MalwareEducationEducationRansomwareData ExfiltratedData EncryptedRansom DemandedIdentity (basic)Government IDMediumContained

American Council for International Studies

bd_38613616484c8581 · schema v1 · pii pii-v1

Severity

Medium

Discovered

Jun 10, 2021

Filed

Dec 9, 2021

To disclose

26 weeks

Affected

180state residents only

Linked

8 filings

Confidence

66%

Full breach record for American Council for International Studies →2 incidents on file

American Council for International Studies (ACIS) notified the NH AG of a malware/ransomware incident discovered June 10, 2021. Unauthorized access occurred May 25-June 10, 2021, resulting in encryption of systems and exfiltration of names and SSNs from 180 NH residents. ACIS engaged forensic specialists, secured systems, and provided 1 year of credit monitoring via Experian.

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Incident timeline

undetected · 16 days

discovery → filing · 26 weeks / 182 days

May 25, 2021

Begins

Jun 10, 2021

Discovered

Dec 9, 2021

Filed

This filing is one of 8 filings about the same incident.View merged incident

Linked disclosures

Why this link?

Regulatory filings (7) · sorted by filing gap

Montana State AGbd_0cfa5fef00b11ee02021-12-03 · +6dCandidate
Oregon State AGbd_2b22345a0d7b36b32021-12-03 · +6dVerified
Maine State AGbd_417f20105b7024322021-12-03 · +6dVerified
Indiana State AGbd_6ceece1529a33a202021-12-03 · +6dVerified

Show 3 more filings ↓up to 6d gap

California State AGbd_b51c1c9a31d338052021-12-03 · +6dVerified
Washington State AGbd_ce6f170a133fdcaf2021-12-03 · +6dVerified
Massachusetts State AGbd_e554b021581b89902021-12-03 · +6dVerified

Name: Mullen Coughlin LLC
norm: mullen coughlin

Name: American Council for International Studies
norm: american council for international studies
Industry: Educationllm

Discovered: Jun 10, 2021
Breach occurred: May 25, 2021 – Jun 10, 2021
Undetected for: 16 daysoccurrence → discovery
Materiality determined: —
Notification sent: Dec 3, 2021
Affected individuals: 180state-resident count only
Data types: Identity (basic)Government ID
Attack vector: Ransomware
MITRE ATT&CK: T1486 Data Encrypted for ImpactT1041 Exfiltration Over C2 Channel
Threat actor: ExternalFinancial
Regulator citations: Notified Office of the New Hampshire Attorney GeneralNotified other appropriate state regulators

During the incident: Launched an investigation with the assistance of third-party computer forensic specialists
Secured the systems
Restored access to the information
Investigated what happened and whether the event resulted in any unauthorized access to, or theft of, information
Performed a comprehensive review of information stored on the systems
Conducted a manual review of its records to determine the identities and contact information for potentially affected individuals
Confirmed address information for affected individuals
Provided preliminary notice of this event along with an offer of complimentary credit monitoring services to potentially affected employees
Provided written notice of this event to affected individuals
Reported this event to federal law enforcement
Notified other appropriate state regulators
Changes made: Working to implement additional administrative and technical safeguards and training to its employees
Reviewing its security policies and procedures to reduce the risk of similar future events
Source: Quoted from the filing itself, not independently verified.

Time to disclose: 26 weeks(182 days from discovery to filing)
Compliance flags: — (clock not assessable for this source)

Status: No extraction artifact recorded for this disclosure.

Filing propagation · 8 filings · 8 states

View merged incident ↗

Montana State AGDec 3 · first

Oregon State AGDec 3 · first

Maine State AGDec 3 · first

Indiana State AGDec 3 · first

California State AGDec 3 · first

Washington State AGDec 3 · first

Massachusetts State AGDec 3 · first

New Hampshire State AG+6d · this page

Pattern: first filing Dec 3 (MT), last Dec 9 (NH) — a 6-day rolling notification. Rolling spreads often mean counsel is filing as thresholds trip per state. Why this link?

Evidence ladder

Leak-site claim

Attacker assertion only. Establishes: claim date, group, alleged victim.

Press / market report

Unlocks: incident narrative, operational impact. Still no compliance clock.

State AG / regulator filingThis record

Unlocks: discovery date, data types, affected count, compliance clock.

SEC 8-K / victim statement

Unlocks: materiality, stated response, full audit trail. Ceiling removed.

Source URL: https://mm.nh.gov/files/uploads/doj/remote-docs/american-council-international-studies-20211209.pdf
DisclosureLens links to the originating regulator URL — full filing bodies are not redistributed from public surfaces (§4.5).
Filed at: Dec 9, 2021
Raw hash: 5d67dcca22fe87e52625278428031b15e75a151a8cb5b7fead28eda821c7437a

Linked disclosures

Regulatory filings (7) · sorted by filing gap

Reporting entityMullen Coughlin LLC

Victim entityAmerican Council for International Studies

Incidentdiscovered Jun 10, 2021

Stated responseLaunched an investigation with the assistance of third-party computer forensic specialists

Complianceclock not assessable

Extraction provenanceno artifact recorded

Source provenancemm.nh.gov