I don't know the precise answer to your question. I can undertake to look into it. In fact, it was difficult to research where that regulatory obligation came from, because I just recently discovered it. All I can do is refer you to a document that was provided, or that will be provided electronically, which is the “U.S. Tax Shelter Industry: The Role of Accountants, Lawyers, and Financial Professionals”. This was a 2003 report from the Senate committee in the United States.
If it's all right, I can read you a short passage, which is somewhat telling of this problem, or I can direct you to it. I'll actually just draw your attention to page 13, which details both that requirement and the reality that large accounting firms chose not to register, knowing that was a breach of the law, and did so in a calculated way. Evidence given to the Senate of the United States was that they calculated the profits and the tax that would be saved versus the lack of enforcement for this registration. It's much like the Ford Pinto was a calculation, and it cost us less to fix the Pinto than to pay off the people who were going to be killed. It's not exactly the same, but it is a cold calculation that was done.
What I would say further to your first question regarding the self-regulated professions is that I spent eight to ten hours looking through all the reported cases since 1987. They're online. That's almost 30 years of cases. I looked through the unlawful conduct provisions, and I looked through the reputation of the profession. There wasn't one case about tax evasion internationally. There were fraud cases that were domestic. There was not one case about that.