As you know, lawyers are exempt in this bill from the suspicious and prescribed transaction reporting requirements. What I mentioned in my presentation was that there is a regime in place, however, to deal with the issues that those reports were intended to address, in the federation's view, and that is the no-cash rule, as we call it, which was adopted by the federation and implemented by all the law societies in Canada.
I would like to clarify one thing Mr. Skolrood said. These rules are actually in bylaws and regulations pursuant to the various law society acts in each province in the country. So they're executive legislation, they're not simply rules of conduct, although the concepts are reflected in the rules of conduct of the law societies.
Under these rules, lawyers are prohibited from receiving the cash amount of $7,500 or more from a client or a third party. In this way, the law societies are effectively regulating the flow of cash through lawyers. They are not permitted to take it. So as I said, there is a higher standard actually applicable to the legal profession than simply having them report a large cash transaction of $10,000 or report a suspicious transaction. They cannot take the money.
In our view, there is no need for a reporting regime, certainly with respect to suspicious transactions, for all the reasons that were argued in the constitutional challenge.
Now, there's a second part to this, of course, and that's the client identification verification requirements. We are continuing in our discussions with the Department of Finance on an appropriate regime for lawyers, because we understand that lawyers will be included, or are supposed to be included, as reporting entities under the regulations that are coming forward. So this is the nature of our discussion. We have not yet seen the regulations, but we'll look at them with interest.