The modern compliance landscape is about protecting against ongoing attacks, and APTs are the big bad of this mission. A new APT, Scattered Spider, has quickly become one of the most high-profile threat actors in modern cybersecurity, specifically because it’s using APT tactics while flipping the script on how they work.
This group offers a wake-up call: even the most security-conscious organizations are still dangerously reliant on outdated assumptions about trust, identity, and vendor access. It’s up to you and your compliance partners to understand these threats and how to adapt.
Who Is Scattered Spider?
Scattered Spider (also known as UNC3944 or Octo Tempest) is a financially motivated, English-speaking cybercriminal group that has targeted enterprises across telecom, insurance, aviation, retail, and IT services. Unlike traditional ransomware gangs, which rely heavily on malware and phishing, Scattered Spider weaponizes social engineering, helpdesk impersonation, and cloud identity exploitation.
Scattered Spider as an Advanced Persistent Threat (APT)
Scattered Spider is increasingly being recognized as an Advanced Persistent Threat (APT). An APT is often associated with state-sponsored cyber terrorism, which gains unauthorized access to systems and remains undetected for extended periods. Their goal is usually not immediate disruption, but long-term access, surveillance, data theft, and eventual extortion.
Some of the unique attributes of an ATP that we see in Scattered Spider include:
- Persistence: APTs embed themselves deeply into systems, often using legitimate credentials and access routes.
- Adaptability: They evolve their techniques in response to defenses, making them hard to evict.
- Long-Term Strategies: APTs can remain in systems for months, collecting intelligence or laying groundwork for larger attacks.
The rise of Scattered Spider reflects cyberscrime as an enterprise, with the complexity of any modern organization. As attack surfaces expand and digital supply chains become more complex, APTs exploit the seams, especially where trust is assumed.
Perhaps the most important lesson we learn here is that Scattered Spider’s approach is more about access abuse than technical exploitation. We’ve long recognized that people are often the weakest link in a cybersecurity plan, and Scattered Spider capitalizes on this with a people-focused attack strategy. That makes them effective in environments that rely heavily on SaaS, cloud infrastructure, and distributed support teams.
Their attacks often include:
- Helpdesk social engineering: Calling in as an employee, requesting MFA reset or new device enrollment, and providing convincing personal identifiers.
- SIM swapping: Gaining control of an employee’s phone number to intercept MFA codes or complete 2FA flows.
- Cloud lateral movement: Once inside, pivoting through SaaS and cloud environments using valid credentials and session hijacking.
- Vendor impersonation: Exploiting third-party access by posing as a trusted IT provider or remote support agent.
Why Scattered Spider Signals a Shift in Threats and Responses
This group exposes a fundamental reality that identity is the new perimeter. Where many organizations have locked down their network traffic and patched known vulnerabilities, they’ve underestimated how easy it is to walk in the front door using trust-based systems.
Scattered Spider forces enterprises to confront uncomfortable truths:
- Your helpdesk is part of your attack surface.
- Your outsourced IT partner or supply chain may be your weakest link.
- Your MFA system isn’t safe if attackers can trick an employee into resetting it.
- The best trust system is zero-trust.
How Compliance Can Help Organizations Fight Back
Cybersecurity compliance frameworks help operationalize best practices that close the exact gaps Scattered Spider exploits. When properly implemented, these controls turn soft targets into hardened environments.
Here’s how compliance adherence helps:
- CMMC and NIST 800-171: Both require MFA, control over remote access, and monitoring of privileged account activity. These controls limit social engineering even if they don’t 100% mitigate it.
- SOC 2: Enforces principles around access controls, vendor risk, incident response, and change management… all key when dealing with impersonation and identity pivoting.
- HIPAA: Emphasizes strict access policies and workforce security to reduce the risk of unauthorized account modifications.
- ISO 27001: Requires documented identity management policies, audit logging, and access reviews that can expose privilege creep or account misuse.
It’s absolutely necessary, then, to think about compliance, ongoing monitoring, and the ongoing evolution of your security stack to begin addressing these threats.
Best Practices to Defend Against APTs like Scattered Spider
To defend against groups like Scattered Spider, organizations should implement a multi-layered identity and access strategy with strong governance. Most compliance frameworks currently provide guidelines for pursuing these strategies; as such, incorporating these practices into your compliance program is essential.
Key recommendations include:
- Move to phishing-resistant MFA: Swap out SMS codes and push notifications for hardware security keys (FIDO2), biometrics, or device-bound passkeys. They’re harder to trick or steal.
- Lockdown helpdesk procedures: Ensure your support teams verify identity in multiple ways before making account changes. One piece of info isn’t enough.
- Segment and minimize third-party access: Vendors should only get what they need—and nothing more. Use isolated environments or virtual desktops with full session logging.
- Watch for weird identity behavior: Use behavioral analytics to detect off-hours logins, sudden privilege changes, or logins from unusual locations.
- Strengthen cloud identity governance: Manage cloud identities and require ongoing reviews of decommissioned accounts.
- Simulate the threat: Run penetration tests and red team scenarios that mimic real-world helpdesk impersonation, SIM swaps, and lateral movement using valid credentials.
- Tie detection efforts to frameworks: Ensure your alerts and controls map to NIST, CMMC, or SOC 2. This connects security operations to compliance.
- Plan for identity-based incidents: Your incident response playbook should assume attackers are using stolen credentials. Be ready to revoke access, kill sessions, and quickly reset trust.
Continuum GRC Helps You Manage Identity Compliance
Scattered Spider uses trust and gaps in human processes to breach some of the most secure environments in the world. By embracing compliance not as a checkbox, but as a blueprint for hardened operations, organizations can outpace these new forms of identity-first threats.
We provide risk management and compliance support for every major regulation and compliance framework on the market, including:
- FedRAMP
- GovRAMP
- GDPR
- NIST 800-53
- DFARS NIST 800-171, 800-172
- CMMC
- SOC 1, SOC 2
- HIPAA
- PCI DSS 4.0
- IRS 1075, 4812
- COSO SOX
- ISO 27000 Series
- ISO 9000 Series
- CJIS
- 100+ Frameworks
And more. We are the only FedRAMP and StateRAMP-authorized compliance and risk management solution worldwide.
Continuum GRC is a proactive cybersecurity® and the only FedRAMP and StateRAMP-authorized cybersecurity audit platform worldwide. Call 1-888-896-6207 to discuss your organization’s cybersecurity needs and learn how we can help protect your systems and ensure compliance.
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