A senior judge has urged foreign exchange facilities to step up checks to prevent stolen bank money being laundered through their businesses.
Belfast Recorder David McFarland was speaking as he gave a ruling on sentencing guidelines in 'money mule' fraud cases.
A total of 14 people are currently awaiting sentence after pleading guilty to allowing their bank accounts to be used to launder millions of pounds taken by organised criminals from legitimate account holders.
So far it has cost the banking sector more than £3.5 million in so-called "phishing'' operations by gangs based in Northern Ireland or abroad.
Money taken in the frauds is first lodged in legitimate bank accounts.
The cash then disappears when it is either transferred to other accounts or withdrawn.
The legitimate accounts are 'loaned' out to criminals in return for a small payment.
Judge McFarland said organised criminals were using foreign currency exchange bureaux to withdraw thousands of pounds and convert it into foreign currency.
"One recurring theme in all these cases is the very lax money laundering regime that is operated by these facilities,'' he said.
"It is important that they adopt a much more proactive procedure in checking the nature of the transaction, why there is a need for the foreign currency, and look for travel documents to corroborate any story about a holiday.''
Judge McFarland said a typical 'money mule' would be a "vulnerable individual'' who would only have a bank account for social security benefits or income.
"Having come under the influence of criminal elements who would exploit them, they are likely to have a modest income and lack the resistance to the type of demands placed on them. The offending will be opportunistic with limited planning on their part."
The judge said that although the offending is "significant... it is not a crime which calls for a sentence to satisfy a genuine and measured public reaction to the crime and which would be a retribution in nature''.
"I therefore consider that it is within the discretion of a sentencing judge to leave open the option of suspending a sentence without the specific need to consider the existence of exceptional circumstances.
"The need for such circumstances would apply should this be a second money laundering offence, fraud or other dishonesty offence.''
Judge McFarland added that defendants should be aware a suspended sentence would be unlikely if they were found guilty after a jury trial.
"Suspended sentences are a means of expressing the seriousness of the offences with an acknowledgement that the custody threshold has been passed... (it) allows the offender to remain in the community to assist in their rehabilitation, but with a threat hanging over them should they re-offend.''
But he warned: "If there is no remorse or acknowledgement of guilt, a suspended sentence could well be inappropriate'.''