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.
A model assesses each payment for suspected fraud in real time and stops suspicious payments or refers them for review.
Understand the 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 and data flows
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.
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.
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.
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.
12 review first6 clarify7 baseline threats
The diagram shows the typical architecture. Select a component to see what happens there and adapt its features to your system. Enable “Analysis guidance” to see which threats need reviewing for this architecture. The page's checklist continues to describe the typical case.
None yet. Each change will appear here.
In this system design: 12 to review first, 6 to clarify, 7 baseline threats.
External access: Present
Review first
To clarify
Input: Part of every AI system
Review first
Third-party content: Present
AI model: Part of every AI system
Review first
To clarify
Provider service: Depends on your system
To clarify
Document collection: Depends on your system
To clarify
Training and feedback: Present
Review first
Result: Part of every AI system
Baseline for every AI system
Business application or equipment: Present
Review first
person: Part of every AI system
Baseline for every AI system
Affected person: Present
Unapproved AI services: Depends on your system
To clarify
Supply chain and technical foundations: 5 baseline threats applying to every AI system
Baseline for every AI system
Money laundering detection and sanctions screening
Searches across many entries for money laundering and checks parties against sanctions lists
Credit scoring and creditworthiness assessment
Assesses a person's ability to repay rather than individual payments
AI-based cyberattack detection
Detects compromised accounts and phishing in networks and emails
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.
When a bank or merchant uses a payment service provider, the model comes from that provider.
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.
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
Record data, participants, interfaces and permissions. Resolve uncertain characteristics in the model.
Relate review candidates to actual data flows: what could happen, and who would be affected?
Assess impacts and likelihood in the deployment context. The number of review candidates is not a risk score.
Select appropriate controls, assign responsibilities and define effectiveness checks. Document residual risks and approvals.
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.
Fraudsters use small payments to test what gets through, then adjust the amount, merchant and timing. The model subsequently treats later payments as unremarkable.
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.
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.
The system can reject payments without human review. A wrongly configured threshold can stop many legitimate payments in a short time.
Your own training or operational feedback can introduce manipulated data into training datasets.
Listed because of these characteristics
Training data or an adopted base model can introduce hidden triggers for misbehaviour.
Listed because of this characteristic
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
Complex or high-volume inputs can exhaust model computing resources.
Listed because of this characteristic
Targeted queries can recover some personal or protected training data from the model.
Listed because of these characteristics
Sensitive Information Disclosure
Confidential content can appear in answers, supplied context or logs.
Listed because of these characteristics
Exfiltration from ML Application
Protected data can leak through tools, network connections, storage or insiders.
Listed because of this characteristic
A network-accessible application can be overwhelmed by mass requests.
Listed because of this characteristic
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.
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 your system is built
How you operate the system
Some systems represent accounts, devices and merchants as a network of relationships to detect connected fraud rings.
If yes, add
If the deployer sets the threshold according to fraud costs and lost revenue, the system pursues a business objective.
If yes, add
These questions arise for almost every AI system.
If yes, add
If yes, add
If yes, add
If yes, add
If yes, add
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.
Applies if staff or appointed representatives operate or use AI systems.
Applies since 2 February 2025.
Detailed obligations
Annex III, point 5(b), expressly excludes systems intended to detect financial fraud.
Detailed obligations
Classify your system with the quick checker All obligations in the obligations compass
Review these threats for every AI system, whatever its purpose.
If any of these features does apply to your system, add the listed threats.
Does the system generate its own text, such as answers, drafts or summaries?
The system produces a risk score and a decision, rather than text.
If yes, add
Does the system generate or edit images, sounds, voices or videos?
If yes, add
Does the system create new content from open-ended requests that people read, see or hear directly? Translation, reading aloud and transcription do not count.
If yes, add
Can users give the system natural language tasks that it then performs?
The model assesses payment data and does not accept natural language instructions.
If yes, add
Does the system search its own collection of documents or records for relevant content?
If yes, add
Does the system formulate answers from retrieved documents?
If yes, add
Does the system remember content from earlier conversations or tasks and reuse it later?
If yes, add
Does the system call other programs, interfaces or search services itself, even if only to read?
If yes, add
Does the system determine its next steps itself based on earlier results?
If yes, add
Does the system delegate tasks to other AI agents or incorporate their results?
If yes, add
Is the system connected to tools or data sources through the Model Context Protocol (MCP)?
If yes, add
Do documents from several customers, departments or permission groups share one search store?
If yes, add
Does the system process several input types together, such as text with images or speech?
If yes, add
Does the system generate code, scripts or database queries for further use?
If yes, add
Does the system execute programs, scripts or commands itself?
If yes, add
Visa, Visa Prevents Approximately $25 Billion in Fraud Using Artificial Intelligence, 17 June 2019 According to the deployer
Visa describes using AI to assess all VisaNet authorisations in real time.
Stripe, Radar: Risk evaluation (documentation) According to the deployer
Stripe describes machine learning models that assess each payment's risk in real time.
EBA, Follow-up report on machine learning for IRB models, 2023
The European Banking Authority identifies fraud detection as a major use of machine learning in banking.
BaFin lists fraud detection among the most common AI uses in finance.
Updated: 30 September 2026. Review checklist rules version 0.3.2, threat catalogue version 2026.10.24.2. How these pages are structured