In some cases, it can be, that the card holders bank grants the Liability Shift. For instance, some banks only require one 3-D Secure every 24 hours and the others will be approved, in order to speed up the payment process. The Liability Shift is still granted, however high risk businesses (Jewelery, Electronics, ect.) may want to stick to the highest level of security. It is your (The merchant) decision, if you want to accept these transactions, or if you want a full authentication.