The advent of mobile and digital wallets coupled with contactless payment methods and the ever-increasing growth in on-line payments have made e-payments become ubiquitous and have increased the need to develop effective authentication protocols, technology, policies and procedures to mitigate and reduce the risk of fraud. Recent legal cases in the United States have allowed negligence claims against financial institutions that do not have effective multi-factor authentication systems in place, where losses would otherwise have been borne by customers. As technology develops and consumer transactions and instructions are increasingly provided remotely or through contactless methods, effective authentication and security technology will continue to become increasingly critical. The use of digital wallets requires careful review of financial services account agreements; in particular limitations of liability and other provisions relating to allocation of risk ought to be reviewed. As with debit cards, financial institutions should expect losses may be borne by them, except where the consumer does not cooperate with an investigation, fails to report a lost or stolen card or fails to protect his or her PIN.