Okay, welcome to another episode of The know your

compliance podcast. I am extremely excited to be sitting

down with a good friend of mine, Chris Thompson. Now, Chris is

trained as a lawyer and works for the provincial government in

a financial crimes capacity, so I'm his background is wonderful

for the conversation about unexplained law focus, but I'll

let Chris introduce himself, and then we'll get into the topic.

Yes,

I'm a proud former lawyer. The practice of

law was not for me, but it was an interesting venture that led

me to where I am now, which I'm quite happy at. But I mean, if

you guys Google me. You can probably figure out where it

worked. But just as a disclaimer, I am appearing here

in my own capacity and abuse. I'm about to espouse are mine

and mine alone. So

all right, you, you have not been sanctioned or

officially sanctioned,

correct? Cool, cool, yeah, nor is it anything

we'd actually deal with normally. We wouldn't deal with

these. But it's a personal interest to me so well,

I think, and that's actually why I reached out to

you in the first place, is the intersection of your

professional obligations right now and your background as a

trained lawyer and having worked as a lawyer are kind of the

perfect intersection for this specific topic. So with all of

that being said, the topic today we're going to be talking about

is unexplained wealth. Is unexplained wealth orders. And,

well, I wanted to have this conversation because unexplained

wealth orders are newer into Canada. In fact, new into BC,

only at this point in time. But are a really important tool. You

know, we spend our world in on the really trusted side. I think

we spend our life in deep in fin track and fatfa is big component

of unexplained wealth orders. Yes, and so I think there's some

obvious kind of reasons for us to be having a conversation. But

let's start at the very beginning, because some of our

audience won't necessarily know what an explained wealth order

some of our audience comes from other provinces. Some Yeah, so

can you give us, like a two, three minute intro to what an

unexplained wealth order is for a struggle?

So in in one sentence, an unexplained wealth

order is an order from a government or an investigatory

body to explain the source of funds for an asset. And the

context of that is, typically you have investigations that go

into that look into criminal bodies or criminal gangs or any

types of financial non financial crime, and criminals have to

hide the money somewhere. And a lot of the times, the

investigations, for whatever reason, don't result in criminal

charges, or they're hampered in some way, or they can't be

charged threshold, but whatever the case is, but there's these

assets that you're reasonably there's a reasonably sure are

proceeds of crime. I mean, we all know the obvious examples,

the the 18 year old kid at your high school that's driving a

Bentley, right, and mom works at Safeway, and Dad is unemployed

or something like, okay, it does not take a genius to figure out

that that kid's doing something sketchy positive, right? Yeah,

and so fat. If the Financial Action passports is very a

global money laundering and terrorist financing watchdog,

they have said essentially that a country must have a non

conviction based civil forfeiture, unless their

constitution for visit, which is our civil forfeiture of the

civil forfeiture office, which is different than an unexplained

wealth order. But Fauci also says that they should also have

a law that forces someone to explain the lawful origin of

property, interesting. And so this, these UW O's are sort of

newer in kind of a worldwide context, and there's a number of

countries that have started. But as you're saying, Yeah, BC, as

far as I know, it was the first Canadian province to do

Yeah. And I mean, from a BC point of view, it came

straight out of the column commission, really, yes. If we

go back to where the the origins of how we got here are,

I think it was recommendation, like 101 it was

like 99 that I'm saying we need people to investigate stuff. And

then number 101 was,

we need a UW, L, we need a new tool in this fight.

Yeah. Now I think some of our listeners are probably going to

pick up on one of the real challenges, and I think we'll

come back to the challenge in a second. But one of the real

challenges is there's kind of a presumption of guilt all of a

sudden, instead of a presumption really sets, is what, what some

would say, yes, yeah. So I think I want to asterisk that up

front, because I know some people are going to be just

focused in on that, because that's the first thing you hear,

yes, if you're not, if you're not thinking through that, well,

if you're not looking at that in a bigger picture of broader

sense kind of thing, yeah. I think where I wanted to kind of

go first though was, Is this a tool that was necessary? I mean,

I acknowledge that fat for recommends it and look like as a

member of the g7 we started fat for, like Canada has clearly

bought into all of this things, whether we've done a good job of

implementing a recommendation. Questions that we signed on for

in the first place, but many would argue we have not, but

that's a that's well outside the scope, but I guess so. One are

unexplained wealth orders a necessary tool, and are they

being used effectively? Or where are we in that continuum? I

suppose that's where I would start. Yeah,

and it depends on what you mean by the word

necessary, like it's it will be an incredibly useful tool, and

it will assist in taking on a lot of organized crime and and

not punishing offenders in the legal sense, but removing some

of the proceeds of crime. But they always say, you know, uh,

crime doesn't pay. Yeah, it does. Actually, it pays quite

well. That's, that's, that's why crime exists. Any, anyone,

anyone who works in any kind of law enforcement agency will tell

you, crime pays very well in the general case, I mean, it's,

we're all doing our best to stop and deter and detect and assess

and disrupt and all those things. But you need tools and

is it necessary? Well, if you want to be able to to take steps

to remove the proceeds of crime, given the legal infrastructure

that we have now, like the charter and all those things,

yeah, I would say yes. I mean, is the world going to collapse

if we don't have them? Yeah, going on. We haven't had them

forever, up until now, and society hasn't collapsed into

energy and chaos. But I think it's an incredibly useful tool,

or could be an incredibly useful tool, and to, again, just assist

in fighting crime in a different capacity, okay? And like

just to, I want to really double down and double

click on something you just said, which I think is hugely

important, crime does pay. Like, that's, oh, yeah, in fact,

that's why crime exists. If, if you could go and make billions

of dollars selling whatever else, you probably wouldn't sell

cocaine. Like, that's crime case, period, full stop. And

that's, that's fundamentally why I'm why I do what I do with the

company, is because I do believe that by by implementing

appropriate controls in businesses, we can actually make

a dent in our society and remove some of the crime that that we

do see, and I like that, that I'm fully bought in, yes. So

that part, I'm on board with

that to some degree, though. That's more of a

preventative thing, like UWS roll out for the fact, well,

yeah. But if you, if you can prevent it, if you can

make it, yeah, if you make it less likely that people are

going to get to keep the keep the money at the end of all

this, yeah, that's true. They're they're less likely to to want

to do it in the first place. It becomes less appealing. Yes. Now

UW owes have been in place in other jurisdictions. Yes. And I

know you did a bit of reading into that ahead of time. Maybe

walk us through. We were talking about off fire. We were talking

about the case in London. That seems like a particularly

interesting, useful to illustrate why these are

important tools in the fight of in financial investigation,

support,

yeah, and that's, I think, one of the one

of the aspects of this being a relatively new thing, is that

it's been used. You start with sort of the most egregious

cases, and you don't want to go with a brand new law the court

and try and test its constitutionality like a

marginal case, right? You want to go in there where the case,

where you literally your brief, can be like, dear court, duh

Stein, the plaintiffs, right? And that seems to have been the

case for a lot of the UWS that I've seen so far. So the

example, I thought a lot of this is, is from a report, and it's a

star Wealth Report, which you can just Google. It's, it's

quite interesting, if you like reading 128 pages on obscure

legal

so for listeners, probably do, actually, to be

honest. So

Well, probably 100% of the people at this table

do, exactly, yeah. So this is a case. That's the Haji ever case

out of the UK. This was 2018 so there was an a guy who worked in

the government of Azerbaijan. He moved to London, he and his

wife, and over the previous 10 years, so from oh six to 2016

she spent 16 million pounds, about 20 million US at Harris,

which is a luxury department store. They bought a house for

13 point 2 million US dollars, which were expenses that were

vastly out of keeping of what her husband could make in his

own home country. And their house was owned by a British

Virgin Islands BVI company linked to both her and her

husband. So this drew the attention of the UK authorities,

as also her husband, had been convicted in 2016 of

misappropriation and fraud. He got 15 years in jail and was

ordered to pay $39 million and so some of the funnier things is

like she spends $20 million at least $2 million at Herods a

year. And there was one I found she spent, uh. Let me pull it up

here. She spent, I think, 30 she spent 600,000 pounds in one day

on a spending spree. She also spent, I think, like, $30,000 in

one shot to Godiva chocolates. That's

a couple of chocolates. That's a couple of

that. Yes, I don't know how long would it

take you to eat $30,000 of Godiva, but that's

a pretty high quality job, true.

So not exactly a sympathetic case. And so here's

a case where, okay, this guy's been convicted in, I assume, he

was convicted in Azerbaijan and sentenced in order to prison.

And this woman's later living in London with what are kind of,

obviously proceeds of crime, like, there's, there's no way

this actually buy this money legally. So then the question

becomes, okay, if you don't have unexplained welfares, how do you

prevent this type of of living large based off your crime? And

I mean, she's not convicted of a crime, you know, it's arguable

whether or not she's done anything wrong, like she's just

been given a blank check from her husband, and maybe she

hasn't, but still, this is the person. These are the proceeds

of crime. And if you want to make crime not pay, you got to

go after these types of things. You absolutely have to, yeah,

and so they did, and that was the first case.

So you started by talking, and I think we didn't

go into the distinction which I'm hopefully vote to make,

which is you started by talking about this is an investigative

tool, yes, and this case just ended up in what sounded more

like forfeiture. In fact. Can we just parse the parse part? Parse

apart for our listeners a little bit for a second, the difference

there between forfeiture and, yeah,

investigation in some cases. I mean, it might

legally, there's a difference. There might be a distinction

without a difference, for the for the general public, but an

unexplained wealth order, in and of itself, is just an order from

the court for a subject to provide information on the

source of welfare property. So like, Hey, okay, you know, haul

someone out of gym class and get them to explain where they got

the money for their Bentley like that. That's it. It's a court

order. You have to go to court. You have to file a bunch of

stuff, and the court will say, yes, okay, you can make this

person tell you where they got the money from. And that's it.

It doesn't give you the authorization to seize it.

Doesn't give you any other powers. You can't freeze it, you

can't do any of those things. You just have the power to

compel the person to provide the information. And then, if the

information is insufficient, well, there's, then, when I was

looking into that, now, there's, there's three possibilities,

yeah, I

think this is not, yeah. Okay, so court grants the order. Well,

let me back up a sec. So what the what the person has to

provide is an affidavit to the court. So there's going to be

some kind of investigator they have to provide. They have to

swear an affidavit to a court saying, and this is BC specific.

It varies a little bit around the world, but the idea is the same.

And I should say, I think we've got a little bit

wrong. Manitoba has also introduced them, but hasn't used

them yet. Oh, okay, so, but BC is the first to use them, and

clearly, directionally, it seems likely that other provinces will

follow suit. That's I like to joke that BC lives in the future

on the water regular, yep,

so the bleeding edge, yeah,

exactly. Yeah, yes.

So if you think you know the high school kids

mentally is proceeds of crime. What do you have to say is on an

affidavit, there's a reason to suspect a person is involved in

illegal activities or as a politically exposed person, you

have to have a reason to believe that the person has an interest

in the underlying property that you're looking to investigate.

The property has to be worth more than $75,000 so you can't

be like, Hey, where's that? Watch from PFO. Like, No. Uncle

counts that. And there has to be one, a serious question to be

tried, that one of these three things are true, that the known

sources of income are insufficient to acquire or

maintain the property. The property was used to engage in

unlawful activity, or the property was acquired or

maintained as a result of unlawful activity. And again,

none of these are beyond a reasonable doubt or even balance

of probabilities. So balance of probabilities is 50% plus one,

yeah, the someone at trial, or fact, a court, whoever has to

find that it's more likely than not that something has something

happened. That's not the standard here. You've got reason

to suspect the person is involved in legal activities.

You have to have a reason to believe that the person has the

interest in the property. And the legal term, serious question

to be tried, basically means it has to make sense what you're

saying, like you can't just ponder stuff up out of thin air.

So a lot of our listeners will become will be

familiar with the concept of reasonable grounds to suspect,

because that's when the threshold for a suspicious

transaction report must be filed okay for fin track filing

purposes. And so this distinction becomes really

important, and really, to me, interesting actually, because

what you're saying is that i. Uh, an unexplained wealth order

doesn't rise to the same level as a as if I'm if I'm hearing

you right anyway, doesn't have to have absolute fact, or

doesn't have to be beyond reasonable doubt. No, no, that's

interesting.

And that's, again, the civil standard.

There's no There's no jail time. People's liberty isn't knows

liberty is threatened here, so you you don't need that beyond a

reasonable doubt standard, okay? And that's where some of the

controversy comes from. Is people saying, like, Well, hey,

they haven't been convicted of a crime. They haven't been any of

this stuff that the onus to prove your innocence is put on a

person who owns the asset. Now, legally speaking, like

conceptually, maybe that's true, depending on on how

sophisticated your understanding of criminal law is. But to be

found guilty of something, you have to be charged with a crime.

Nobody's being charged with a crime, therefore, you're not

innocent of anything anyway, like you're not guilty, you're

not innocent. There's no possibility of you being found

guilty of something because you're not being charged with a

crime, right? So there's no onus on you to prove your innocence

of anything because you're not being charged with a crime.

There's an onus on you to to show that this property at

question isn't the isn't the proceeds of crime, or at least

that you acquired it illegally. And I guess the

debater in me would then say, sure, but if I can't

prove that I acquired this legally, the assumption is that

I acquired illegally. That's correct, and that is an

interesting term from how we normally view a lot of things in

Canada. I think

maybe I mean, if you're used to looking at at

things in the criminal context, that's true, yeah. But anyone

who's ever filed their taxes knows that I was hoping it

brings it's all back to tax. I worked as a tax lawyer, followed

up tax there's certain situations in life where the

subject or the person who owns an asset question is really the

only one that can make sense of something that happens. So I

wouldn't expect CRA to file my taxes, because I know what I did

during the year. I know how my accounting structure set up. I

know. Well, I mean, I, you know, earn a wage. It's fairly

straightforward, like CRA could probably be pretty close to my

taxes. But, you know, I own a house and I got rental income,

they're not going to be able to parse through all my bank

accounts and figure out how much I spent on rental maintenance

like they're just not right without outrageous amounts of

efforts. So there's a quote with something like the the taxpayers

in the unique position of knowing all the information

about the subject, right? So what it's the the theory of

these unexplained wealth orders is that it's not practical for

the government to figure out where you got the money to buy

this asset from. Like, that's going to be prohibitively

complicated for someone who has to compel bank records and

transfers and a lot of these assets. I mean, if, if you're

really good at money laundering, the money will come from

overseas, like it's if you paid for your Bentley with a check

drawn on a Panama bank, yeah? Like, good luck, right? It's

going to take us years to figure that out, to be able to track it

down, and we just don't have the resources to do that. Okay, so I

mean unexplained wealth orders are a means to level the playing

field between law enforcement and criminals, because law

enforcement just doesn't have the resources to figure all this

stuff out, but it's very, very easy for someone. Most of the

time we can get into it's not but most of the time it's fairly

easy for someone who legitimately acquired asset, an

asset, to prove how to legitimately acquire it. Like,

if, I mean, I own a house, like, okay, Chris, who I own this

house? How do you bought this house? Okay, well, here's the

mortgage documents, here's the money, here's where I sold my

old house. Here's the bank records where it all came

through. Here's my income for the last like, it's easy, I can

do it in 10 minutes, right? Fair enough.

And in fact, going back to the taxes, your your

taxes would probably support your case, because that's

legitimately where the money came and you weren't trying to

hide, yeah, I think you weren't trying to hide any money into

that. So, yes, yeah, yes, yes, of course. No, that perfect.

So I think now, sorry, the one part where it

does get interesting is if it's like, I bought this house 15

years ago. Well, I can't get the bank records. No banks keep

records for 789, years. And I don't know if anyone's even

looked at that yet, but the cases in BC are the ones again,

where they're, what are called unsympathetic defendants, where

it's like, well, yes, but yeah, there's going to be at some

point, I think someone's going to say, like, Hey, man, yeah, I

had a great night at a casino in on my 50th birthday, 17 years

ago, and then you I deposited the money as a to the bank

account. But the like, the bank records are long, so that's, you

know, that's a bridge someone's gonna have to cross at some

point. It doesn't sound like a fund bridge track to cross, I

gotta be honest. Well, then the other side of this, maybe then

the government will just think, like. Right? The detractors of

the people who are arguing against this law, they're going

to say stuff like, and it's legitimate that, you know, it

can be abused. Taxpayers may not have the documentation, like all

of that's true in or at least it's plausible, yeah, now there

are safeguards in that this stuff has to go through a court,

like someone in the law enforcement to kind of, like, I

wouldn't be able to just go and see someone Bentley and, like,

start driving it around. Well, thank goodness. And that's I

probably would be able to fit in the Bentley. But anyway, you

know, a lot of the almost any law enforcement power can be

abused, but that's what we have the courts for. And I think

most, most law enforcement agents and most law enforcement

agencies, almost all the time, are trying to do, you know,

proper, defective investigations. And I've, I've

been in situations where I'm like, Okay, well, I asked for

some information. The person's like, Hey, man, X, happened?

It's no one's fault. Like, I had a flood in the basement 10 years

ago. Here's the records. Like, the sewage backed up, like you

want the box, like it's all yours, man. Like, oh, that's

okay. You keep and you give people the benefit of the doubt.

Okay, if there's sort of legitimate reason to, but again,

this is this, UW, Bo, is the one situation while you're not

giving people the benefit of the doubt as a policy, yeah. But if

there's, I think there's different reasons where, if it's

if you've got something that's wildly uncharacteristic with

your income, well, you should have the paperwork, especially

if it's recent.

So it's interesting. I think that, like as as we've

talked through this, to me the the most obvious use case,

immediate use case for this that I think will be interesting when

it eventually happens, is there the common example of where real

estate brokerages are failing in their contract obligations is

when the homemaker or the student buys the west side of

house and Anyway, it's such a it's such a cliche example that

I think it's almost a meme at this point.

But we've had a few of those where you pull land

title and it's like, yeah, owners, so and so, student, 99%

and then 1% mom in where, right?

That question, and now suddenly, maybe that's,

would that be a good example of a good example of a case where a

nine planned author might be useful

if there's ties to crime? Yeah. I mean, it's

again, it's not, it's not a fishing expedition. Okay, we

cannot just look at, you know, the the government, or whatever,

the civil forfeiture office, or anyone the police. Just can't go

wandering around saying like you are an Aston Martin, tell me how

you know how you buy it. No, if you're just a law abiding

citizen, and there's no reasonable grounds to suspect

them, all these other pieces that you're actually tied to

organized crime, you're not

going to get it on its own welfare. If that third

part of that three part test that that actually was

important, but I think is the part that kind of gives us some

comfort and protection, I guess is what you're suggesting. Well,

there's

a the the third part is a serious question to be

tried is the non sources of income or insufficient

properties? Yeah? We Yeah. We still have to go to court with a

bunch of facts, right? We can't just show up with some dude with

a shiny thing and say, like, hey, what that shiny thing? Can

you get him to prove to us how he bought it? Like, no, there's

a process to go through,

so not a tool of bureaucratic welfare, not that

I'm aware of. Okay, yes, yeah. Okay, so I think we've started

to cover this a fair bit, and I think I just want to kind of

make sure we've addressed it, because I think it's the one

thing that people generally kind of get their backs up against

the wall, as you quite rightly said, the BC liberties, Civil

Liberties Association, sorry, came out pretty hard against

unexplainable authorities, yeah. And what's the, what's the case

against? And, I guess, what's the, what's the rationale, where

I think, where you think this probably passes the smell test

that at Port of all, yeah.

So the the case against again, is, like you were

saying, is we have a presumption of accidents, yeah, the general

public writ large has the right to just go about our daily lives

without harassment for police or any investigatory body

generally, right? And the idea is that in order for be this

subject of the scrutiny of the state, they must have some kind

of evidence or probable cause, whatever your standard is, like

that, there are we have, we generally have a right to be

left alone, right? Yeah, and this is a situation where people

feel that your your right to be left alone and your right to be

innocent until proven guilty, that those two things are kind

of being violated, one of the other rights, again, in the

charter, or not in the charter, sorry, but one of our rights is

until proven guilty. Like there's a fundamental concept in

in our criminal system, our criminal systems, and pretty

much everyone's around the world, yeah, that you know, we

would sooner let 99 guilty. People go for free, then put one

innocent person behind bars. And I think that right way to go.

And then it's certainly frustrating in law enforcement

jobs at times, but you know, it's not, it's not supposed to

be easy. It's not supposed to be easy to lock someone up or take

the money or, you know, give them sanctions. And so the

opponents say this concept of we shouldn't have to prove our

innocence, and this concept of basically being left alone by

the state unless we've done something wrong, both of those

are at odds with the idea of unexplained wealth over quite

and like the Azerbaijani lady, has she done anything criminal?

I don't know. Maybe not, like there was no allegations. She

hasn't been charged with anything. She hasn't been

convicted in hasn't been convicted in anything. All she's

done is married some guy who probably extorted millions of

dollars out of whoever, and then she is just living

off the luxury. Yeah, she somehow managed to spend 30

million of dollars. Well, her husband made about a million

dollars in the same period of time, exactly.

Yeah, yeah. And so the the the next step of

that. So my rationale is, my rationale, I think everyone's

rational is, is it, is it conscionable to think that,

okay, just because someone isn't convicted of a crime, that they

should be able to live off the proceeds of crimes, yeah, and

if, like, you take the counter example, like, that's, you know,

brother a and Brother B. Brother B's a drug dealer, earns much

money, buys brother a, a Bentley in a house and all these other

things. Okay, well, do we want to let brother a keep the beta

in the house? I kind of think no. I mean, brother a hasn't

committed a crime. He hasn't done anything wrong. I just

don't think in in sort of a legal system writ large and fat,

if agrees with me, on a worldwide basis, that it just

doesn't make sense, it would offend the sensibilities of most

people, yeah, to see like the little brothers of drug dealers

being able to keep their Bentleys and all these other

proceeds of crime forever.

It does make it a bit easier to become a criminal with

while you personally might not be advanced if your entire

family and the ones you love or whatever will be then, yeah,

you're probably right, yeah.

One of the other things you got to think about,

too with these unexplained wealth orders is it? One of the

goals was to really go after the heads of organized crime gangs.

Okay? Because they're typically structured in a way that the

people up at the top aren't the ones going up and committing the

day to day Crimean, but they're the ones that have the the

mansions. They're crimers. Do crime. They crying. You need to

stop crying. Carry on. Yeah. So yeah, the the heads of organized

crime gangs, you know, the money funnels up and and the low level

guys that keep getting that, getting charged with whatever it

is that they're doing, yeah. And if you want to go after the

upper level Echelon people, it's going to be really, really hard

to get everyone to get everyone to flip on the way up. And an

easier way to do it is just take all their stuff, right if you

can prove that all of this stuff, or at least with an

unexplained wealth order, if they're unable to prove that all

of their assets, or whatever assets you're investigating,

weren't proceeds of crime, weren't not proceeds of crimes,

or too many negatives, if the upper, if the upper members of

the if the Crimean can't prove a legitimate source of their

assets, right, then I think it's, I don't think anyone's

going to be against taking toys away from gangsters. Yeah.

Well, I think that's, that's probably the more

sympathetic approach to this, which is, you know, like the the

guy living in the $20 million mansion who has hundreds of

people selling little baggies of coke? Yeah, I don't like Coke.

Is my thing today, but I've mentioned it twice, being a

lawyer,

our stereotypical Yeah, but crap, I

went BMW to damn it. Oh, it's black, but the turn signals

work. I use them all the time.

Yeah, so, but anyhow, I think that's that becomes a

much more sympathetic argument for general people

to accept. I think, yeah. And one of the

other reasons too is a lot of the times it's really hard, if

not impossible, to get documents from other jurisdictions. Okay,

so if you want to prove that that the particular source of

funds for something was illegitimate and it comes from

Saudi Arabia or Lithuania or, I think the Philippines, don't

quote me on that one, though, like there's some jurisdictions

where various law enforcement agencies in Canada have

agreements with various law enforcement agencies around the

world, both civil and criminal. Criminal, it's typically called

an mlat, a mutual legal assistance treaty. It will take

years, right? Okay? And so if you are a criminal, and you run

your your funds through five countries, and it takes two

years to get an mlat, and take it 10 years to figure out where

the money came from, and that's just not feasible. So criminals

know. Of that, and then they use that. And so these orders are an

attempt to sort of level the playing field between the

criminals that understand the financial obscurity system, or

how to obscure finances, and law enforcement.

Which is, which is why? I mean, I guess if I, if I

go federal policing, would become a federal policing force

who had the tools like unexplained wealth orders is

probably better suited to fight some of these transactional

crimes, which is what you're suggesting. Well,

I mean, we have federal police, we have the

RCMP. I'm not sure that it's necessarily a lack of policing

effort. I think it's just a function of how the system works

like the international system, yeah, and I know the steps

involved, that was at a conference the other day. They

said it takes, you know, the the investigator has to draft an

order, and then they send it, I think, to crown. And then that

takes a while, and then it comes back with some corrections, and

it goes back and forth, and it gets approved somewhere else,

and then it has to go to some office, and then the office

sends it. It all has to get officially translated into,

like, Dutch or something. But then the lady who does the

official Dutch translations is on a two week kayaking trip,

and, like, I don't know Nunavut, or whatever it was, and so she

has to come back. And then the translation happens, and it gets

sent over to the Netherlands. And then, I don't know whatever

Dutch guy does the translation. Like, it's this, it's nuts. And

I kind of liken it to, this is my standard analogy. Do you know

how tennis? This is how I understand tennis. It used to be

played. So do you know where the numbers in tennis come from?

Like the zero, 1530, 3040, okay, no. So it used to be that when

you started, you both stood at like a line, which, let's call

zero, okay, when you won a point, you went 15 feet ahead.

Oh, and when you won that point, you went to 30 feet, you know,

in that point, you went to 40 feet. And one, when you won that

you won the match. That's kind, I feel that sort of like how the

approvals process in law enforcement works. You start at

line zero, and then you go with your supervisor, and then you

hit the ball back and forth. And eventually you hit a winner.

Then they approve it. You move up to line 15, which is the next

level of approval. Then you hit the ball back and forth a bunch

of times. Eventually you hit a winner. Then you go up to line

30, and then, like line 40 is whatever director of the

institution you're running, who has to ultimately sign off on

this thing, and then who might actually get you somewhere all

of a sudden, or who hits it back. And then you have to go

back to line zero and start over again. That sounds terrible. It

is. Yeah, I have said My job is 80% pretty good, 10% awesome,

and 10% mind. I'm only tedious, and some of that is the mind

Emily tedious part. It's just this endless series of back and

forth right now that's not all the time. That's fairly rare.

Most of the time, the stuff gets touched, like once or twice, but

for something where it's like overseas requests are everyone

knows they're a pain, and they take forever, and it's you're

kind of coordinating among a bunch of different institutions

and dealing with different languages in different time

zones, and it's a pain. So these I explained wealth orders are

kind of a means of leveling that playing field between the

criminals and

investigate what right? Okay, and really making

the the transactional side of it a little bit a little bit

easier, makes sense? Yeah, no, no, that makes sense. Cool.

Well, thank you so much. This has been a really, kind of a

helpful analysis in unexplained wealth orders. Ultimately, I

think why they're important. And I think the case that that they

that they may not the civil liberties they might impact, let

me put it that way, and ending that whole balance of whether

they're good or bad, and necessary or evil or whatever, I

think we've kind of hopefully kind of gone through that enough

that our listeners gotta get a sense of that. So thank you so

much, Chris for for understanding the topic and

being willing to spend your time with me talking about it. Happy

to be here, and thanks for being also awesome. Thanks. Thank you.

Bye.