Bulletproof Hosting: A Critical Enabler of Cybercrime and the Challenges in Disruption

Abstract

Bulletproof hosting (BPH) services represent a critical and insidious enabler within the global cybercrime ecosystem, furnishing malicious actors with resilient and difficult-to-disrupt infrastructure for a diverse array of illicit online operations. This comprehensive report meticulously dissects the intricate operational methodologies employed by BPH providers, scrutinizes their pivotal role in catalyzing and sustaining various forms of cybercrime, explores the profound technical and jurisdictional complexities they introduce to law enforcement and cybersecurity efforts, and evaluates the extensive international initiatives and persistent challenges encountered in the identification, disruption, and imposition of sanctions against these digital sanctuaries. Through an in-depth examination of prominent BPH entities, including a detailed case study of Zservers, this analysis endeavors to illuminate the multifaceted nature of cybercrime facilitation and underscore the imperative for a concerted, globally coordinated response to effectively mitigate its far-reaching impact on digital security and economic stability.

Many thanks to our sponsor Esdebe who helped us prepare this research report.

1. Introduction

The advent of the digital age, characterized by unprecedented connectivity and technological advancement, has simultaneously witnessed an alarming proliferation and escalating sophistication of cybercriminal activities. From pervasive data breaches and elaborate financial fraud schemes to the crippling impact of ransomware attacks and the clandestine operations of state-sponsored advanced persistent threats (APTs), the digital landscape is continuously assailed by malicious actors. A foundational and increasingly critical component enabling the persistence and scale of these illicit endeavors is the existence of specialized internet hosting services known as bulletproof hosting. These services offer cybercriminals an exceptionally resilient, anonymous, and often legally unassailable environment from which to orchestrate and execute their operations. Unlike legitimate hosting providers bound by strict terms of service and legal obligations to respond to abuse complaints, BPH services are distinguished by their deliberate resistance to interventions, including takedown requests from victims, industry abuse teams, and even international law enforcement agencies. This inherent resistance provides a sanctuary for malicious actors, allowing them to execute their schemes with a disconcerting degree of impunity. This report undertakes a rigorous and in-depth analysis of bulletproof hosting, meticulously detailing its operational dynamics, examining its profound implications for global cybersecurity, and evaluating the complex, often arduous, global efforts being marshaled to counteract its pervasive influence.

Many thanks to our sponsor Esdebe who helped us prepare this research report.

2. Understanding Bulletproof Hosting

2.1 Definition and Core Characteristics

Bulletproof hosting, at its essence, refers to internet hosting services specifically designed and marketed to be impervious to complaints, abuse reports, and takedown requests, particularly those originating from law enforcement agencies, cybersecurity researchers, and intellectual property rights holders. These providers intentionally operate within or exploit legal ambiguities of jurisdictions characterized by lenient or unenforced cybercrime laws, or states with limited international legal cooperation frameworks. This strategic jurisdictional selection allows them to host content and facilitate activities that would otherwise be swiftly subjected to removal or severe legal repercussions in more stringent regulatory environments. The ‘bulletproof’ moniker is not merely a marketing term; it reflects a deliberate operational posture aimed at maximizing the longevity and resilience of hosted illicit content, making it exceptionally difficult for legitimate authorities to disrupt. These services are typically advertised on clandestine cybercriminal forums, dark web marketplaces, and encrypted messaging channels, specifically targeting individuals or groups engaged in illicit activities. They openly offer infrastructure that explicitly supports a spectrum of malicious activities, including, but not limited to, large-scale malware distribution networks, sophisticated phishing campaigns, resilient botnet command and control (C2) servers, illicit online pharmacies peddling unverified or counterfeit medications, websites facilitating the sale of counterfeit goods, child exploitation material, and darknet marketplaces dealing in illicit narcotics, stolen credentials, and weaponry.

Key characteristics that define BPH providers include:

• Immunity to Abuse Complaints: A fundamental promise of BPH is the disregard for abuse reports concerning phishing, malware, spam, or copyright infringement. They often have ‘no questions asked’ policies regarding content.
• Jurisdictional Arbitrage: Strategic placement of servers and corporate entities in countries with weak or non-existent cybercrime laws, limited extradition treaties, or a general reluctance to cooperate with international law enforcement.
• Anonymity for Clients: Strong emphasis on client anonymity, often requiring payment in cryptocurrencies and allowing registration with false or stolen identities.
• Technical Resilience Measures: Implementation of advanced technical measures to evade detection and disruption, as detailed in the following section.
• Targeted Client Base: Unlike legitimate hosting, BPH services exclusively cater to and actively solicit cybercriminals and actors engaged in illicit activities.
• High Profit Margins: Due to the specialized and risky nature of their services, BPH providers often charge premium rates, attracting them to this lucrative niche.

2.2 Operational Mechanisms and Evasion Strategies

BPH providers employ a sophisticated array of strategies, encompassing technical, financial, and operational layers, to maintain the resilience and clandestine nature of their services. Their operational mechanics are designed to create a labyrinthine network that is arduous for investigators to navigate and dismantle.

2.2.1 Infrastructure Acquisition and Obfuscation

• Leasing and Sub-leasing: BPH providers rarely own extensive physical server infrastructure. Instead, they typically lease dedicated servers, virtual private servers (VPS), or even entire IP address ranges from legitimate, often unwitting, upstream providers or data centers globally. They may then sub-lease these resources to their cybercriminal clients. This layering of services, sometimes referred to as ‘nested hosting’, significantly complicates the process of tracing illicit activity back to its source.
• Compromised Infrastructure: In some instances, BPH operators may utilize compromised legitimate servers or networks (e.g., through unpatched vulnerabilities or weak credentials) as part of their bulletproof infrastructure, effectively turning innocent third parties into unwilling accomplices.
• False/Stolen Identities: A cornerstone of their operational security is the use of false, stolen, or fabricated identities to register domains, acquire servers, and establish accounts with upstream legitimate providers. This includes using stolen credit card details, forged documents, or mule accounts, creating a significant investigative hurdle for attribution.
• Shell Companies and Nominees: To further obscure their true ownership and financial flows, BPH operators frequently establish complex corporate structures involving shell companies registered in offshore jurisdictions or utilize nominee directors, making it exceptionally difficult to pierce the corporate veil.

2.2.2 Technical Resilience and Evasion

• Dynamic IP Address Rotation (Fast Flux): A common technique, Fast Flux involves rapidly changing the IP address associated with a domain name in the DNS records. This constant rotation, sometimes occurring every few minutes, makes it exceedingly difficult for security services to blacklist or block malicious domains. It forces investigators to continuously update their blocklists, which is resource-intensive and often lags behind the changes.
• Domain Name Hopping: Similar to IP rotation, BPH clients may frequently switch between multiple domain names for the same malicious service (e.g., a C2 server or phishing site). If one domain is identified and blacklisted, another immediately takes its place, ensuring continuous operation.
• Content Delivery Networks (CDNs) and Reverse Proxies: Malicious content can be served through legitimate CDNs or reverse proxy services. This not only obfuscates the true origin IP address but also leverages the robust infrastructure of these services for resilience against DDoS attacks and improved performance, making takedowns more challenging as legitimate infrastructure is involved.
• Encryption: Widespread use of SSL/TLS encryption for all communications between clients and hosted malicious services (e.g., C2 traffic, phishing form submissions) makes it harder for network defenders to inspect traffic content.
• DDoS Protection for Themselves: BPH providers often employ sophisticated DDoS protection measures to safeguard their own infrastructure from retaliatory attacks or disruption efforts by white-hat hackers.
• Geographic Distribution: Spreading their physical server presence across multiple jurisdictions, including those with lax laws or where cooperation is difficult, provides redundancy and makes comprehensive takedowns more complex.

2.2.3 Financial and Communication Anonymity

• Cryptocurrency Payments: The vast majority of BPH services exclusively accept payments in cryptocurrencies such as Bitcoin, Monero, or Zcash. These digital currencies, particularly those offering enhanced privacy features, provide a high degree of anonymity for both the provider and the client, complicating financial tracing and asset seizure efforts.
• Encrypted Communication Channels: Communication between BPH operators and their clients typically occurs over encrypted messaging platforms (e.g., Jabber with OTR, Telegram, Signal) or through dedicated, secure forums. This makes it difficult for law enforcement to intercept or monitor their interactions.

This dynamic and multi-layered approach to operational security makes it exceptionally challenging for cybersecurity professionals, threat intelligence analysts, and law enforcement agencies to track, identify, and effectively mitigate the activities of cybercriminals who depend on BPH services.

Many thanks to our sponsor Esdebe who helped us prepare this research report.

3. The Role of Bulletproof Hosting in Cybercrime

Bulletproof hosting services are not merely ancillary components but are absolutely integral to the enduring success and scale of various cybercriminal operations. They provide the foundational infrastructure that allows cybercriminals to operate with a significant degree of anonymity, resilience, and operational continuity, effectively shielding them from detection and disruption.

3.1 Facilitation of Illicit Activities: A Deeper Dive

BPH services underpin a vast spectrum of cybercrimes, offering the necessary secure and persistent environment for their execution:

• Ransomware Campaigns: BPH providers are indispensable for ransomware groups. They host critical components such as:

  • Command and Control (C2) Servers: These servers issue commands to compromised systems (botnets), manage encryption keys, and exfiltrate data. Their resilience is crucial for the success of a ransomware attack, as disruption means the threat actors lose control of their deployed malware.
  • Data Leak Sites: Following a double extortion attack where data is exfiltrated, BPH hosts websites used to publicize stolen data if the victim refuses to pay the ransom. These sites need to be highly resilient to takedown attempts to maximize pressure on the victim.
  • Payment Portals: While most ransomware payments are in cryptocurrency, BPH may host accompanying instructional sites or portals detailing payment procedures.
  • Malware Payloads: The actual ransomware executables or dropper files are often hosted on BPH infrastructure to ensure continuous availability for distribution.

• Phishing and Scamming Operations: BPH is a preferred choice for hosting fraudulent websites designed to harvest credentials or perpetuate scams due to its resistance to takedown notices:

  • Phishing Landing Pages: These are meticulously crafted fake login pages mimicking legitimate banking, email, social media, or corporate portals. BPH ensures these pages remain online long enough to ensnare a significant number of victims before being detected and blacklisted.
  • Business Email Compromise (BEC) Scams: BPH can host intermediary sites used in BEC scams to redirect funds or provide fake invoices.
  • Technical Support Scams: Websites prompting users to call fake support lines or download malicious ‘diagnostic’ software.
  • Investment and Romance Scams: Long-running fraudulent investment platforms or dating sites designed to fleece victims over extended periods, requiring stable hosting resistant to external complaints.

• Botnet Command and Control (C2) Infrastructure: Botnets, large networks of compromised computers, rely heavily on robust C2 servers to receive commands from their operators. BPH provides the ideal environment for these C2s, ensuring that botnet operators can maintain control over their enslaved machines for prolonged periods, enabling activities like:

  • Distributed Denial of Service (DDoS) Attacks: Orchestrating overwhelming traffic to target websites, disrupting services.
  • Spam Campaigns: Sending massive volumes of unsolicited emails, often containing malware or phishing links.
  • Credential Stuffing: Attempting to log into accounts using stolen credentials, facilitated by BPH-hosted C2s.
  • Cryptocurrency Mining: Deploying illicit crypto-mining software on compromised systems.

• Malware Distribution and Exploitation Kits: BPH is crucial for the initial deployment and persistence of malware:

  • Drive-by Download Sites: Websites hosting exploit kits that automatically infect visitors’ computers by exploiting browser or software vulnerabilities.
  • Malware Repositories: Centralized locations for storing various malware strains (trojans, keyloggers, infostealers) for distribution.
  • Malicious Software Updates: Sites masquerading as legitimate software update servers to distribute malware.

• Dark Web Marketplaces and Illicit Content: While not exclusively BPH, many dark web marketplaces and sites hosting illegal content (e.g., child exploitation material, drug sales, stolen data forums) rely on providers offering extreme levels of anonymity and resistance to law enforcement intervention.

• Spamming and SEO Poisoning: BPH provides the computational power and network resilience to send vast quantities of unsolicited emails and host malicious websites optimized to rank highly in search engine results, directing unsuspecting users to malware or phishing pages.

• Terrorism and Extremism: In some instances, radical groups have leveraged the resilience and anonymity of BPH to host propaganda, recruitment materials, and secure communication platforms, complicating counter-terrorism efforts.

The anonymity and resistance to takedown requests offered by BPH providers allow cybercriminals to target victims globally without significant interference, leading to substantial financial losses, reputational damage, and, in some cases, severe social harm.

3.2 Case Study: Zservers and the LockBit Connection

Zservers, a Russia-based bulletproof hosting provider, emerged as a quintessential example of how such services directly underpin and enable large-scale, financially devastating cybercriminal enterprises. Its notoriety peaked with the targeted sanctions imposed by a coalition of international authorities, specifically highlighting its profound involvement with the notorious LockBit ransomware group.

Background of Zservers: Little is publicly known about the early origins of Zservers, but it gained a reputation within cybercriminal circles for offering highly resilient and abuse-tolerant hosting solutions. Its operational model was predicated on providing infrastructure that could withstand takedown attempts and investigations, a key selling point for ransomware operators and other cybercriminals who require consistent uptime for their illicit activities. Zservers operated by leasing a global network of servers and IP addresses, then reselling them with assurances of minimal interference from abuse complaints, making it a prime choice for those looking to maintain illicit online presences without fear of rapid disruption.

The LockBit Connection: The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), in a coordinated action with the U.K.’s National Crime Agency (NCA) and Australia’s Australian Signals Directorate (ASD)/Australian Federal Police (AFP), formally sanctioned Zservers in early 2025. The core accusation was that Zservers had ‘materially assisted, sponsored, or provided financial, material, or technological support’ to the LockBit ransomware group. This sanctioning decision was part of a broader international effort, dubbed ‘Operation Cronos,’ specifically targeting the LockBit ransomware ecosystem. Zservers was implicated in providing highly specialized servers designed to resist law enforcement actions, thereby enabling LockBit’s extensive ransomware attacks. These attacks, often employing a double extortion model (encrypting data and threatening to leak it), have collectively extorted over $120 million from victims globally. The resilience offered by Zservers allowed LockBit to maintain persistent command and control over compromised networks and host their data leak sites, crucial for pressuring victims into paying ransoms.

Impact on Noted Victims: The scale of LockBit’s operations, facilitated by providers like Zservers, is evident in the high-profile targets it successfully compromised:

• Boeing: One of the world’s largest aerospace companies, suffered a LockBit attack impacting parts of its network, leading to data exfiltration and operational disruption.
• Industrial and Commercial Bank of China (ICBC): The U.S. arm of China’s largest bank was significantly impacted by a LockBit attack, disrupting its financial services and reportedly impacting the U.S. Treasury market.
• U.K.’s Royal Mail: A major disruption to international parcel delivery services in the UK, causing significant economic and logistical challenges.
• Britain’s National Health Service (NHS): While specific details are often guarded, any attack on critical healthcare infrastructure poses severe risks to patient care and national security.
• Allen & Overy: A prominent international law firm, highlighting the reach of ransomware into professional services, which often hold sensitive client data.

Zservers’ deliberate provision of services that guaranteed anonymity and resilience against takedown requests made it a cornerstone of LockBit’s operational infrastructure. The sanctions against Zservers aimed to sever this critical support lifeline, hindering LockBit’s ability to operate and extract ransom payments by targeting the financial and technical infrastructure that sustained it. The case underscores how BPH providers are not passive observers but active enablers, intricately woven into the fabric of sophisticated cybercriminal enterprises. (apnews.com, reuters.com)

Many thanks to our sponsor Esdebe who helped us prepare this research report.

4. Technical and Jurisdictional Complexities

The battle against bulletproof hosting is inherently fraught with significant technical and jurisdictional challenges, largely due to the deliberate design of BPH services to obfuscate origins and exploit international legal disparities. These complexities necessitate highly sophisticated and coordinated responses from law enforcement and cybersecurity agencies globally.

4.1 Technical Challenges

The technical infrastructure of BPH services is specifically engineered to evade detection, attribution, and disruption. This sophistication creates substantial hurdles for investigators:

• Attribution and Tracing Obfuscation: BPH operators employ multiple layers of obfuscation to hide their own identities and the true location of their illicit infrastructure. This includes:

  • Proxy Chains and Nested VPNs: Routing traffic through multiple layers of proxies or VPNs, sometimes hosted on other BPH services, making it extremely difficult to trace back to the originating source.
  • Tor Network Utilization: Leveraging the Tor network for anonymous communication and accessing dark web services further complicates traffic analysis and source identification.
  • Compromised Legitimate Systems: Illicit activities may be launched from compromised legitimate servers, cloud instances, or home routers, turning them into unwilling proxies and adding noise to forensic investigations.

• Dynamic Infrastructure and Evasion Techniques: The constantly shifting nature of BPH infrastructure is a significant obstacle:

  • Fast Flux and Domain Generation Algorithms (DGAs): As discussed, rapid IP address changes and algorithmic domain generation make blacklisting ineffective and require continuous monitoring and updating of threat intelligence feeds.
  • Rapid Server Migration: When a service is detected, BPH operators can quickly migrate the malicious content or C2 server to a new server in a different jurisdiction or under a new IP address, often within minutes, maintaining operational continuity.
  • Anti-Analysis and Polymorphic Malware: Malware hosted on BPH infrastructure is often designed with anti-analysis features to detect virtual machines or sandboxes, and polymorphic capabilities to change its signature, evading traditional antivirus detection.
  • Abuse of Legitimate Cloud and CDN Services: Malicious content can be hidden within legitimate cloud infrastructure (e.g., AWS S3 buckets, Google Cloud Storage) or delivered via legitimate Content Delivery Networks, making it difficult to block without impacting legitimate services.

• Encryption and Secure Communications:

  • End-to-End Encryption: The widespread use of SSL/TLS for web traffic and encrypted channels (e.g., Signal, Telegram, Jabber with OTR) for operator-to-client communication makes intelligence gathering via network traffic interception exceedingly difficult.
  • Encrypted Payloads: Malware payloads themselves may be encrypted, making static analysis challenging.

• Resource-Intensive Investigations: Identifying, mapping, and disrupting BPH networks requires significant resources, including advanced technical skills, expensive specialized tools, and considerable time for forensic analysis, network monitoring, and intelligence gathering. This often stretches the capabilities of law enforcement agencies.

• Sinkholing Challenges: While effective for disrupting botnet C2s by redirecting traffic to a controlled server, sinkholing requires identifying the C2, gaining control of DNS records, and constant monitoring, which is complex when dealing with dynamic BPH infrastructure.

4.2 Jurisdictional Challenges

The global nature of the internet, coupled with the strategic choices of BPH providers, creates profound jurisdictional hurdles for international law enforcement:

• Sovereignty and International Law: Every nation exercises sovereignty over its own cyber infrastructure and legal processes. There is no universally recognized or enforced international cybercrime law. Definitions of cybercrimes, acceptable investigative techniques, and standards of evidence vary widely across jurisdictions.

• Mutual Legal Assistance Treaties (MLATs) and Letters Rogatory: These traditional mechanisms for cross-border legal cooperation are notoriously slow, cumbersome, and often ineffective in the fast-paced world of cybercrime. Requesting data or action from a foreign government through an MLAT can take months or even years, by which time the malicious infrastructure has long since moved or been dismantled by the criminals.

• Lack of Political Will and Non-Cooperation: A significant challenge arises when BPH providers operate in jurisdictions where authorities lack the political will to cooperate with international law enforcement. This can be due to various factors, including corruption, geopolitical tensions, lack of resources, or even tacit state complicity with certain cybercriminal groups.

• Anonymity of Operators: Even if the servers are identified, prosecuting the BPH operators themselves is challenging due to their rigorous use of anonymity measures, including false identities, shell companies, and operating from non-extraditable countries.

• Evidence Collection and Admissibility: The rules for collecting electronic evidence, ensuring its chain of custody, and its admissibility in court vary significantly between legal systems, complicating international prosecutions.

• Concept of ‘Cyber Safe Havens’: Certain countries become de facto ‘cyber safe havens’ where BPH operations can flourish with minimal fear of law enforcement intervention. These jurisdictions become attractive to cybercriminals, who establish a presence knowing that cross-border enforcement is unlikely.

These technical and jurisdictional complexities necessitate a nuanced, multi-layered approach to combating BPH, combining technical innovation with robust international diplomatic and legal efforts to close the gaps exploited by cybercriminals.

Many thanks to our sponsor Esdebe who helped us prepare this research report.

5. International Efforts and Challenges in Disrupting Bulletproof Hosting

Recognizing the profound threat posed by bulletproof hosting services, international authorities have intensified their coordinated actions. However, despite notable successes, significant challenges persist in effectively disrupting these resilient criminal enablers.

5.1 Sanctions and Legal Actions

Financial sanctions and legal prosecutions have emerged as potent tools in the global effort to degrade the operational and financial capabilities of BPH providers.

• Targeted Sanctions (e.g., Zservers): The sanctioning of Zservers in February 2025 by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), in concert with the U.K.’s National Crime Agency (NCA) and Australia’s Australian Signals Directorate (ASD) and Australian Federal Police (AFP), exemplifies a concerted international strategy. These sanctions were imposed under specific authorities, such as U.S. Executive Order 13694 (as amended by 13757), which targets malicious cyber activities. The direct impact of such sanctions includes:

  • Asset Freezes: Any assets of the sanctioned entity (Zservers) and its designated administrators or affiliates within the jurisdiction of the sanctioning countries are frozen.
  • Financial Exclusion: U.S. persons, entities, or any parties dealing in U.S. currency are generally prohibited from engaging in transactions with sanctioned entities. This effectively cuts off access to the international financial system, making it difficult for BPH providers to receive payments (even in cryptocurrency, if converted through regulated exchanges) or procure legitimate infrastructure.
  • Travel Bans: Designated individuals associated with the BPH service may face travel bans to the sanctioning countries.
  • Reputational Damage: Sanctions publicly name and shame the entities, raising awareness within the legitimate technology sector about their illicit activities.
    The sanctions against Zservers were not isolated but part of a broader ‘Operation Cronos,’ a coordinated multinational effort against the LockBit ransomware group, demonstrating an intent to disrupt the entire cybercrime ecosystem, from the malware operators to their infrastructure providers.

• Other Legal Frameworks:

  • Council of Europe’s Budapest Convention on Cybercrime: This landmark international treaty, ratified by over 60 countries, provides a crucial legal framework for international cooperation in cybercrime investigations, including mutual legal assistance and extradition. While not perfect, it significantly streamlines the process compared to ad-hoc agreements.
  • National Laws: Countries like the U.S. (e.g., Computer Fraud and Abuse Act – CFAA) and the U.K. (e.g., Computer Misuse Act) have robust national laws that allow for the prosecution of individuals involved in facilitating cybercrime, including BPH operators.
  • EU Directives: The European Union has issued directives, such as the Cybersecurity Directive (NIS2) and various Anti-Money Laundering (AML) directives, that aim to enhance cybersecurity resilience and combat financial crimes, which can indirectly impact BPH operations by increasing scrutiny on financial transactions.

• Prosecution of Operators: Law enforcement agencies have achieved success in identifying and prosecuting BPH operators. For instance, in 2021, the founder and administrators of a prominent BPH service known as ‘Fingers of God (FG-host)’ were successfully apprehended and sentenced in the U.S. for their role in facilitating various cybercriminal activities, including child exploitation material. Such prosecutions serve as a deterrent and dismantle key components of the BPH ecosystem. (bleepingcomputer.com)

5.2 Seizure of Infrastructure and Takedowns

Direct action against physical infrastructure remains a potent tactic for disrupting BPH services:

• Zservers Server Seizure: As part of ‘Operation Cronos,’ the Dutch police, acting on intelligence, successfully seized 127 servers associated with Zservers. This physical seizure took critical infrastructure offline, immediately disrupting the operations of numerous cybercriminal clients utilizing the service, particularly those associated with LockBit. This action demonstrated the practical effectiveness of international intelligence sharing and coordinated physical intervention. The impact was immediate, rendering numerous C2 servers, data leak sites, and other malicious infrastructure inaccessible. (securityweek.com)

• Sinkholing Operations: This technique involves redirecting malicious traffic from compromised machines (botnets) to servers controlled by law enforcement or cybersecurity researchers. By controlling the domain name or IP address associated with a botnet’s C2, investigators can ‘sinkhole’ the traffic, preventing criminals from issuing commands and allowing for identification of victims. This method is highly effective for disrupting large-scale botnets but requires precise timing and coordination.

• Domain Name Seizures: Cooperation with domain registrars and registries is crucial. Law enforcement can obtain court orders to seize control of malicious domain names, rendering them unusable by criminals. This can be challenging with less cooperative registrars or those operating in non-responsive jurisdictions.

• Cooperation with Legitimate Providers: While BPH specifically avoids legitimate oversight, a significant part of the disruption effort involves pressuring or working with legitimate upstream Internet Service Providers (ISPs), data centers, and cloud providers (e.g., Amazon Web Services, Google Cloud) whose infrastructure may be unwittingly or negligently used by BPH operators. Through abuse reports and legal requests, these legitimate entities can be compelled to terminate services to identified BPH clients.

• Public-Private Partnerships: Collaborative efforts between law enforcement agencies and private cybersecurity firms, threat intelligence companies, and CERTs (Computer Emergency Response Teams) are essential. These partnerships facilitate rapid information sharing about emerging threats, malicious infrastructure, and BPH operations, accelerating detection and response times.

5.3 Challenges in Enforcement

Despite these intensified efforts and successes, the fight against BPH is an ongoing and complex battle, marked by several persistent challenges:

• Adaptability and Resilience of Cybercriminals: Cybercriminals and BPH operators are highly agile. When one service is disrupted, they quickly adapt by migrating to new providers, adopting new obfuscation techniques, or shifting to new jurisdictions. This constant cat-and-mouse game requires continuous innovation from law enforcement.

• Resource Constraints: Investigating and prosecuting BPH operations is incredibly resource-intensive, requiring specialized technical expertise, significant manpower, and considerable financial investment. Many law enforcement agencies, particularly in developing nations, lack these resources.

• Balancing Privacy and Security: The legitimate use of privacy-enhancing technologies (e.g., VPNs, Tor) presents a challenge. While these tools offer legitimate privacy benefits, they are also heavily leveraged by BPH operators and their clients to obscure their activities, creating a dilemma for policymakers and investigators.

• Emerging Technologies: The proliferation of decentralized technologies (e.g., Web3, blockchain-based hosting, decentralized autonomous organizations – DAOs) and anonymous cryptocurrencies (e.g., Monero) presents new avenues for BPH-like services that are even more resistant to traditional takedown methods. The potential for AI to automate and scale malicious activities further complicates the landscape.

• Lack of Global Political Consensus: Disagreements among nations regarding cyber norms, state-sponsored cyber activities, and the extent of cross-border cooperation continue to hinder a unified global response to cybercrime and its enablers like BPH.

• Measuring Long-Term Success: While individual takedowns can cause immediate disruption, measuring the long-term impact on the overall cybercrime ecosystem is difficult. Services may re-emerge under new names, or clients may simply find alternative providers.

Addressing these challenges requires sustained investment, continuous innovation in technical and legal strategies, and an unwavering commitment to international collaboration.

Many thanks to our sponsor Esdebe who helped us prepare this research report.

6. Future Outlook and Recommendations

The enduring threat posed by bulletproof hosting services necessitates a forward-looking and multifaceted strategic response. The dynamic nature of cybercrime, coupled with the inherent resilience of BPH models, demands constant adaptation and enhanced collaboration across various sectors.

6.1 Technological Solutions and Research

• Advanced Threat Intelligence Platforms: Continued investment in and development of highly sophisticated threat intelligence platforms that can ingest vast amounts of data from diverse sources (e.g., dark web forums, passive DNS, network telemetry, blockchain analysis). These platforms, leveraging Artificial Intelligence (AI) and Machine Learning (ML), can identify patterns, anomalies, and emerging BPH infrastructures more rapidly and accurately than manual methods.
• Proactive Detection and Forecasting: Research into predictive analytics and behavioral modeling to anticipate where new BPH services might emerge or where existing ones might migrate. This includes analyzing trends in criminal forums, geopolitical shifts, and technological developments.
• Blockchain Analysis Tools: As cryptocurrencies remain the preferred payment method, advanced blockchain analytics tools are crucial for tracing illicit financial flows, identifying wallets associated with BPH providers, and assisting in potential asset seizures.
• Decentralized Network Monitoring: Developing new methodologies and tools to monitor and analyze malicious activities on emerging decentralized networks (e.g., IPFS, blockchain-based hosting) that could be exploited for BPH purposes.
• Automated Takedown Request Systems: Streamlining and automating the process of sending abuse reports and takedown requests to legitimate upstream providers, registrars, and cloud services, thereby reducing the window of opportunity for malicious content.

6.2 Policy, Legal, and Regulatory Reforms

• Strengthening Mutual Legal Assistance Treaties (MLATs): Reforming and modernizing MLAT processes to be more agile, efficient, and responsive to the speed of cybercrime investigations. This may involve expedited procedures for certain types of cybercrime or the development of a ‘fast-track’ MLAT process.
• Harmonization of Cybercrime Laws: Encouraging greater international harmonization of cybercrime definitions and penalties to facilitate smoother cross-border prosecutions and reduce jurisdictional arbitrage opportunities for BPH operators.
• Increased Accountability for Service Providers: Implementing regulatory frameworks that place a greater onus on legitimate internet service providers, registrars, and cloud platforms to conduct due diligence on their customers and to respond more swiftly and effectively to abuse complaints, with penalties for negligence.
• International Norms and Frameworks: Continued efforts through intergovernmental bodies (e.g., United Nations, Council of Europe, G7/G20) to develop and enforce international norms for responsible state behavior in cyberspace, including the non-provision of safe havens for cybercriminals.
• Sanctions Expansion: Broadening the scope and reach of targeted sanctions programs to more consistently identify and penalize entities and individuals who materially support cybercrime infrastructure globally.

6.3 Enhanced International Cooperation

• Information Sharing: Fostering deeper and more trusted relationships between international law enforcement agencies, intelligence services, and private sector cybersecurity firms to facilitate rapid, secure, and actionable intelligence sharing regarding BPH activities and their clients.
• Joint Operations and Task Forces: Conducting more frequent and robust multinational joint operations, similar to ‘Operation Cronos,’ to simultaneously disrupt multiple layers of cybercriminal operations, including their BPH dependencies. These operations benefit from pooling resources and expertise.
• Capacity Building: Providing technical assistance, training, and resources to law enforcement agencies in countries with weaker cybercrime laws or limited enforcement capabilities. Strengthening these nations’ abilities to combat BPH domestically reduces the number of potential ‘cyber safe havens.’
• Diplomatic Engagement: Engaging in active diplomatic efforts to encourage non-cooperative states to adhere to international cybercrime norms and facilitate investigations originating from other jurisdictions.

6.4 Private Sector Engagement

• Proactive Threat Hunting: Cybersecurity companies, threat intelligence vendors, and domain registrars should proactively hunt for and identify BPH infrastructure and services, sharing this information with law enforcement.
• Industry Best Practices: Developing and promoting industry best practices for identifying and mitigating abuse on their platforms, including stricter Know Your Customer (KYC) requirements for hosting services.
• Research and Development: Private companies should continue to invest in R&D for new tools and techniques to detect, track, and disrupt BPH operations.

6.5 Public Awareness and Education

• Cyber Hygiene Promotion: Educating the general public and businesses about basic cyber hygiene practices (e.g., strong passwords, multi-factor authentication, recognizing phishing attempts) reduces the pool of potential victims for cybercriminals enabled by BPH.

By adopting a comprehensive strategy that integrates technological innovation, legal and policy reforms, and unwavering international cooperation, stakeholders can hope to significantly diminish the operational effectiveness and economic viability of bulletproof hosting services, thereby enhancing global cybersecurity and safeguarding digital infrastructures worldwide.

Many thanks to our sponsor Esdebe who helped us prepare this research report.

7. Conclusion

Bulletproof hosting services are an undeniable and formidable pillar in the intricate architecture of modern cybercrime, providing an enduring and anonymous operational environment that underpins a vast spectrum of illicit activities. As exemplified by the critical role of Zservers in facilitating the devastating LockBit ransomware attacks, BPH providers are not passive entities but active enablers, whose resilience and disregard for legal norms amplify the scale and impact of cybercriminal enterprises, resulting in substantial financial losses, reputational damage, and, in some cases, tangible harm to critical infrastructure and public safety. The inherent technical sophistication employed by BPH operators, coupled with the profound complexities arising from jurisdictional disparities across sovereign nations, creates a formidable challenge for global law enforcement and cybersecurity communities. Effectively addressing the persistent threat posed by BPH services demands a meticulously orchestrated, multifaceted approach. This strategy must seamlessly integrate cutting-edge technical innovation for enhanced detection and disruption, proactive legal reforms to close existing loopholes and standardize international responses, and, crucially, robust and unwavering international cooperation. By developing a nuanced and comprehensive understanding of the operational dynamics of BPH providers and acknowledging the intricate challenges involved in their disruption, stakeholders across government, industry, and academia can collectively formulate and implement more effective, sustainable strategies to combat cybercrime, dismantle its underlying infrastructure, and fortify the security of digital infrastructures on a global scale. The fight against bulletproof hosting is a perpetual arms race, requiring continuous vigilance, adaptability, and a unified global front to safeguard the integrity and security of the digital world.

Many thanks to our sponsor Esdebe who helped us prepare this research report.

References

• U.S. Department of the Treasury. (2025, February 11). Russian cybercrime network targeted for sanctions across US, UK and Australia. Associated Press. https://apnews.com/article/361e788f5482bfd787af01002af2ff4c
• Reuters. (2025, February 11). US, UK, Australia target Russia-based Zservers over Lockbit ransomware attacks. https://www.reuters.com/technology/cybersecurity/us-uk-australia-target-russia-based-zservers-over-lockbit-ransomware-attacks-2025-02-11/
• SecurityWeek. (2025, February 12). 127 Servers of Bulletproof Hosting Service Zservers Seized by Dutch Police. https://www.securityweek.com/127-servers-of-bulletproof-hosting-service-zservers-seized-by-dutch-police/
• Wikipedia. (2024, May 15). Bulletproof hosting. https://en.wikipedia.org/wiki/Bulletproof_hosting
• BleepingComputer. (2021, July 1). Bulletproof hosting founder imprisoned for helping cybercrime gangs. https://www.bleepingcomputer.com/news/security/bulletproof-hosting-founder-imprisoned-for-helping-cybercrime-gangs/
• BleepingComputer. (2021, October 29). Bulletproof hosting admins sentenced for helping cybercrime gangs. https://www.bleepingcomputer.com/news/security/bulletproof-hosting-admins-sentenced-for-helping-cybercrime-gangs/
• BleepingComputer. (2021, August 24). Bulletproof hosting admins plead guilty to running cybercrime safe haven. https://www.bleepingcomputer.com/news/security/bulletproof-hosting-admins-plead-guilty-to-running-cybercrime-safe-haven/
• The Record from Recorded Future News. (2025, February 11). Russian bulletproof hosting service Zservers sanctioned by US for LockBit coordination. https://therecord.media/zservers-russia-bulletproof-hosting-us-uk-sanctions
• Pindrop. (2024, February 12). Inside the Fight Against Bulletproof Hosting Providers. https://www.pindrop.com/article/inside-fight-against-bulletproof-hosting-providers/
• Cyble. (2024, February 20). ACSC Targets Bulletproof Hosting To Disrupt Cybercrime. https://cyble.com/blog/acsc-highlights-bulletproof-hosting-providers/