Domestic UPI Frauds: Finance Ministry Presented Data in LokSabha

Introduction

The much-awaited DPDP Rules have now finally been released in the official Gazette on 3rd January 2025 for consultation. The draft Digital Personal Data Protection Rules, 2025 (DPDP Rules) invites objections and suggestions from stakeholders that can be submitted on MyGov (https://mygov.in) by 18th February 2025.

DPDP Rules at Glance 

• Processing of Children's Data: The draft rules say that ‘A Data Fiduciary shall adopt appropriate technical and organisational measures to ensure that verifiable consent of the parent is obtained before the processing of any personal data of a child’. It entails that children below 18 will need parents' consent to create social media accounts.
• The identity of the parents and their age can be verified through reliable details of identity and age available with the Data Fiduciary, voluntarily provided identity proof or virtual token mapped to the same. The data fiduciaries are also required to observe due diligence for checking that the individual identifying themselves as the parent is an adult who is identifiable, if required, in connection with compliance with any law for the time being in force in India. Additionally, the government will also extend exemptions from these specific provisions pertaining to processing of children's data to educational institutions, and child welfare organisations.
• Processing of Personal Data Outside India: The draft rules specify that the transfer of personal data outside India, whether it is processed within the country or outside in connection with offering goods or services to individuals in India, is permitted only if the Data Fiduciary complies with the conditions prescribed by the Central Government through general or specific orders.
• Intimation of Personal Data Breach: On becoming aware of a personal data breach, the Data Fiduciary must promptly notify the affected Data Principals in a clear and concise manner through their user account or registered communication method. This notification should include a description of the breach (nature, extent, timing, and location), potential consequences for the Data Principal, measures taken or planned to mitigate risks, recommended safety actions for the Data Principal, and contact information of a representative to address queries. Additionally, the Data Fiduciary must inform the Board without delay, providing details of the breach, its likely impact, and initial findings. Within 72 hours (or a longer period allowed by the Board upon request), the Data Fiduciary must submit updated information, including the facts and circumstances of the breach, mitigation measures, findings about the cause, steps to prevent recurrence, and a report on notifications given to affected Data Principals. 
• Data Protection Board: The draft rules propose establishing the Data Protection Board, which will function as a digital office, enabling remote hearings, and will hold powers to investigate breaches, impose penalties, and perform related regulatory functions.

Journey of Digital Personal Data Protection Act, 2023

The foundation for the single statute legislation on Data Protection was laid down in 2017, in the famous ‘Puttaswami judgment,’ which is also well recognised as the Aadhar Card judgment. In this case, ‘privacy’  was recognised as intrinsic to the right to life and personal liberty, guaranteed by Article 21 of the Constitution of India, thus making ‘Right to Privacy’ a fundamental right.  In the landmark Puttaswamy ruling, the apex court of India stressed the need for a comprehensive data protection law. 

Eight years on and several draft bills later, the Union Cabinet approved the Digital Personal Data Protection Bill (DPDP) on 5th July 2023. The bill was tabled in the Lok Sabha on 3rd August 2023, and It was passed by Lok Sabha on 7th August, and the bill passed by Rajya Sabha on 9th August and got the president's assent on 11th August 2023; and India finally came up with the ‘Digital Personal Data Protection Act, 2023. This is a significant development that has the potential to bring about major improvements to online privacy and the handling of digital personal data by the platforms.

The Digital Personal Data Protection Act, 2023, is a newly-enacted legislation designed to protect individuals' digital personal data. It aims to ensure compliance by Data Fiduciaries and imposes specific obligations on both Data Principals and Data Fiduciaries. The Act promotes consent-based data collection practices and establishes the Data Protection Board to oversee compliance and address grievances. Additionally, it includes provisions for penalties of up to ₹250 crores in the event of a data breach. However, despite the DPDP Act being passed by parliament last year, the Act has not yet taken effect since its rules and regulations are still not finalised.

Conclusion

It is heartening to see that the Ministry of Electronics and Technology (MeitY) has finally released the draft of the much-awaited DPDP rules for consultation from stakeholders. Though noting certain positive aspects, there is still room for addressing certain gaps and multiple aspects under the draft rules that require attention. The public consultation, including the inputs from the tech platforms, is likely to see critical inputs on multiple aspects under the proposed rules. One such key area of interest will be the requirement of verifiable parental consent, which will likely include recommendations for a balanced approach which maintains children’s safety and mechanisms for the requirement of verifiable consent. The Provisions permitting government access to personal data on grounds of national security are also expected to face scrutiny. The proposed rules, after the consultation process, will be taken into consideration for finalisation after 18th February 2025.  The move towards establishing a robust data protection law in India signals a significant step toward enhancing trust and accountability in the digital ecosystem. However, its success will hinge on effective implementation, clear compliance mechanisms, and the adaptability of stakeholders to this evolving regulatory landscape.

References

• Draft DPDP Rules; https://egazette.gov.in/(S(rszckzjqxkns41cjzagebonx))/ViewPDF.aspx
• DPDP Act 2023; https://www.meity.gov.in/writereaddata/files/Digital%20Personal%20Data%20Protection%20Act%202023.pdf

Introduction

Recently the attackers employed the CVE-2017-0199 vulnerability in Microsoft Office to deliver a fileless form of the Remcos RAT. The Remcos RAT makes the attacker have full control of the systems that have been infected by this malware. This research will give a detailed technical description of the identified vulnerability, attack vector, and tactics together with the practical steps to counter the identified risks.

The Targeted Malware: Remcos RAT

Remcos RAT (Remote Control & Surveillance) is a commercially available remote access tool designed for legitimate administrative use. However, it has been widely adopted by cybercriminals for its stealth and extensive control capabilities, enabling:

• System control and monitoring
• Keylogging
• Data exfiltration
• Execution of arbitrary commands

The fileless variant utilised in this campaign makes detection even more challenging by running entirely in system memory, leaving minimal forensic traces.

Attack Vector: Phishing with Malicious Excel Attachments

The phishing email will be sent which appears as legitimate business communication, such as a purchase order or invoice. This email contains an Excel attachment that is weaponized to exploit the CVE-2017-0199 vulnerability.

Technical Analysis: CVE-2017-0199 Exploitation

Vulnerability Assessment

• CVE-2017-0199 is a Remote Code Execution (RCE) vulnerability in Microsoft Office which uses Object Linking and Embedding (OLE) objects.
• Affected Components:some text
  • Microsoft Word
  • Microsoft Excel
  • WordPad
• CVSS Score: 7.8 (High Severity)

Mechanism of Exploitation

The vulnerability enables attackers to craft a malicious document when opened, it fetches and executes an external payload via an HTML Application (HTA) file. The execution process occurs without requiring user interaction beyond opening the document.

Detailed Exploitation Steps

1. Phishing Email and Malicious Document some text
   • The email contains an Excel file designed to make use of CVE-2017-0199.
   • When the email gets opened, the document automatically connects to a remote server (e.g., 192.3.220[.]22) to download an HTA file (cookienetbookinetcache.hta).
2. Execution via mshta.exe some text
   • The downloaded HTA file is executed using mshta.exe, a legitimate Windows process for running HTML Applications.
   • This execution is seamless and does not prompt the user, making the attack stealthy.
3. Multi-Layer Obfuscation some text
   • The HTA file is wrapped in several layers of scripting, including: some text
     • JavaScript
     • VBScript
     • PowerShell
   • This obfuscation helps evade static analysis by traditional antivirus solutions.
4. Fileless Payload Deployment some text
   • The downloaded executable leverages process hollowing to inject malicious code into legitimate system processes.
   • The Remcos RAT payload is loaded directly into memory, avoiding the creation of files on disk.

Fileless Malware Techniques

1. Process Hollowing
The attack replaces the memory of a legitimate process (e.g., explorer.exe) with the malicious Remcos RAT payload. This allows the malware to:

• Evade detection by blending into normal system activity.
• Run with the privileges of the hijacked process.

2. Anti-Analysis Techniques

• Anti-Debugging: Detects the presence of debugging tools and terminates malicious processes if found.
• Anti-VM and Sandbox Evasion: Ensures execution only on real systems to avoid detection during security analysis.

3. In-Memory Execution

• By running entirely in system memory, the malware avoids leaving artifacts on the disk, making forensic analysis and detection more challenging.

Capabilities of Remcos RAT

Once deployed, Remcos RAT provides attackers with a comprehensive suite of functionalities, including:

• Data Exfiltration: some text
  • Stealing system information, files, and credentials.
• Remote Execution: some text
  • Running arbitrary commands, scripts, and additional payloads.
• Surveillance: some text
  • Enabling the camera and microphone.
  • Capturing screen activity and clipboard contents.
• System Manipulation: some text
  • Modifying Windows Registry entries.
  • Controlling system services and processes.
  • Disabling user input devices (keyboard and mouse).

Advanced Phishing Techniques in Parallel Campaigns

1. DocuSign Abuse
Attackers exploit legitimate DocuSign APIs to create authentic-looking phishing invoices. These invoices can trick users into authorising payments or signing malicious documents, bypassing traditional email security systems.

2. ZIP File Concatenation
By appending multiple ZIP archives into a single file, attackers exploit inconsistencies in how different tools handle these files. This allows them to embed malware that evades detection by certain archive managers.

Broader Implications of Fileless Malware

Fileless malware like Remcos RAT poses significant challenges:

• Detection Difficulties: Traditional signature-based antivirus systems struggle to detect fileless malware, as there are no static files to scan.
• Forensic Limitations: The lack of disk artifacts complicates post-incident analysis, making it harder to trace the attack's origin and scope.
• Increased Sophistication: These campaigns demonstrate the growing technical prowess of cybercriminals, leveraging legitimate tools and services for malicious purposes.

Mitigation Strategies

1. Patch Management some text
   • It is important to regularly update software to address known vulnerabilities like CVE-2017-0199. Microsoft released a patch for this vulnerability in April 2017.
2. Advanced Email Security some text
   • It is important to implement email filtering solutions that can detect phishing attempts, even those using legitimate services like DocuSign.
3. Endpoint Detection and Response (EDR)some text
   • Always use EDR solutions to monitor for suspicious behavior, such as unauthorized use of mshta.exe or process hollowing.
4. User Awareness and Training some text
   • Educate users about phishing techniques and the risks of opening unexpected attachments.
5. Behavioral Analysis some text
   • Deploy security solutions capable of detecting anomalous activity, even if no malicious files are present.

Conclusion

The attack via CVE-2017-0199 further led to the injection of a new fileless variant of Remcos RAT, proving how threats are getting more and more sophisticated. Thanks to the improved obfuscation and the lack of files, the attackers eliminate all traditional antiviral protection and gain full control over the infected computers. It is real and organisations have to make sure that they apply patches on time, that they build better technologies for detection and that the users themselves are more wary of the threats.

References

• Fortinet FortiGuard Labs: Analysis by Xiaopeng Zhang
• Perception Point: Research on ZIP File Concatenation
• Wallarm: DocuSign Phishing Analysis
• Microsoft Security Advisory: CVE-2017-0199

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Introduction

The Central Electricity Authority (CEA) has released the Draft Central Electricity Authority (Cyber Security in Power Sector) Regulations, 2024, inviting ‘comments’ from stakeholders, including the general public, which are to be submitted by 10 September 2024. The new regulation is intended to make India’s power sector more cyber-resilient and responsive to counter emerging cyber threats and safeguard the nation's power infrastructure.

Key Highlights of the CEA’s New (Cyber Security in Power Sector) Regulations, 2024

• Central Electricity Authority has framed the ‘Cyber Security in Power Sector Regulations, 2024’ in the exercise of the powers conferred by sub-section (1) of 177 of the Electricity Act, 2003 in order to make regulations for measures relating to Cyber Security in the power sector.
• The scope of the regulation entails that these regulations will be applicable to all Responsible Entities, Regional Power Committees, Appropriate Commission, Appropriate Government and Associated Power Sector Government Organizations, and Training Institutes recognized by the Authority, Authority and Vendors.
• One key aspect of the proposed regulation is the establishment of a dedicated Computer Security Incident Response Team (CSIRT) for the power sector. This team will coordinate a unified cyber defense strategy throughout the sector, establishing security frameworks, and serving as the main agency for handling incident response and recovery. The CSIRT will also be responsible for creating/developing Standard Operating Procedures (SOPs), security policies, and best practices for incident response activities in consultation with CERT-In and NCIIPC. The detailed roles and responsibilities of CSIRT are outlined under Chapter 2 of the said regulations.
• All responsible entities in the power sector as mentioned under the scope of the regulation, are mandated to appoint a Chief Information Security Officer (CISO) and an alternate CISO, who need to be Indian nationals and who are senior management employees. The regulations specify that these officers must directly report to the  CEO/Head of the Responsible Entity. Thus emphasizing the critical nature of CISO’s roles in safeguarding the nation’s power grid sector assets.
• All Responsible Entities shall establish an Information Security Division (ISD) dedicated to ensuring Cyber Security, headed by the CISO and remain operational around the clock. The schedule under regulation entails that the minimum workforce required for setting up an ISD is 04 (Four) officers including CISO and 04 officers/officials for shift operations. Sufficient workforce and infrastructure support shall be ensured for ISD. The detailed functions and responsibilities of ISD are outlined under Chapter 5 regulation 10. Furthermore, the ISD shall be manned by sufficient numbers of officers, having valid certificates of successful completion of domain-specific Cyber Security courses.
• The regulation obliged the entities to have a defined, documented and maintained Cyber Security Policy which is approved by the Board or Head of the entity. The regulation also obliged the entities to have a Cyber Crisis Management Plan (CCMP) approved by the higher management.
• As regards upskilling and empowerment the regulation advocates for organising or conducting periodic Cyber Security awareness programs and Cyber Security exercises including mock drills and tabletop exercises.

CyberPeace Policy Outlook

CyberPeace Policy & Advocacy Vertical has submitted its detailed recommendations on the proposed ‘Cyber Security in Power Sector Regulations, 2024’ to the Central Electricity Authority, Government of India. We have advised on various aspects within the regulation including harmonisation of these regulations with other rules as issued by CERT-In and NCIIPC, at present. As this needs to be clarified which set of guidelines will supersede in case of any discrepancy that may arise. Additionally, we advised on incorporating or making modifications to specific provisions under the regulation for a more robust framework. We have also emphasized legal mandates and penalties for non-compliance with cybersecurity, so as to make sure that these regulations do not only act as guiding principles but also provide stringent measures in case of non-compliance.

References: 

1. https://cea.nic.in/wp-content/uploads/notification/2024/08/Draft_CEA_Cyber_Security_in_Power_Sectyor_Regulations_2024_English_Version.pdf

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