Versatile AI Risk Assessment
Banking and insurance

Payment fraud detection

A model assesses each payment for suspected fraud in real time and stops suspicious payments or refers them for review.

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A concise PDF covering how the system works, its data flows and points to investigate, ready to share.

The explanations and measures describe the typical system design. Extensive personal changes add an appendix.

Understand the use case

What defines this use case?

Payment networks, payment service providers and banks use these models. The European Banking Authority and BaFin identify this as one of the most common AI uses in finance.

This page describes a typical system design. Actual data flows and permissions depend on your implementation.

System design
Analysis and processing
Ability to act
Can act within applications
Fields of use
banking, card payments, payment services
Also known as
fraud detection, transaction monitoring

How it works, step by step

System design and data flows

  1. Input data

    Each payment supplies its amount, recipient, time, device and location, alongside the card or account's payment history.

    The person initiating the payment determines its amount, recipient, device and location; that person may be a fraudster. Each payment is linked to a card or account, and therefore to a person.

  2. Processing

    A model compares the payment with known fraud patterns and normal behaviour and calculates a risk score.

    The system compares transactions and their characteristics with learned patterns or expected behaviour. It produces an anomaly assessment that can trigger further review. Blocking or declining a transaction occurs only through subsequent process logic and the authority assigned within it.

  3. Results

    The system approves the payment, requests additional confirmation, stops it or rejects it.

    The result describes the defined model task. A match, category or forecast acquires its professional significance only in conjunction with the underlying data and intended use.

  4. Use and impact

    The decision is made while the person waits at a checkout or online shop and determines whether the payment goes through.

    Write or execution permissions allow the system to change a state within an application. Model responses, tool calls and changes actually executed must therefore be considered separately.

Explore the system design: Select a component to see its task, incoming and outgoing data, and role in the use case. The guided walkthrough explains each phase. Then use Yes, Uncertain and No to represent your specific system variant.

How the system is built

12 review first6 clarify7 baseline threats

InputProcessingResultImpact Externalaccess 31 Input 40 Third-partycontent 00 AI model 11 Providerservice 02 Documentcollection 01 Memory 00 Training andfeedback 30 OtherAI agents 00 Tools andinterfaces 00 Result 00 Business appor equipment 10 person 00 Affectedperson 00 AI serviceswithout approval 01 Externalaccess 31 Input 40 Third-partycontent 00 AI model 11 Providerservice 02 Documentcollection 01 Memory 00 Training andfeedback 30 OtherAI agents 00 Tools andinterfaces 00 Result 00 Business appor equipment 10 person 00 Affectedperson 00 AI serviceswithout approval 01
  • Present
  • Depends on your system
  • Absent
  • Review first
  • To clarify

In this system design: 12 to review first, 6 to clarify, 7 baseline threats.

Architecture as a list

How it differs from similar use cases

Data and information

Input data and information sources

The person initiating the payment determines its amount, recipient, device and location; that person may be a fraudster. Each payment is linked to a card or account, and therefore to a person.

Processing and operating environment

When a bank or merchant uses a payment service provider, the model comes from that provider.

Storage and further use

Payment networks and service providers train their models using payments that pass through them. Chargebacks and manual review results feed back as new training examples.

Results and data sharing

The system stops or rejects high-risk payments before a person sees them.

Using a provider does not automatically determine where processing takes place. Storage location, subcontractors, deletion periods and use for training must be checked for the specific deployment.

Assess risks and determine measures

From understanding the system to analysing risks

  1. Define the system boundary

    Record data, participants, interfaces and permissions. Resolve uncertain characteristics in the model.

  2. Investigate threats

    Relate review candidates to actual data flows: what could happen, and who would be affected?

  3. Assess risk

    Assess impacts and likelihood in the deployment context. The number of review candidates is not a risk score.

  4. Provide evidence of measures

    Select appropriate controls, assign responsibilities and define effectiveness checks. Document residual risks and approvals.

Key threats in the application context

  • 4 particularly important
  • 8 typical
  • 6 depending on the system
  • 7 additional threats for every AI system

A total of 25 threats from the threat catalogue may be relevant to this use case.

Also review: whether the system disadvantages groups

Check whether selection, ranking or assessment disadvantages people with protected characteristics, such as sex, age or origin.

Priority review points

  1. Adversarial Inputs

    Fraudsters use small payments to test what gets through, then adjust the amount, merchant and timing. The model subsequently treats later payments as unremarkable.

  2. Model Drift & Degradation

    New scams, such as transfers following a call from a fake bank employee, differ from learned cases. Detection is poorer until enough new examples are available.

  3. Targeted Poisoning / Label Poisoning

    Customers who report their own purchases as fraud introduce incorrect labels into training data. The model then flags similar legitimate payments or misses genuine fraud.

  4. Excessive Agency

    The system can reject payments without human review. A wrongly configured threshold can stop many legitimate payments in a short time.

8 further review candidates in the typical design

Other relevant threats

  1. Training Data Poisoning

    Your own training or operational feedback can introduce manipulated data into training datasets.

    Listed because of these characteristics

    • Learns from your own data
    • Uses operational feedback
  2. Backdoor ML Model

    Training data or an adopted base model can introduce hidden triggers for misbehaviour.

    Listed because of this characteristic

    • Learns from your own data
  3. Model Theft

    Anyone able to query the model can replicate it through many queries. Internally trained weights can be stolen through network access.

    Listed because of these characteristics

    • Learns from your own data
    • Accessible over a network
  4. Model Denial of Service

    Complex or high-volume inputs can exhaust model computing resources.

    Listed because of this characteristic

    • Accessible over a network
  5. Privacy Attacks

    Targeted queries can recover some personal or protected training data from the model.

    Listed because of these characteristics

    • Processes personal data
    • Processes confidential data
  6. Sensitive Information Disclosure

    Confidential content can appear in answers, supplied context or logs.

    Listed because of these characteristics

    • Processes personal data
    • Processes confidential data
  7. Exfiltration from ML Application

    Protected data can leak through tools, network connections, storage or insiders.

    Listed because of this characteristic

    • Processes confidential data
  8. Application Denial of Service

    A network-accessible application can be overwhelmed by mass requests.

    Listed because of this characteristic

    • Accessible over a network

Up to 6 further threats may apply, depending on your system design. Nine threats need to be reviewed for every AI system. Two of these are particularly important here and are therefore listed above.

System features and open questions

Each Yes adds further threats to your checklist, up to 6 in total. If you cannot yet answer a question, include its threats in your review.

How many threats a Yes adds
  • Added by this Yes

How your system is built

  1. Uses a knowledge graph1 threat
  2. Optimises a specified metric1 threat

How your system is built

Does the system use a knowledge graph storing concepts and their relationships?

Some systems represent accounts, devices and merchants as a network of relationships to detect connected fraud rings.

If yes, add

Is the system intended to maximise a specified metric, such as revenue, utilisation or clicks?

If the deployer sets the threshold according to fraud costs and lost revenue, the system pursues a business objective.

If yes, add

How you operate the system

These questions arise for almost every AI system.

Can people or programs query the model directly, for example through an interface?

If yes, add

Controls and implementation

Measures for the priority review areas are expanded. Each linked measure explains how to implement it.

Controls for the remaining threats are available on their pages in the threat catalogue.

AI Act provisions

Applies to every AI system

Art. 4: AI literacy

Applies if staff or appointed representatives operate or use AI systems.

Applies since 2 February 2025.

Obligations and details for Art. 4: AI literacy
Who bears the obligations
Provider, Deployer, Product manufacturer, Provider of a general-purpose AI model

Detailed obligations

Generally does not apply

Annex III no. 5 point b: Creditworthiness

Annex III, point 5(b), expressly excludes systems intended to detect financial fraud.

Obligations and details for Annex III no. 5 point b: Creditworthiness
The general condition is
Applies if the system assesses people's creditworthiness or establishes their credit scores.
Exception
Systems intended to detect financial fraud.
Who bears the obligations
Provider, Deployer, Product manufacturer

Detailed obligations

Classify your system with the quick checker All obligations in the obligations compass

Cross-cutting threats

Review these threats for every AI system, whatever its purpose.

Why these threats always belong on the checklist

Atypical system features

View 15 further questions

If any of these features does apply to your system, add the listed threats.

Sources

Related use cases

Also in the field of Banking and insurance

Often used together with

Updated: 30 September 2026. Review checklist rules version 0.3.2, threat catalogue version 2026.10.24.2. How these pages are structured