Prior to the introduction of the client identification and verification rules, we had extensive discussions/negotiations with the Department of Finance and FINTRAC to explore ways that we might be able to avoid the constitutional battle that we then had. There was, at that time—and I anticipate there would be now—a willingness to try to work with those organizations in a constitutionally compliant way.
What does that mean? It means that the information that lawyers obtain from their clients in the course of the solicitor-client relationship—and that is distinct from something you might do; it's purely business and nothing to do with providing legal advice or representation—is protected by solicitor-client privilege. Lawyers are no more allowed to share that, to breach that, than anybody else is, because that is the law, and the privilege belongs to the client.
There is quite a lot of information that could be provided to FINTRAC, for example, in an aggregate form, or ways that identify potential patterns via typologies and so forth, as Ms. Johnson and I were talking about before. The reaction of FINTRAC at the time was that they were not interested if we were not talking about enforcing the federal regulations. We remain willing to talk.