Within Use Cases

Why Fraud AI Still Needs Appeals

Fraud models can stop stolen-card transactions, but false alarms need clear review routes when real customers are affected.

On this page

  • How transaction risk scoring works in everyday payments
  • The value and cost of blocking suspicious activity
  • Why appeals, monitoring and escalation matter
Preview for Why Fraud AI Still Needs Appeals

Introduction

Fraud-detection AI is one of the most widely used forms of artificial intelligence in everyday life. Every time a card is tapped, a transfer is initiated, or an online purchase is attempted, machine-learning systems may assess whether the activity resembles normal customer behaviour or known fraud patterns. These systems can stop stolen-card transactions in milliseconds and prevent large financial losses. However, the same systems can also make mistakes. A genuine customer travelling abroad, buying an unusually expensive item, or using a new device may be treated as suspicious. That is why effective fraud prevention depends not only on accurate AI models but also on clear appeal routes, human review, and ongoing monitoring of errors. AI can identify risk, but institutions still need governance processes for the people affected by incorrect decisions. [LSEG+2Mastercard]lseg.comFraud Detection in FinanceFraud Detection in Finance - GlossaryLearn how fraud detection protects against financial crimes using methods like AI, KYC, and AML…

Fraud Flags illustration 1

How Transaction-Risk Scoring Works in Everyday Payments

Modern fraud systems rarely rely on a single rule such as “block all foreign transactions”. Instead, they evaluate many signals at once and generate a risk score. Payment providers describe these systems as analysing transaction history, merchant characteristics, spending patterns, device information, location data, behavioural indicators and relationships between entities across payment networks. Transactions assessed as low risk are approved, while higher-risk transactions may trigger extra verification or be declined. [Visa Corporate+3Mastercard+3Mastercard]mastercard.comDecision Intelligence for Fraud and Risk Management Precise, real-time decisioningMake better approve/decline decisions with intelligence designed to increase accuracy and precision of fraud detection.Read more

The goal is not merely to detect known fraud. Machine-learning models are designed to identify unusual combinations of signals that may indicate account takeover, stolen cards, synthetic identities or other emerging threats. Compared with older rule-based approaches, AI systems can adapt more quickly when fraudsters change tactics. Mastercard states that its Decision Intelligence platform uses AI-based risk assessment in real time, while Visa similarly emphasises machine learning as a way to improve fraud detection and reduce unnecessary declines. [Mastercard+2Mastercard]mastercard.comDecision Intelligence for Fraud and Risk Management Precise, real-time decisioningMake better approve/decline decisions with intelligence designed to increase accuracy and precision of fraud detection.Read more

Research on payment authentication systems also shows how seemingly ordinary changes can affect risk assessments. Studies of 3-D Secure payment systems found that factors such as transaction location, device characteristics and transaction value can substantially alter the likelihood of a challenge, decline or card block. This illustrates why legitimate customers sometimes encounter unexpected payment interruptions even when no fraud is occurring. [arXiv]arxiv.orgarXiv Investigation of 3-D Secure's Model for Fraud DetectionInvestigation of 3-D Secure's Model for Fraud DetectionSeptember 25, 2020…Published: September 25, 2020

The Value and Cost of Blocking Suspicious Activity

The benefit of fraud AI is straightforward: preventing criminals from stealing money. Financial institutions face enormous volumes of fraudulent activity, and manual review alone cannot operate at the speed required for modern payments. AI systems can screen transactions in fractions of a second and identify patterns across millions or billions of payment events. [Mastercard+2LSEG]mastercard.comUnlike traditional ruleAI is helping banks save millions by transforming payment…6 Feb 2026 — AI improves payment fraud detection by quickly analyz…

Yet every fraud system faces a trade-off between catching fraud and avoiding false alarms. If thresholds are too permissive, more fraudulent transactions succeed. If thresholds are too strict, legitimate customers are blocked. The latter problem is often called a false decline.

False declines create costs beyond temporary inconvenience. Customers may be unable to complete purchases, access services, or make urgent payments. Merchants lose sales, and financial institutions may damage trust with their customers. Industry discussions increasingly treat false declines as a governance problem as well as a technical one because the burden falls on real people whose transactions were legitimate. Mastercard and Visa both describe reducing false positives as a major objective of modern fraud AI. [Visa Corporate+2Mastercard]corporate.visa.comVisa CorporateThe future of fraud detection: smarter, faster, safer | VisaDiscover how AI and machine learning are reshaping fraud detect…

Concrete examples show why this matters. In the retail sector, AI-driven fraud tools have been introduced specifically to recover transactions previously rejected by older systems. One reported deployment recovered millions of dollars in legitimate orders by replacing rigid approve-or-decline decisions with more nuanced risk assessments and additional verification pathways. [Business Insider]businessinsider.comThese older systems often incorrectly decline legitimate transactions, leading to lost revenue and customer dissatisfaction. TickPick, an…

The broader lesson is that successful fraud prevention is not measured solely by fraud losses avoided. It must also be judged by how many genuine customers can continue using payment systems without unnecessary interruption. [Mastercard+2FinTech Futures]mastercard.comHow AI driven fraud solutions and payment optimization…3 days ago — Static or overly constrictive fraud controls can block l…

Why Appeals, Monitoring and Escalation Matter

A blocked payment is often a high-impact decision. Unlike many digital recommendations, it can affect a person’s ability to purchase goods, travel, pay bills or access funds. For that reason, governance frameworks increasingly emphasise review mechanisms alongside automated detection.

An effective appeal process typically provides several layers of protection:

  • Immediate customer notification when a transaction is blocked or challenged.
  • Alternative verification methods, such as one-time codes or identity checks.
  • Access to human support staff when automated checks cannot resolve the issue.
  • Escalation procedures for repeated or high-value disputes.
  • Monitoring systems that track error rates and patterns of false declines.

These safeguards recognise that risk scores are probabilistic judgments rather than proofs of fraud. Even highly accurate systems will produce some incorrect outcomes because fraud detection involves predicting uncertain behaviour. [LSEG]lseg.comFraud Detection in FinanceFraud Detection in Finance - GlossaryLearn how fraud detection protects against financial crimes using methods like AI, KYC, and AML…

Regulators have increasingly focused on accountability when automated systems influence financial decisions. In the United States, the Consumer Financial Protection Bureau has repeatedly stated that institutions cannot avoid explanation and accountability requirements simply because complex algorithms or AI models are involved. Where adverse decisions are made, organisations remain responsible for providing meaningful reasons and complying with consumer-protection obligations. Consumer Financial Protection Bureau+2Consumer Financial Protection Bureau [consumerfinance.gov]consumerfinance.govinnovation spotlight providing adverse action notices when using ai ml modelsConsumer Financial Protection BureauProviding adverse action notices when using AI/ML modelsJul 7, 2020 — This blog conveys an incomplete…

In the United Kingdom, regulators reviewing anti-fraud controls have likewise stressed complaint handling, governance and continuous improvement rather than treating fraud technology as a complete solution on its own. Fraud prevention systems are expected to be supported by oversight, customer support processes and mechanisms for correcting mistakes. [FCA]fca.org.ukOctober 30, 2023 — 7 Nov 2023 — This publication sets out the key findings from our review of how firms mitigate the risks of APP fraud a…Published: October 30, 2023

Fraud Flags illustration 2

When Fraud Models Get Things Wrong

False positives are not unique to financial services. Across many sectors, fraud and risk algorithms sometimes flag large numbers of legitimate cases. One widely reported example involved a UK government fraud-detection system that incorrectly identified many legitimate benefit claims for investigation, demonstrating how predictive systems can generate significant numbers of unnecessary reviews when deployed at scale. [The Guardian]theguardian.comOfficial figures, revealed through freedom of information laws, indicate that two-thirds of these flagged claims were legitimate. Consequ…

The existence of such errors does not mean fraud AI is ineffective. Rather, it highlights the importance of measuring performance beyond raw detection rates. Institutions need to know:

  • How often genuine customers are incorrectly blocked.
  • Whether certain groups experience higher false-positive rates.
  • How quickly appeals are resolved.
  • Whether customers receive understandable explanations.
  • Whether human reviewers can override incorrect automated outcomes.

Without these measurements, organisations may overestimate the success of fraud systems while underestimating the customer harm caused by mistakes. [Consumer Financial Protection Bureau+2FCA]consumerfinance.govinnovation spotlight providing adverse action notices when using ai ml modelsConsumer Financial Protection BureauProviding adverse action notices when using AI/ML modelsJul 7, 2020 — This blog conveys an incomplete…

The Governance Challenge Behind Fraud Flags

As fraudsters increasingly use AI themselves—including sophisticated impersonation techniques, automated scam campaigns and synthetic identities—financial institutions face pressure to strengthen detection capabilities. Recent UK fraud reporting has highlighted growing concerns about AI-enabled scams and the scale of financial losses they can generate. [The Guardian]theguardian.comNearly 15,000 scams were reported, often involving false opportunities in gold, property, cryptocurrencies, carbon credits, and wine. Cri…

This pressure can encourage more aggressive fraud controls, but stronger detection alone is not enough. The central governance challenge is balancing security with fairness. A system that approves every transaction would eliminate false declines but invite fraud. A system that blocks every unusual transaction would reduce fraud but create unacceptable disruption for legitimate users.

The practical solution is neither complete automation nor complete reliance on human judgement. Instead, modern fraud programmes increasingly combine AI-based risk scoring with appeals processes, human escalation, performance monitoring and accountability requirements. The strongest systems treat a fraud flag as the beginning of a review process rather than the final word on whether a customer should be able to access their money. Consumer Financial Protection Bureau+3Mastercard+3Visa Corporate [mastercard.com]mastercard.comUnlike traditional ruleAI is helping banks save millions by transforming payment…6 Feb 2026 — AI improves payment fraud detection by quickly analyz…

Fraud Flags illustration 3

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Endnotes

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    Title: Fraud Detection in Finance
    Link: https://www.lseg.com/en/risk-intelligence/glossary/financial-crime/fraud-detection
    Source snippet

    Fraud Detection in Finance - GlossaryLearn how fraud detection protects against financial crimes using methods like AI, KYC, and AML...

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    Title: Unlike traditional rule
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    AI is helping banks save millions by transforming payment...6 Feb 2026 — AI improves payment fraud detection by quickly analyz...

  3. Source: corporate.visa.com
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    Visa CorporateThe future of fraud detection: smarter, faster, safer | VisaDiscover how AI and machine learning are reshaping fraud detect...

  4. Source: mastercard.com
    Link: https://www.mastercard.com/sg/en/[business
    Source snippet

    Make better approve/decline decisions with intelligence designed to increase accuracy and precision of fraud detection.Read more...

  5. Source: mastercard.com
    Link: https://www.mastercard.com/us/en/business/cybersecurity-fraud-prevention/risk-decisioning/decision-intelligence.html
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    Make better approve/decline decisions with intelligence designed to increase accuracy and precision of fraud detection.Read more...

  6. Source: arxiv.org
    Title: arXiv Investigation of 3-D Secure’s Model for Fraud Detection
    Link: https://arxiv.org/abs/2009.12390
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    Investigation of 3-D Secure's Model for Fraud DetectionSeptember 25, 2020...

    Published: September 25, 2020

  7. Source: mastercard.com
    Link: https://www.mastercard.com/global/en/business/payments/merchant-cloud/insights/ai-optimization.html
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    How AI driven fraud solutions and payment optimization...3 days ago — Static or overly constrictive fraud controls can block l...

  8. Source: fca.org.uk
    Link: https://www.fca.org.uk/publications/multi-firm-reviews/anti-fraud-controls-complaint-handling-firms-focus-app-fraud
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    October 30, 2023 — 7 Nov 2023 — This publication sets out the key findings from our review of how firms mitigate the risks of APP fraud a...

    Published: October 30, 2023

  9. Source: mastercard.com
    Link: https://www.mastercard.com/in/en.html
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    A global technology company in the payments...We connect and power a digital economy that benefits individuals, enterprises...

  10. Source: mastercard.com
    Link: https://www.mastercard.com/global/en.html
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    A global technology company in the payments industryWe connect and power a digital economy that benefits people, businesses and governmen...

  11. Source: mastercard.com
    Title: US | Mastercard
    Link: https://www.mastercard.com/us/en.html
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    Mastercard US | Mastercard - A global technology company in...We connect and power a digital economy that benefits people, businesses an...

  12. Source: mastercard.com
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    By modernising payments, improving access to capital and providing innovative, digital services, Mastercard empowers SMEs to build...Re...

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    mastercard.comMastercardWe're sorry but choose_shop doesn't work properly without JavaScript enabled. Please enable it to continue. Manag...

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    Link: https://www.mastercard.com/content/dam/mccom/shared/business/b2b/reports/decision-intelligence-beyond-mastercard-playbook.pdf
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    Differentiated insights.Read more...

  15. Source: youtube.com
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    Mastercard accelerates card fraud detection with [generative AI]({{ 'generative-ai/' | relative_url }}) technology...

  16. Source: youtube.com
    Title: Mastercard accelerates card fraud detection with generative AI technology
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    AI fraud detection false positives false declines payment processing Mastering Financial Fraud Detection: Reducing False Positives with A...

  17. Source: businessinsider.com
    Link: https://www.businessinsider.com/mastercard-ai-credit-card-fraud-detection-protects-consumers-2025-5
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    AI-driven solutions have been part of Mastercard's security tools for over a decade, with the current systems analyzing up to 160 billion...

  18. Source: fintechfutures.com
    Link: https://www.fintechfutures.com/ai-in-fintech/mastercard-battles-fraud-false-declines-with-ai-based-tool
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    Mastercard Battles Fraud, False Declines with AI-Based ToolMastercard is employing artificial intelligence to improve the accuracy of rea...

  19. Source: businessinsider.com
    Link: https://www.businessinsider.com/riskified-ai-fraud-detection-tickpick-falsely-declined-transactions-2025-7
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    These older systems often incorrectly decline legitimate transactions, leading to lost revenue and customer dissatisfaction. TickPick, an...

  20. Source: consumerfinance.gov
    Title: innovation spotlight providing adverse action notices when using ai ml models
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    Consumer Financial Protection BureauProviding adverse action notices when using AI/ML modelsJul 7, 2020 — This blog conveys an incomplete...

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    Consumer Financial Protection BureauConsumer Financial Protection Circular 2022-03May 26, 2022 — ECOA and Regulation B require creditors...

    Published: May 26, 2022

  22. Source: theguardian.com
    Link: https://www.theguardian.com/society/article/2024/jun/23/dwp-algorithm-wrongly-flags-200000-people-possible-fraud-error
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    Official figures, revealed through freedom of information laws, indicate that two-thirds of these flagged claims were legitimate. Consequ...

  23. Source: theguardian.com
    Link: https://www.theguardian.com/money/2026/jun/15/investment-fraud-uk-more-than-220m-lost-last-year-scams-ai
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    Nearly 15,000 scams were reported, often involving false opportunities in gold, property, cryptocurrencies, carbon credits, and wine. Cri...

  24. Source: consumerfinance.gov
    Title: CFP B Acts to Protect the Public from Black-Box Credit Models Using
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    CFPB Acts to Protect the Public from Black-Box Credit Models Using...May 26, 2022 — Companies relying on complex algorithms must provide...

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    결제 분야의 글로벌 기술 선도 기업우리는 안전하고 간편하며 손쉽게 접근 가능한 결제를 통해 전 세계 소비자, 사업자 및 정부에 도움이 되는 포용적인 디지털 경제를 연결하고 이끌어가고 있습니다...

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    CFPB Orders Wells Fargo to Pay $3.7 Billion for...Dec 20, 2022 — CFPB is ordering Wells Fargo Bank to pay more than $2 billion in redres...

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    Mastercard ConnectMastercard Connect is designed to help our partners—business customers like you. Whether you're an issuer, acquirer, se...

  32. Source: mastercardservices.com
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    Fight Fraud With Real-Time, Product-Level DataAnd since many fraud tools incorporate artificial intelligence, they improve their accuracy...

  33. Source: mastercardbelgium.prezly.com
    Title: mastercard rolls out artificial intelligence across its global network
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    alone, the value of false declines is more than 13 times the total amount lost to actual card fraud,” said Al Pascual, senior vice...Rea...

  34. Source: GOV.UK
    Title: www.gov.uk PSF A Standards
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    Published: May 2025

Additional References

  1. Source: riddlecompliance.com
    Link: https://riddlecompliance.com/ai-and-consumer-finance-how-cfpb-is-regulating-emerging-tech/
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    AI and Consumer Finance: How CFPB Is Regulating...Explore how AI impacts consumer finance and what CFPB is doing to ensure fairness, tra...

  2. Source: jonesday.com
    Link: https://www.jonesday.com/en/insights/2023/10/cfpb-issues-aiinvolved-adverse-actions-guidance
    Source snippet

    CFPB Issues AI-Involved Adverse Actions GuidanceThe CFPB issued guidance for creditors that utilize AI and related complex modelling in t...

  3. Source: consumercouncil.org.uk
    Link: https://www.consumercouncil.org.uk/
    Source snippet

    Consumer Council for Northern IrelandWe are the statutory consumer body for Northern Ireland. We provide advice and information, investig...

  4. Source: ukfinance.org.uk
    Link: https://www.ukfinance.org.uk/events-training/lessons-in-building-best-in-class-fraud-solution
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    Lessons in Building a Best-in-Class Fraud SolutionJoin us for an insightful webinar, where we delve into the critical strategies and inno...

  5. Source: ofcom.org.uk
    Link: https://www.ofcom.org.uk/siteassets/resources/documents/consultations/category-1-10-weeks/consultation-online-safety—additional-safety-measures/responses/uk-finance.pdf?v=409245
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    UK FinanceThere is no modelling of false positives or appeals, while it mentions that once content that is detected to be illegal but aft...

  6. Source: consumerfinancialserviceslawmonitor.com
    Link: https://www.consumerfinancialserviceslawmonitor.com/2023/09/cfpb-calls-for-increased-specificity-and-accuracy-on-reasons-for-credit-denials-when-lenders-employ-artificial-intelligence/
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    Consumer Financial Services Law MonitorCFPB Calls for Increased Specificity and Accuracy on...Sep 20, 2023 — The CFPB makes clear in thi...

  7. Source: consumerfinancemonitor.com
    Link: https://www.consumerfinancemonitor.com/2023/09/20/cfpb-revisits-adverse-action-notice-requirements-when-using-artificial-intelligence-or-complex-credit-models/
    Source snippet

    CFPB Revisits Adverse Action Notice Requirements When...Sep 20, 2023 — The CFPB issued Circular 2022-3 addressing Equal Credit Opportuni...

  8. Source: nascus.org
    Link: https://www.nascus.org/cfpb-summaries__trashed/circular-2023-03-adverse-action-notification-requirements-and-the-proper-use-of-the-cfpbs-sample-forms-provided-in-regulation-b/
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    Circular 2023-03: Adverse Action Notification Requirements and the...When using artificial intelligence or complex credit models, may cr...

  9. Source: goodwinlaw.com
    Link: https://www.goodwinlaw.com/en/insights/blogs/2024/03/interpretable-algorithms-as-a-potential-solution-to-cfpbs-guidance-on-ai-driven-credit-denials
    Source snippet

    Interpretable Algorithms as a Potential Solution to CFPB's...28 Mar 2024 — The Consumer Financial Protection Bureau (CFPB) issued guidan...

  10. Source: reuters.com
    Link: https://www.reuters.com/business/finance/britains-banks-see-fraud-cases-spike-after-refund-rules-take-effect-2026-06-14/
    Source snippet

    This follows the UK's October 2024 implementation of rules mandating reimbursement of up to £85,000 for APP fraud victims, making it the...

    Published: October 2024

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