Right. We work quite a lot with our U.S. counterparts on this. They don't recommend at all that you pay facilitation payments. The reason is that those payments are probably illegal in another country and are probably criminalized by other jurisdictions.
The U.K. would be an example where they don't have that exemption, but they will use administrative sanctions to address this, so the person doesn't get a criminal record.
Whereas you will see with the U.S. higher numbers, most of their cases are done on books and record-keeping offences, and we're introducing this in our legislation. We are on the same par, but we have to use different tools to address the same types of practice. That's what we're doing with this legislation.