We have begun. We've done quite a lot of work. More needs to be done, and a round of consultation with other agencies needs to occur. We will also need a round of consultation with the industry to ensure that we're getting it right.
The whole purpose of proceeding down this path was that in the current regime we have the power of persuasion—and we can be quite persuasive—but there is also the power to refer for criminal investigation prosecution. Many of the transgressions or deficiencies we identify are in that big grey zone in the middle where some sanction should be applied, but not one as draconian as a criminal investigation prosecution. For example, if we were to proceed with a criminal prosecution against a smallish money service firm that is otherwise law-abiding, we would put them out of business.
