodity malware threats. in March 2021, threat actors used
that also acts as a downloader to deploy
large-volume spam campaigns to deliver
follow-on malware.36
crimeware via compressed Excel documents.

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Where next?
DoppelDridex Hancitor To help tackle the impact of commodity
A noteworthy spam campaign in March 2021 In February and March 2021, spam campaigns malware in OT environments:
lured users with an e-mail that appeared delivered the commodity malware Hancitor.
to be from intuit[.]com. E-mails from this Actors spread Hancitor via e-mails with • Patch endpoint systems, firewall
campaign have included subjects like a DocuSign order theme and links to Google potential infection vectors, update anti-
“Invoice/Sales Receipt” and “Purchase Order Docs URLs hosting malicious Microsoft Word virus software, keep offline or air-gapped
Receipt” and attachments with names like documents. The Word documents dropped backups and use application whitelists.
“Payment_Receipt [number].xls.” The malicious an embedded Hancitor DLL to victim systems.
• Conduct regular phishing awareness
Excel attachment contains two hidden sheets Hancitor contacts the C2 domain api.ipify[.]org
programs for all staff, segment
with invisible strings in cell A15. Upon execution, to report the target machine’s external IP
Active Directory domains by
a macro decodes multiple URLs, downloads address, contact its C2 at URLs using the
function or criticality and maintain
the DoppelDridex loader from the URLs path “/8/forum.php,” and download Ficker
a principle of least privilege for
and executes it via the Windows regsvr32 Stealer from .ru domains. Hancitor may
each user group and account.
process; then the loader drops the embedded also deliver the Cobalt Strike malware if
DoppelDridex malware into memory and the victim system has a Microsoft Active • Remove or disable commonly abused
executes it.37 Threat actors that split from Directory environment.39 Hancitor activity and non-essential services, if appropriate.
the group responsible for Bitpaymer is connected to the threat group MAN1,
and Dridex allegedly originated the a criminal enterprise that Accenture CTI
DoppelDridex malware.38 has linked to the Dyre banking malware.40

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Dark Web actors
challenge IT and
OT networks
Dark Web activities, including enablement of CLOP
and Hades ransomware actors, information stealers
and digital fingerprints in the underground Genesis
Market, reflected noteworthy challenges to both IT
and OT networks in early 2021.

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Dark Web activities, including What’s happening?
enablement of CLOP and Hades
ransomware, information stealers and CLOP and Hades ransomware actors are changing the game
fingerprints in the underground Genesis
Market, reflected noteworthy challenges Public reporting in early 2021 tied CLOP this skillset could threaten OT networks.48
to both IT and OT networks in early 2021. ransomware actors to a series of global data Given the EDR bypass, Accenture CTI
breaches exploiting a recently discovered considers Hades ransomware actors the
As threat actors congregate in Dark Web vulnerability in the widely used Accellion File latest gang threatening both IT and OT
forums to share and trade tools, TTPs Transfer Appliance (FTA).41 After a review of the networks. Operators’ schemes now
and victim data, they are increasing timeline of Accellion FTA compromises, CLOP encompass capturing and encrypting
their pressure tactics, learning how to name-and-shame releases on the Dark Web, company data and traversing IT
bypass security protections and finding victim disclosures and insights from Accenture networks to OT networks.
new ways to monetize malware logs. incident response efforts, Accenture CTI
agrees that CLOP ransomware actors likely Ransomware operators rarely succeed
Organizations need to share teamed up with the actors responsible for when they try to compromise OT networks,
but may not even need to do so to achieve
information among defenders exploiting the Accellion FTA vulnerability.42 43 44 45
Profitability and managing victims at scale their objectives. In both a February 2021
to understand, prevent, identify attack on boat builder Beneteau and the
could result in escalation and copycats over
and respond to threat activity. May 2021 Colonial Pipeline attack, the mere
the course of the year.
presence of actors within the IT network
Hades ransomware actors also gained traction forced preventive OT shutdowns and
in early 2021 and demonstrated their ability short-term effects comparable to an OT
to bypass Endpoint Detection and Response infection. OT shutdowns, even if preventive,
(EDR) tools46 and reach edge devices.47 may become more common in future attacks
Hades actors manually disabled or used against OT-dependent organizations.49 50
custom tools to evade defenses and
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Information is easy to buy and even easier to use

Since the beginning of 2021, Accenture CTI A threat actor can use malware logs to Accenture CTI considers the malware logs that
observed a slight but noticeable increase masquerade as a legitimate network user Dark Web actors sell in Genesis Market to pose
in threat actors selling malware logs, which and avoid detection, gaining initial access a particularly serious threat to organizations’ IT
constitute data derived from information to a victim system by using valid credentials. and OT assets. Genesis Market has drastically
stealer malware.51 Information stealers Threat actors often use malware logs to access lowered barriers to entry for malware log
can collect and log a wide range of sensitive an organization’s Web resources and attempt exploitation by compiling and selling malware
system, user and business information, to access privileged administrator accounts logs in a format Genesis ads dub “bots”
such as the following: on an organization’s webservers. In some or a “plug-ins.” Even less technically savvy
cases, they may try to access computers threat actors can intuitively use a plug-in
• System information on a victim’s network via services like RDP with Genesis’ freely available Web browser.
• Web browser bookmarks or SSH. A common alternative action is for
threat actors to sell malware logs directly
• Web session cookies
to hackers, or to sell them in bulk to
• Login credentials (websites, “malware log” Dark Web marketplaces,
Remote Desktop Protocol (RDP), such as Genesis Market or Russian Market.
Secure Shell Protocol (SSH))
• Payment card data
• Cryptocurrency wallet addresses

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Where next?
To help tackle the impact of the Dark Web on OT networks:

• Undertake responsible monitoring: • Increase intelligence sharing • Prepare a continuity of operations plan:
Seek early warning of potential of incident response analysis: Anticipate and develop contingency
unauthorized access through Share information to identify threat plans for a potential theft of administrator
responsible Dark Web monitoring, signatures and attribution, plan and credentials, a bypass of Endpoint
whether directly or through a cyber execute defense and response and Detection and Response systems
threat intelligence provider. prepare network defense and business and physical shutdowns (either as
operations for future threat activity. preventive or reactive measures),
to prepare network and business
operations for the future occurrence
of a ransomware or similar event.

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Spotlight: On the edge of security
Edge devices such as Internet of Things (IoT) objects, switches and routers operate at the
boundary of a network to control data flowing in and out of the organization. At the border
between IT and OT environments, they are critical to OT security—breaches can mean
direct access into OT environments, completely bypassing IT networks.

But low rates of network monitoring52 security policies are consistent with Stringent edge device policies may
make it difficult for OT incident responders National Institute for Standards and encourage organizations to allocate
to identify attack vectors and causes of Technology (NIST) recommendations.54 funds from many parts of the business
intrusion—and unable to advise on how The law promises greater security for edge to bolster security efforts. With investment
to secure OT systems. As a result, securing devices and addresses some longstanding in the right places, security leads can
edge devices has become as important challenges. On May 12, 2021, President Biden secure edge devices in OT environments
as securing ICS themselves. signed the Executive Order on Improving through a combination of monitoring,
the Nation’s Cybersecurity which includes response and intelligence.
Policy matters. On December 4, 2020, direction to create pilot cybersecurity
former President Trump signed the Internet labelling programs to educate the public
of Things Cybersecurity Improvement Act on security capabilities of IoT devices
of 2020.53 The act encourages government and software development practices.55
agencies to work collaboratively so that IoT

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Targeting edge devices
In February 2021, Accenture CTI discovered Financially motivated cyber criminals have
a threat actor advertising Citrix VPN access to used VPN access to launch a ransomware
a “large resources corporation” on a reputable attack and may target OT systems—they
Russian-language forum specializing in know manufacturers and other users of ICS
malware and ransomware.56 Citrix is a VPN are especially vulnerable to downtime and
gateway commonly placed at OT boundaries may be more likely to pay ransoms to get
to connect and correlate various Internet their systems back online.
protocols from different networks.
Meanwhile, cyber espionage threat actors
Threat actors often access vulnerable may use VPN access to get onto OT networks
networks and systems such as Citrix by to steal data or hide with the intention of
exploiting known vulnerabilities that are issuing a destructive attack later. Both
unpatched or that vendors are in the process threat actor types can access edge devices,
of patching. In late 2019, the still-active threat which could lead to the disruption of critical
campaign known as Fox Kitten (also known business operations and loss of revenue.
as UNC757)57 accessed companies in various
industries, including the energy industry,
via VPN n-day exploits.58

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Defend the edge
Here are some familiar security capabilities and traverse into an OT environment Cyber threat intelligence offers improved
organizations can use to increase their enables an entity to secure its IT and OT visibility into overall network threats and
edge device security: boundaries. Data from OT IR engagements informs decision makers how to prioritize
can also help inform red teaming exercises security around potential targets and threats.
OT Security Operations Center (SOC) to identify edge vulnerabilities before
Unlike a traditional SOC that focuses primarily an edge breach occurs. OT IR is a key As edge device vulnerabilities and targeting
on IT assets, an OT SOC monitors security component of security in the context are on the rise, it is critical for organizations
events in both the IT and OT environments of OT and IT convergence, as well as to start changing their security cultures
for visibility of threats and risks. Monitoring operational security as a whole. from being reactive to adopting a proactive
edge devices on the boundary of an OT approach to security “on the edge.”
environment is a key component of overall Cyber Threat Intelligence (CTI)
cybersecurity and cyber resiliency. An OT Traditional cyber threat intelligence provides
SOC coupled with managed detection and information on threat actors targeting IT or
response (MDR) can help defend against OT, but often only addresses edge device
cyber threats and reduce exposure to them.59 security during the deployment of highly
specialized systems. Accenture CTI takes OT
OT Incident Response (IR) security a step further with key vulnerability
OT IR is essential in uncovering how threat intelligence and monitors major edge
actors access OT environments via edge devices, their vendors and their version
devices if a breach occurs. Insight into numbers to make clients aware of threats
how threat actors access edge devices to IT, OT and cloud environments.

2021 Cyber Threat Intelligence Report 20


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38. Stone-Gross, Brett; Frankoff, Sergei; and Hartley, Bex, 48. Accenture Cyber Threat Intelligence, “Hades Ransomware February 16, 2020.
“BitPaymer Source Code Fork: Meet DoppelPaymer Affects Large Corporate Networks from December 2020 to
Ransomware and Dridex 2.0,” July 12, 2019. March 2021,” April 9, 2021. IntelGraph reporting. 59. “Managed Security,” Accenture, accessed April 4, 2020.

2021 Cyber Threat Intelligence Report 22


Contacts
Joshua Ray Howard Marshall Jayson Jean
Managing Director Managing Director Senior Manager
Accenture Security Accenture Security Accenture Security

Josh Ray is Managing Director for Cyber Defense across Howard Marshall is Managing Director for Accenture Cyber Jayson Jean is Director of Business Operations for
Accenture globally. Josh has more than 20 years of combined Threat Intelligence (CTI) and leads the business globally. Accenture CTI in North America and the Asia Pacific
commercial, government and military experience in the Prior to joining, Howard was FBI Deputy Assistant Director region, with responsibility for business development of
field of cyber intelligence, threat operations and information of the Cyber Readiness, Outreach and Intelligence Branch. the Cyber Threat Intelligence portfolio. Prior to this role,
security. He holds a Bachelor of Science degree in information He holds a Bachelor of Arts degree in Political Science and Jayson has 14 years of experience building the strategic
technology from George Mason University, an Executive a Juris Doctorate from the University of Arkansas. direction and leading product development for vulnerability
Certificate in strategy and innovation from MIT Sloan School management at Accenture CTI.
of Management and served honorably as a member of
the United States Navy.

Christopher Foster Valentino De Sousa Contributors


Senior Principal Senior Principal
Patton Adams, Will Archer, Adam Bumgarner,
Security Innovation Security Innovation Bianca Forbes, Roya Gordon, Hannaire Mekaouar,
Nellie Ohr, Max Smith, Nancy Strutt.
Chris Foster is Director of Product Strategy for Accenture Valentino De Sousa leads Accenture Cyber Threat Intelligence
Cyber Threat Intelligence. Chris has more than 18 years of in Europe. He is a member of the ENISA Ad-Hoc Working Group
combined experience in the field of threat intelligence serving on Cyber Threat Landscapes. Previous roles include leading
public and private sector organizations to include Booz Allen different threat intelligence teams responsible for malware
Hamilton, Chevron, United States Department of Defense and analysis, research and development, analysis of adversaries,
United States Department of Homeland Security. He holds active campaigns and leading indicators of impeding attacks.
a Bachelors from Vanderbilt University and an MBA from the He holds a Bachelor of Science in business administration
McCombs School of Business, University of Texas at Austin. from the American University of Rome and a Master of Science
in terrorism studies from the University of East London.

2021 Cyber Threat Intelligence Report 23


About Accenture About Accenture Security
Accenture is a global professional services company with leading Accenture Security is a leading provider of end-to-end cybersecurity
capabilities in digital, cloud and security. Combining unmatched services, including advanced cyber defense, applied cybersecurity
experience and specialized skills across more than 40 industries, solutions and managed security operations. We bring security
we offer Strategy and Consulting, Interactive, Technology and innovation, coupled with global scale and a worldwide delivery
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Our 569,000 people deliver on the promise of technology and professionals, we enable clients to innovate safely, build cyber
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We embrace the power of change to create value and shared success on Twitter or visit us at www.accenture.com/security
for our clients, people, shareholders, partners and communities.
Visit us at www.accenture.com

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No sponsorship, endorsement or approval of this content by the owners of such marks is intended, expressed or implied.

This content is provided for general information purposes and is not intended to be used in place of consultation with our professional advisors.

Given the inherent nature of threat intelligence, the content contained in this report is based on information gathered and understood at the time of its creation.
The information in this report is general in nature and does not take into account the specific needs of your IT ecosystem and network, which may vary and require unique
action. As such, Accenture provides the information and content on an “as-is” basis without representation or warranty and accepts no liability for any action or failure to
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