Thanks very much.
I think you raise a fascinating question, and I don't know the answer, but it raises a much larger issue, which I think I touched upon when I talked about EDC. The statute that you're reviewing and all this work that you're doing is really focused on deposits and flow through, which is where the major risk of money laundering is. When a trust account is used for flow through, like a real estate transaction, that's where there were really huge risks—in the old days they took cash—and it's the same with financial institutions.
However, that's not the extent of all the risks. They are just the ones the statute focuses on. I know that the law society rules include things like client fees and bail. There are other exceptions as well—again, where it's not a flow through. It's the same with some of the rules for financial institutions, which is why EDC is not covered at all.
This might be a larger theme that the committee might consider looking at: money laundering risks or risks of receiving the proceeds of crime in cases where you're not looking at a flow through, if that makes sense.