The funds were sent to a bank in an European country -- with $20,000 taken out immediately.

Although the theft is currently before US courts, Henry said the Bank of America has adopted the attitude that a Trojan on your PC is "your problem".

"The defendant claims he was told to move to Internet banking by the bank and from the bank's perspective, Internet banking reduces the cost of transactions enhancing profits; if the court rules in the bank's favor then that is a bad precedent," Henry said.

David Bell, chief executive of the Australian Bankers' Association (ABA) said systems are in place to constantly monitor online transactions.

As a result fewer customers are actually reporting incidents of online fraud, particularly when it involves phishing.