Money leaves or fails to arrive
Double charges, lost refunds, wrong amounts, orphan orders, failed payouts.
Severity: money. Attached to 22 of 46 published product types, backed by 31 evidence records.
Product types that carry it
| Product type | Grade | Note for this type | Evidence |
|---|---|---|---|
| mobile banking app | primary | A debit card purchase approved against an available balance settles later and the current account is charged an overdraft fee it should not carry. | |
| neobank | primary | A customer closes the account in the app and the remaining balance is not sent to their external bank within the promised window. | |
| peer-to-peer payment app | primary | The recipient sees a friend's payment as available to cash out, then the app freezes or reverses it after review, after the recipient has already spent it. | |
| crypto exchange | primary | Attackers steal customer coins from the exchange's hot or multisig wallets, or an account flagged to skip liquidation runs a negative balance on customer assets. | |
| lending platform | primary | Autopay pulls a repayment from a bank account the borrower never authorized, or still debits on a date the borrower was granted an extension. | |
| buy now pay later service | primary | A merchant refunds a returned item, but the remaining instalments stay scheduled and autopay keeps collecting them from the shopper's card. | |
| stock trading app | primary | A market order is silently converted to a limit order and cancelled, so the customer re-enters it later at a worse fill price, or instant deposit buying power is traded before the ACH pull is returned and the broker carries the loss. | |
| insurance app | primary | Policyholders are overcharged at renewal until a complaint reaches the regulator, and the carrier pays restitution on every affected policy. | |
| expense management tool | secondary by design analysis | A departed employee's corporate card keeps working because offboarding does not freeze it, and the company carries the charges under its card agreement. | |
| telemedicine app | primary | A patient asks to cancel the monthly care membership in the app, the cancellation runs through several steps, and the card is charged for next month's visits while the request is pending. | |
| mental health app | primary | A user in a hard week tries to cancel the therapy subscription, the cancel path takes several steps, and the next month is charged while the request is still pending. | |
| ecommerce store | primary | A cancelled out-of-stock order is closed with store credit instead of the card refund the shopper is owed. | |
| subscription box service | primary | A subscriber tries to cancel online in the channel used to sign up, the flow hides or blocks the cancellation, and the next box is charged and shipped. | |
| grocery delivery app | primary | A shopper who reports a late grocery delivery gets a small credit toward the next basket when the guarantee promised a full refund. | |
| travel booking app | primary | The airline cancels a flight sold by the app as merchant of record, the airline holds the fare, and the traveller's refund waits on a transfer the app never chases. | |
| loyalty program app | primary | Points a member already earned lose redemption value after a rule change, or a stored value card linked to the rewards account is drained. | |
| ERP system | secondary | A payroll module run on the ERP pays employees the wrong amount, or nothing. | |
| EV charging app | secondary by design analysis | A session the charger ends early still bills the full pre-authorised amount, or a stop tap that never reaches the charger keeps billing per kWh. | |
| dating app | primary | A member who disputes a premium renewal with the bank is banned and loses the subscription period already paid for. | |
| mobile game | primary | A child taps a confusingly placed purchase button and the saved card is charged for in-game currency without a parent's consent. | |
| language learning app | secondary by design analysis | A learner's free trial rolls into a yearly plan with no in-app cancel path, or a family plan seat keeps billing after the owner removed that member. | |
| kids app | primary | A child taps buy on gems right after a parent typed the password, and the parent is charged for purchases they never approved. |
Tests that address it
- integration tests: mandatory for this risk on 7 product types.
- end-to-end functional tests: mandatory for this risk on 12 product types.
- data integrity and migration testing: mandatory for this risk on 10 product types.
- compliance checks: mandatory for this risk on 1 product types.
- penetration testing: mandatory for this risk on 2 product types.
- unit tests: mandatory for this risk on 7 product types.
- release smoke tests: mandatory for this risk on 9 product types.
- payment and money-flow testing: mandatory for this risk on 17 product types.
- contract tests: mandatory for this risk on 1 product types.
- regression suite: mandatory for this risk on 1 product types.
- resilience and failure testing: mandatory for this risk on 1 product types.
- exploratory testing: mandatory for this risk on 1 product types.
Evidence
ev-0001store-guidelineprimary
App Review Guidelines, Apple
Apple reviews every iOS, iPadOS and macOS App Store submission against these guidelines, including crashes and bugs at review, privacy disclosures, in-app purchase rules and extra rules for medical, financial and kids apps, and apps with user-generated content must let users report offensive content and block abusive users (guideline 1.2), and apps offering loot boxes or similar mechanisms must disclose the odds of each item type before purchase (guideline 3.1.1).
published undated · verified 2026-10-07
ev-0026regulatorprimary
Electronic Fund Transfers (Regulation E), Consumer Financial Protection Bureau
Regulation E sets error resolution and liability rules for consumer electronic fund transfers, so wrong or unauthorised transfers must be investigated and corrected.
published undated · verified 2026-10-07
ev-0049regulatorprimary
Buy Now, Pay Later: Market trends and consumer impacts, Consumer Financial Protection Bureau
Consumer complaints to the CFPB indicate that returns and disputes are a common concern.
Supports money-loss and regulatory-penalty for a BNPL service: the regulator's market report on pay-in-four lenders records complaints about continued instalment payments on disputed items, and lists required autopay and borrower overextension among consumer risks.
published 2022-09-15 · verified 2026-10-07
ev-0050regulatorprimary
CFPB Takes Action to [...] Consumers Can Dispute Charges and Obtain Refunds on Buy Now, Pay Later Loans, Consumer Financial Protection Bureau
Supports money-loss for a BNPL service: the regulator reports that a notable share of BNPL purchases involve a return or dispute and that refunds must be credited to the borrower's plan. The page is marked archived; it is cited for the observed failure, not for the current legal status of the interpretive rule.
published 2024-05-22 · verified 2026-10-07
ev-0064regulatorprimary
North Korea Responsible for [amount] Bybit Hack (Alert Number I-022625-PSA), Federal Bureau of Investigation, Internet Crime Complaint Center
FBI public service announcement attributing the theft of virtual assets from a cryptocurrency exchange to a state-backed group, with stolen assets laundered across many addresses. Supports money-loss for crypto exchanges that hold customer assets in hot or multisig wallets.
published 2025-02-26 · verified 2026-10-07
ev-0065court-or-fineprimary
SEC Charges Samuel Bankman-Fried with Defrauding Investors in Crypto Asset Trading Platform FTX, U.S. Securities and Exchange Commission
SEC complaint alleging a crypto trading platform diverted customer funds to an affiliated trading firm and exempted that firm from key platform risk controls. Supports money-loss for crypto exchanges where account-level exceptions to margin and liquidation rules let customer assets leave.
published 2022-12-13 · verified 2026-10-07
ev-0071regulatorprimary
Fashion Nova Will Pay [amount] for Consumer Refunds To Settle FTC Charges It Violated Rules On Shipping, Refunds, U.S. Federal Trade Commission
A single-merchant online fashion store was charged under the Mail Order Rule for not sending shipping-delay notices with a cancel option and for issuing gift cards instead of refunds on unshipped items, both order-flow behaviours of an ecommerce store. A subscription box ships ordered merchandise under the same rule, so a late box needs the same delay notice and refund.
published 2020-04-21 · verified 2026-10-07
ev-0083regulatorprimary
§ 1026.12 Special credit card provisions., Consumer Financial Protection Bureau
General requirement for money-loss on an expense management tool that issues corporate cards: the consumer cap on unauthorized-use liability can be contracted away for employee card programs, so spend on a lost or misused employee card can fall on the company.
published undated · verified 2026-10-07
ev-0089regulatorprimary
Instacart to Pay [amount] in Consumer Refunds to Settle FTC Lawsuit Over Allegations it Engaged in Deceptive Tactics, Federal Trade Commission
Consumers who experience late deliveries or unprofessional service typically are not offered full refunds and instead are given only a small credit that can be used toward a future order.
Federal settlement with a grocery delivery service over a free delivery claim with undisclosed mandatory service fees, a satisfaction guarantee that paid credits instead of refunds, and membership charges after free trials without consent. Supports regulatory-penalty and money-loss for a grocery delivery app.
published 2025-12-18 · verified 2026-10-07
ev-0095court-or-fineprimary
Official Order of the Texas Commissioner of Insurance No. 2026-10013 (Occidental Fire & Casualty Company of North Carolina), Texas Department of Insurance
Through review of a consumer complaint, the department discovered that a data loading error resulted in Occidental charging rates different than those on file.
Supports data-corruption and money-loss for an insurance app: a data translation error in insurance scores fed the rating engine, renewals were charged rates different from the filed rates, and the insurer owed restitution.
published 2026-07-08 · verified 2026-10-07
ev-0096court-or-fineprimary
Official Order of the Texas Commissioner of Insurance No. 2026-10039 (Germania Companies), Texas Department of Insurance
Supports data-corruption and money-loss for an insurance app: a data loading error made the rating system use incorrect data to calculate auto renewal premiums, producing overcharges and undercharges that required restitution.
published 2026-07-21 · verified 2026-10-07
ev-0098court-or-fineprimary
Enova International, Inc. (2023 enforcement action), Consumer Financial Protection Bureau
The Bureau found that Enova violated the 2019 Order and the CFPA, including by debiting or attempting to debit consumers' accounts without their authorization.
Supports money-loss for a lending platform: an online lender debited borrower bank accounts the borrowers had not authorized and failed to honor loan extensions it had granted, so repayment debits must follow the stored authorization and extension state.
published 2023-11-15 · verified 2026-10-07
ev-0103regulatorprimary
Consumer Financial Protection Circular 2024-07: Design, marketing, and administration of credit card rewards programs, Consumer Financial Protection Bureau
The circular treats reducing the value of rewards already earned, and point conversions after a merger that lose value, as possible unfair or deceptive practices. Written for card rewards; it transfers to any points program where earned balances carry value, so it supports money-loss, data-corruption and regulatory-penalty for loyalty program apps.
published 2024-12-18 · verified 2026-10-07
ev-0106court-or-fineprimary
Attorney General James Gets Dunkin' to Fill Holes in Security, Reimburse Hacked Customers, Office of the New York State Attorney General
An attacker that gained access to one of these accounts would have been able to use the DD card to make purchases, or remove the card from the account and sell it online.
Settlement after credential stuffing took over rewards app accounts holding stored value cards, which attackers spent or resold. Supports fraud-abuse and money-loss for loyalty program apps that hold stored value or redeemable balances.
published 2020-09-15 · verified 2026-10-07
ev-0115court-or-fineprimary
Wells Fargo Bank, N.A. (CFPB enforcement action, 2022), Consumer Financial Protection Bureau
CFPB order finding the bank charged overdraft fees when the account had enough funds at authorisation and froze accounts on suspected fraud when lesser restraints were available. Supports money-loss for a bank account app where available balance, holds and fees are shown and charged.
published 2022-12-20 · verified 2026-10-07
ev-0119court-or-fineprimary
Chime Financial, Inc. (CFPB enforcement action), Consumer Financial Protection Bureau
CFPB order against a fintech offering accounts through partner banks for failing to refund remaining balances to customers who closed their accounts within the promised window. Supports money-loss for the neobank account closure flow.
published 2024-05-07 · verified 2026-10-07
ev-0122court-or-fineprimary
PayPal Settles FTC Charges that Venmo Failed to Disclose Information to Consumers About the Ability to Transfer Funds and Privacy Settings; Violated Gramm-Leach-Bliley Act, U.S. Federal Trade Commission
FTC settlement over a P2P app that told users received money was available to transfer while it could still be frozen or removed after review, shared transactions publicly by default, and did not notify users of password or new device changes. Supports money-loss, data-breach and fraud-abuse for P2P payment apps.
published 2018-02-27 · verified 2026-10-07
ev-0142regulatorprimary
Proposed FTC Order will Prohibit Telehealth Firm Cerebral from Using or Disclosing Sensitive Data for Advertising Purposes, and Require it to Pay [amount], U.S. Federal Trade Commission
The FTC complaint describes pharmacy and prescription information sent to third parties through tracking tools, a patient portal access method that exposed medications to other patients, a failure to block former employees from accessing medical records, and a cancel-anytime promise contradicted by a multi-step, often multi-day cancellation process during which consumers kept being charged. The first two transfer to pharmacy delivery apps; the cancellation finding transfers to any recurring subscription sold online.
published 2024-04-15 · verified 2026-10-07
ev-0169regulatorprimary
FTC Secures Historic [amount] Settlement Against Amazon, U.S. Federal Trade Commission
The process cannot be difficult, costly, or time-consuming and must be available using the same method that consumers used to sign up.
The FTC settled charges that a retailer enrolled shoppers in a paid recurring membership through confusing checkout screens and made cancellation hard; the order sets the enrolment-consent and same-channel cancellation rules any recurring delivery subscription is tested against.
published 2025-09-25 · verified 2026-10-07
ev-0182court-or-fineprimary
Robinhood Financial provided customers with inaccurate or incomplete disclosures regarding its practice of 'collaring' market orders by converting them to limit orders.
Supports money-loss and regulatory-penalty for a stock trading app: market orders converted to limit orders were cancelled, customers re-entered them at worse prices and the firm paid restitution for the order-handling behavior it had not disclosed.
published 2025-03-07 · verified 2026-10-07
ev-0185regulatorprimary
Regulatory Notice 21-14, FINRA
The malicious actor will then submit a request to the firm to request an ACH transfer (or "pull") from the linked bank account while also using the "instant funds" to immediately place orders to buy securities.
Supports fraud-abuse and money-loss for a stock trading app: instant buying power granted before a linked-bank ACH pull settles lets a fraudster trade and withdraw before the deposit is returned, leaving the broker with the loss.
published 2021-03-25 · verified 2026-10-07
ev-0186regulatorprimary
14 CFR 260.6: Refunds for Airline Fare and Ancillary Service Fees (cancelled, delayed or changed flights), U.S. Department of Transportation (14 CFR Part 260, text via Cornell Legal Information Institute)
Federal refund rule for cancelled or significantly changed flights: when a ticket agent is the merchant of record, the airline must tell the agent the traveller's refund eligibility and transfer the funds so the agent can refund. Supports money-loss for a travel booking app that sells flights.
published undated · verified 2026-10-07
ev-0216regulatorprimary
FTC Sues Owner of Online Dating Service Match.com for Using Fake Love Interest Ads To Trick Consumers into Paying for a Match.com Subscription, Federal Trade Commission
Millions of contacts that generated Match's 'You caught his eye' notices came from accounts the company had already flagged as likely to be fraudulent.
Supports fraud-abuse for a dating app: messages and likes from accounts already flagged as fraudulent were used to sell subscriptions. Also supports money-loss: members who disputed charges with their bank were banned from the paid service.
published 2019-09-25 · verified 2026-10-07
ev-0233regulatorsecondary
Lessons Learned from the Transformation of Pay Administration Initiative, Treasury Board of Canada Secretariat
Government lessons-learned report on a public service pay system built on an ERP HR and pay module; it names the risk that employees receive incorrect or no pay. Supports money-loss for ERP systems with payroll.
published undated · verified 2026-10-07
ev-0235regulatorprimary
23 CFR Part 680: National Electric Vehicle Infrastructure Standards and Requirements, U.S. Federal Highway Administration (eCFR)
The price for charging must be displayed prior to initiating a charging transaction and be based on the price for electricity to charge in $/kWh.
The US rule for federally funded chargers requires price shown before a session starts, payment methods accessible to people with disabilities, OCPP between charger and network, network-to-network roaming and real-time port status for third-party apps.
published undated · verified 2026-10-07
ev-0236regulatorprimary
The Public Charge Point Regulations 2023, UK Government (legislation.gov.uk)
The UK regulations for public charge points set contactless payment, payment roaming, reliability, a helpline, open charge point data and price transparency, with an enforcement schedule, so the driver app and its data feed fall in scope.
published undated · verified 2026-10-07
ev-0263court-or-fineprimary
Fortnite Video Game Maker Epic Games to Pay More Than Half a Billion Dollars over FTC Allegations of Privacy Violations and Unwanted Charges, Federal Trade Commission
Children and teens have been bullied, threatened, harassed, and exposed to dangerous and psychologically traumatizing issues such as suicide while on Fortnite.
Supports user-harm for a kids app with chat or multiplayer: the FTC tied harm to children to voice and text chat being on by default, tied unwanted charges to confusing purchase buttons, including purchases triggered when waking the game from sleep, on a loading screen or while previewing an item, and found personal information collected from children under 13 without notifying parents or getting their consent.
published 2022-12-19 · verified 2026-10-07
ev-0264court-or-fineprimary
Apple Inc. Will Provide Full Consumer Refunds of At Least [amount] to Settle FTC Complaint It Charged for Kids’ In-App Purchases Without Parental Consent, Federal Trade Commission
Supports money-loss for a kids app with in-app purchases: the FTC found parents were not told that entering a password also allowed further purchases by their children without another approval.
published 2014-01-15 · verified 2026-10-07
ev-0265store-guidelineprimary
Create and manage subscriptions (Play Console Help), Google
You must also include in your app(s) access to an easy-to-use, online method to cancel the subscription.
Supports store-rejection and money-loss for a language learning app sold by subscription on Google Play: the page requires explicit offer terms, billing frequency and an in-app cancel method for every subscription.
published undated · verified 2026-10-07
ev-0266regulatorprimary
Negative Option Rule, Federal Trade Commission
Supports money-loss for a language learning app whose plans renew automatically: the FTC rule page states its aim of stopping recurring charges consumers did not intend and removing obstacles to cancelling them.
published undated · verified 2026-10-07
ev-0290court-or-fineprimary
In the Matter of Apple Inc., Federal Trade Commission
Supports money-loss for a mobile game: the case concerns children's in-app purchases in games billed to parents without their consent.
published 2014-01-15 · verified 2026-10-07