SEC536: Adversarial AI - Penetration Testing AI Systems


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Contact UsKey findings:
The review's central argument is that traditional vulnerability scanning and penetration testing in ICS environments carries meaningful operational risk to production systems, and that Frenos's digital twin approach lets asset owners perform these assessments against a representative model instead, reducing the scheduling and restoration burden that has historically made red team and purple team exercises difficult to complete in OT settings. The authors position this as directly relevant to compliance documentation requirements (such as NERC CIP-010-4 R3.2.2's requirement to document differences between a test environment and the CIP-applicable production environment it represents) rather than as a replacement for regulatory judgment. This is a SANS product review rather than primary survey research, authored by Tim Conway and Jason Dely and drawing on the Frenos platform's documented capabilities, named regulatory frameworks, and a single named case study (a large electric utility).
Traditional approaches to OT security face many significant challenges, including manual processes, resource constraints, scalability issues, and safety risks from live testing.

A digital twin is a production-mirroring model of a network and its assets that allows security teams to conduct vulnerability analysis, architecture reviews, and breach simulations without risk to live operational systems.
Frenos maps to specific NERC CIP-010-4 requirements, including R3.1 (paper-based or active vulnerability assessments every 15 months) and R3.2.2, which requires documenting the differences between the Frenos test environment and the CIP-applicable production environment it represents.
The review maps Frenos capabilities against NERC CIP, NIST CSF 2.0, TSA Pipeline Security Directives, and NIS2, focusing specifically on the vulnerability assessment, risk assessment, and architecture review requirements within each.
No. The platform is designed to run on-premises on a properly sized server with local GPUs for AI analytics, which supports regulated and isolated ICS networks that may have restrictions on externally controlled cloud services.
Attack path analysis correlates network segmentation, routing rules, open services, and known vulnerabilities to identify likely paths between an assumed attacker position and a target asset, which can reveal that mitigating just one shared path segment neutralizes multiple attack paths at once.


Jason Dely brings over 20 years of experience and a diverse industrial control system background to SANS and the industrial control system (ICS) community.
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SANS Fellow Tim Conway, co-author of ICS456, ICS310, and ICS612, blends decades of hands-on ICS/OT security and compliance expertise with ongoing frontline consulting, helping students turn complex industrial challenges into practical skills.
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