I have two related answers.
I think, on the authority of the commissioner to fine people, the standard of proof there will be less than that of the criminal law. It will make it easier for the commissioner to impose fines than it would be if you're accusing somebody under the Criminal Code or the Evidence Act. On that side, it's a good call. There's still the possibility of judicial review, but the commissioner can simply impose the fines at a reasonable level of proof.
There are other crimes, some of which provide for life imprisonment—which is, to be honest, one of the things that surprised me about the bill. You still have the criminal law level of proof, but I don't know if there's a great deal that can be done without dealing with the old intelligence-to-evidence issue. It's an issue we've tried to resolve for the last 20 years.
Having said that, the appointment of a special counsel and all of these other measures will help. Part of the difficulty is that the rules of discovery in this country are among the broadest in the Commonwealth. When we have issues before the criminal or civil courts, everything becomes available. I'm not sure this is the statute to fix that, but I would urge upon you the view that it is a significant issue and a lot of people have tried to resolve it.
As long as you have the criminal level of proof, I think you've done what you can. Again, I would urge you to look at this more generally in the future.