Right.
Well, I think it's fair to allow some time to phase in to allow companies to adopt appropriate compliance programs. That aspect of it is fair. But even once it comes into force there will be ambiguities because there's a real issue as to whether or not a facilitation payment fits within the central offence-creating provision in the act at all. It might be that removing the facilitation payments exception doesn't change the law at all. But that's what we lawyers do: we advise our clients. It will make it harder to advise clients.