Absolutely.
I don't think that the financial institutions should be put in a situation where they have to take on an independent duty to determine it. It should only be relying on a list. That's what we conveyed to Finance. The appropriate way to do this to ensure consistency in how it should be applied would be to simply rely on a list that is provided, in this case, by the RCMP.
I disagree with my co-witness on the discretion. The wording in the order is “shall.” We shall make an independent determination and we shall freeze if, in fact, the facts support that the activities have taken place. There are concerns with a bank having to make that type of a decision as to whether or not those activities are taking place.