Thank you for the question.
I don't think, for one, lowering the threshold from 25% to 10% and a risk-based approach are mutually exclusive. I think they actually go hand in hand. I would note that the 25% isn't so much a standard as it was an initial global recommendation that everyone just kind of grabbed on to. There is room to go down to 10% and provide more information for the RCMP.
I'm not an expert on the risk-based approach. I'm sure there are others at the witness table who can speak to the specifics of it. It's essentially modelling and looking at what the typical patterns are that one would see in money laundering; what the data that we're now being provided shows us; being able to do an analysis as opposed to doing one-at-a-time searches of companies; being able to strategically mine through the data and see where the activities of a certain company match our modelling; and taking a little bit of a deeper look into a company, just in case.
One of the said experts would know.