...Doron Goldbarsht Against this background, the purpose of this paper is twofold. First, the paper will explore whether the characteristics of frequent-flier programs pose ML risks. A frequent-flier program is defined here as any program offered by an airline that involves issuing miles, bonuses...

...-for shipment. However, just as electronic money operators, loyalty programs have access to additional information that is not considered as “identifying” but could be useful for the analysis of activity and potential investigations. This is especially true for the frequent-flier programs. Booking systems...