The Federation case, which is what you're referring to, set out a clarified and formalized principle of fundamental justice, which is the solicitor-client relationship. It's not just the solicitor-client privilege but also the relationship. The client has to believe and know that the lawyer is four-square in his corner, and that he will not be acting indirectly or directly as an agent for the state.
That makes it difficult for the PCMLA reporting requirements to apply to lawyers, because if a lawyer is taking information from his client and then reporting some of that to a federal agency, the client would be right to think that maybe there were some things that they shouldn't be telling their lawyer because those might get back to the state in which case it might hamper the lawyer's ability to properly defend his client.
We're certainly aware of the bind, if you wish, that puts the PCMLA in, in the context of fighting money laundering. Obviously, lawyers play a key role in a number of areas relating to transactions, to setting up corporations, and so on. The Department of Justice, along with the Department of Finance and FINTRAC and other departments are looking at potential avenues of trying to set up a system whereby if the lawyers cannot report, at least the lawyers would maintain certain types of records which then might be available to FINTRAC by way of a compliance mechanism. I don't want to prejudge the final results, so I can't say that we will or we will not come up with a regime or a method by which lawyers will be able to report on their clients.We are looking at all of the possible avenues, and I'm afraid I can't go into any further details at this time.