Netcraft: Fraud Hosting and Phishing Site Countermeasures: "Fraud Hosting and Phishing Site CountermeasuresNetcraft Services
Once a bank has been alerted to the fact that it is the subject of a phishing attack, the race is on to close the target phishing site as quickly as possible. When the fraud is inadvertently hosted by an otherwise reputable and experienced organization, this can be routine.

However, professional fraudsters will take steps to ensure that the process is as difficult and time consuming as possible: your time is their money.

Fraudsters will often host their sites in developing countries with limited law enforcement resources and incentivize the hosting company to keep the site running as long as it possibly can. Indeed, some unscrupulous hosting companies actually promote fraud hosting as a service. "