There has been a recent spate of talks in Blackhat conf. and other confs, about the versatility of PS.exe, how it is used to perform persistence in comparably little characters, or lines of script than CMD.exe
Some of my Win10 deployments even contain a script which silently disables PS.exe in the installation, and removes every reference to that executable in the registry. There are a few cases where I caught PS.exe re-spawning itself when a Win10 update arrives, so a PS-free deployment is hard to enforce.