Male 1: This is The Every Lawyer, presented by the Canadian Bar Association.

Julia: So, my guest today on The Every Lawyer is Arshinoff. Noah, Arshinoff. Noah Arshinoff teaches anti-corruption law at U Ottawa, and is the founder and managing director of ACT, an International Anti-Corruption Consultancy. He is a lawyer, business consultant and advocacy strategist, with experience in the public, private and association sectors, and he is one of the CBA’s top anti-corruption bad-asses. He has successfully advocated for amendments to various pieces of anti-corruption legislation and policy, including strengthening Canada’s integrity framework, bolstering the Corruption of Foreign Public Officials Act, and implementing Canada’s remediation agreement regime. Noah has written numerous submissions to government and appeared before parliamentary committees to provide testimony on a wide range of issues. So, hi, Noah, welcome to The Every Lawyer. We want to know about everything, but before we get to it, could you please describe the work of the CBA’s anti-corruption team and your part in it?

Noah: Yeah, sure. So, the anti-corruption team really was created to respond to everything to do with anti-corruption. I’ve actually been there from the start – I’ll give you a little bit of the history of it. I was working for the CBA shortly after the OECD issued their phase three evaluation of Canada’s implementation of the Anti-Bribery Convention, right? Which is the big international convention to counter corruption. Canada faced significant criticism by the OECD in our implementation and enforcement of that convention. So, one of my first tasks at the CBA was to establish a committee that could respond to the growing anti-corruption area. It was something quite new, it hadn’t really been looked at in over ten years, but there was this new push. So, yeah, we’re in 2022, so this is my ten-year anniversary of being part of the team in one way or another.

Julia: Wow. OK.

Noah: But yeah, in terms of the work, like the work itself from the committee, you know, it’s included responding to draft legislation, we’ve had policy discussions with government officials, we’ve made recommendations on government policy and law, we’ve interacted with international organisations, so, the OECD I mentioned, the Organization of American States, the OAS. And I think maybe of most value to the legal community in Canada is providing advice to the legal community how to best conduct internal investigations, for example, or spotting red flags. What are the red flags of corruption? And so, there’s been a bit of an educational component in that, too.

Julia: OK, so you’ve been there for ten years, if I understand well, and –

Noah: Yeah, this will be ten years.

Julia: I mean, would you recommend it to other bad-ass people who would love to do that?

Noah: Great. Only for bad-asses, yeah. No, no –

Julia: Only, right? [Laughs]

Noah: Yeah. [Laughs]. No, of course. No, I absolutely recommend it. I think anyone who’s been involved with the CBA likely knows that the value comes in being part of legal and policy discussions before legislation is actually tabled. So, the anti-corruption team has really been looked at as an expert body by government and other entities. And that’s where we’ve been able to have influence and steer the discussion towards practical solutions. So, I mean, I think it’s – if you’re interested in this area, it’s a really great committee to join in the CBA.

Julia: And could you also tell us about the CBA’s involvement in the government-led multistakeholder – and the name is very great – anti-corruption high-level roundtable task team one? First, who came up with such an awesome, cool name?

Noah: You’ll have to ask the feds. [Laughs]

Julia: [Laughs]. Perfect. That’s our next podcast.

Noah: Yeah, that’s right. No, the federal government put together a task force – I mean, it’s a little bit the buzzword of the day, but the point was to determine the road ahead to combat corruption, both domestically and internationally. And so, they requested that the CBA anti-corruption team participate in an effort to determine the effectiveness of the current international framework and our domestic regulatory environment. So, it was – we had very open discussions, and there were multiple departments from the federal government that were involved. And so, we had various members of our – you know, the CBA anti-corruption team provide excellent commentary, and it’s been used to inform really the government’s agenda on anti-corruption.

And, I mean, just to fill that in, too, I think, in the past the federal government maybe has not been well organised, I suppose, in order to really think through this area, and this task team or this high-level roundtable task team, I think, is a change in direction. I think really now the federal government – it’s been bumped up the priority level. And so, they’re really doing a pretty in-depth research and focus on what’s to come in anti-corruption.

Julia: Can we also talk about – because since 2015, actually, the CBA sponsored the “Global Corruption – Its Regulation under International Conventions, US, UK, and Canadian Law and Practice”, a book by Professor Ferguson, which has, at least to some extent, almost taken a life on its own. First, can you tell us how does one become a standard university textbook? How did that happen?

Noah: Be first, be thorough, be valuable. I think those are probably the three principles. Yeah, I mean, to be honest, at the time that Professor Ferguson was drafting this book, there was no textbook anywhere in the world that dealt with anti-corruption law. Nothing. Zero. So, it was – if you wanted to learn about it, it was a smattering of sources. And Professor Ferguson was really ambitious in his project to create this textbook. And I think he did a few things really well. So, you said: How does it become a standard? Firstly, he compared a few different jurisdictions. So, two of them are leading anticorruption jurisdictions in the United States and United Kingdom, and the third one is his home jurisdiction of Canada. So, when you can do a bit of a compare and contrast, I think that’s really, really useful and very practical. Secondly, and maybe the biggest thing, was that he made it publicly available for free around the world. Most legal textbooks, as we know, are quite costly.

Julia: It’s a fortune.

Noah: Yeah, they’re a fortune, right? Yeah.

Julia: Yeah, yeah, yeah. It’s crazy.

Noah: Yeah. And Professor Ferguson, like, he – so he partnered with the UN ODC, with Transparency International, the University of Victoria and the CBA – so that’s how the CBA was involved – to ensure that it had a platform and that it was accessible to anyone, no matter where in the world they were located. So, I mean, you can just – through the CBA’s site, you can actually download a copy of the textbook, and there you have it.

Julia: I mean, if you want knowledge to be spread, this is a really good way to do it. If you can do it and if you have it sponsored as well. And I think the fact that is CBA sponsored that is very, very important involvement in anti-corruption as well. And if we want to download the fourth edition, what’s new in it? What are we going to find?

Noah: Previously, Professor Ferguson was the sole author, and what he did was he had people edit chapters and provide commentary. So, that’s what the CBA anti-corruption team did, with respect to the chapter on the role of lawyers. This time around, the fourth edition, he actually sought experts to author certain segments. So, it’s gone from a single authored work to a collectively authored one. And I think there’s around 15 or so anticorruption experts who are now authors or co-authors of various chapters. So, I think that’s pretty cool. It’s now become more than one person’s project, he’s really done a good job to involve others in it. There’s also two new chapters. And they’re important ones, which is why I mention them. One of the chapters is on collective action, and collective action in itself as a term is a little bit undefined, but what it really means is cross-sectoral approaches to combating corruption.

So, you think of industry partnering with government, partnering with academia, to tackle a specific corruption issue. Collective action’s taking on kind of a life of its own as well in the fight against corruption, but I think it’s being looked at as really the next wave of solutions that we can address. And then it also talks about the role of NGOs, which I think is becoming more and more important in anti-corruption. So, yeah, it’s become a real, I think, living document and source of anti-corruption knowledge.

Julia: And probably the most important one – and coming from an NGO world, I’m very glad to hear that there’s a new chapter about that, because we do discuss a lot about it. But it’s pretty new, right?

Noah: Yeah, absolutely. I think anti-corruption – it started off – and, I mean, even if I just go through the ten years, my ten-year anniversary with the CBA, ten years ago, what we were talking about was bribery of public officials, right? So, you pay a public official somewhere to receive a service faster than if you hadn’t paid them. Something like that, right? But now it’s grown to be this large umbrella, and it encompasses many elements of criminal activity that are tied together. And Professor Ferguson does a good job of outlining a lot of this in his textbook. But when you talk about anti-corruption, you’re also talking about money laundering, you’re talking about the connection to organised crime, environmental crimes, you name it. And there’s lots of, I think, very smart people that are working on finding the solutions to counter the myriad of problems that are caused by corruption, but there’s no single answer. And so, this this book is really doing a good job of carving out all those different aspects of anti-corruption and fitting it into one, well, I mean, quite large textbook.

Julia: With multiple authors as well.

Noah: With multiple authors now, yeah.

Julia: And can we talk also now about Canada a little bit, our country? So, does Canada have a good reputation, or are we seen in the international scene as being tolerant or a bit laxist when it comes to anti-corruption measures?

Noah: Oh, this is the real fun stuff.

Julia: Yeah, getting into it. [Laughs]

Noah: [Laughs]. So, I tend to make the joke in my courses that this is where I get to disparage my country. [Laughs]. Which is not something I should necessarily be proud of. But, you know, we’re – when you think of Canada, I think we’re a it’s-a-problem-here type of country. Right? We’re complacent. And I think there are several problems, right? So, we have some decent laws, but we don’t have enough enforcement. We have a federal provincial issue, where there’s a divide, and some provinces are further ahead than others. We have the reality that provincial prosecutors will all differ in how they may wish to approach corruption. And then we also have a smattering of corporate legislation across multiple sub-national jurisdictions.

So, we end up with this kind of patchwork. And to date, it has not been looked at as really a good global example of how to fight corruption. And yeah, no, I think you’re right. Canada’s reputation, globally, has not been great. We’ve been seen as a bit of a laggard. I mean, we’re nowhere near the worst. I mean, there’s places much, much worse than Canada, but I think when people think of Canada on the international stage, the assumption would be that we would be doing better than we are.

Julia: Yeah. Yeah, honestly, I’m surprised. So, I’m guessing that when you say that Ferguson compare and contrast UK and US with Canada, I’m guessing that we don’t have that much of a good reputation in the book, or at least we’re – maybe he’s contrasting with the patchwork of laws that we have.

Noah: Yeah, the contrast with the UK, to me, is a little bit more interesting than the contrast with the US. And the reason is our legal system really mirrors that of the UK, so there’s so many more similarities with the UK than there is with the US. The US, it’s its own beast; the system is set up in a way completely differently than anywhere else. But they’re very active in enforcement. I mean, very. Not necessarily the way that Canada would want to do it, but that’s why when we look at the UK, and how the UK has moved ahead over the past ten years or 12 years, it’s interesting. You see the pace that the UK has moved, and then you look at Canada and go, wow, we are we are really slow to react.

Julia: Yeah. We’re far behind, guys. And do you have specific areas that are really very bad, and some that we’re better?

Noah: Yeah, I mean, bad, I would say, is probably enforcement. The total number of cases in Canada is very low, like really, really low. We’ve only seen a handful since 1999. And there’s a lot of reasons for that. It’s still very difficult to investigate and prosecute corruption cases. And there’s – you know, prosecutors may have had limited tools at their disposal, etcetera, etcetera. We need to get better at enforcement. There’s no question about that. One area I think we are getting better, like if I look at this optimistically, is anti-money-laundering, which may sound counterintuitive, given what’s been in the news last couple of years about Canada, but the Cullen Commission in BC is a great example. Right? They just released a report in June.

And it highlights really all the problems that exist that have to do with money laundering in Canada, or at least in BC, but I mean, I think a lot of those are true across the board in Canada. And part of my optimism is that it may just be that it’s money laundering’s time in the spotlight, but when a topic receives a lot of attention from the press and the international community, it doesn’t go unnoticed. And so, I think we’re getting better because we’re paying more attention to it. And so, you know, like beneficial ownership registries and things like that, like the federal government has bumped up their timeline to get that in place. Provinces are kind of following suit. There’s activity. There’s things happening on it.

Julia: OK, that’s great. So, we’re not a tax haven.

Noah: Well, I’d say the reason for the Cullen Commission to have been established in the first place is probably because we are, we have been looked at as a tax haven. And you know, if you look at Canada’s experience with beneficial ownership transparency, or rather the complete lack of transparency, then yeah, we probably can be viewed as a tax haven. I mean, several articles have been written about how easy it is to use shell companies in Canada that can then be used to stash cash. Right? And why not? I mean, you think about it, why not? We’re a stable jurisdiction, solid banking and financial system, well-educated population, overall strong economy; it’s a great place to move money to, especially if you’re from a place that is not those things. Right? So … But I think again, because of that reputation we’ve been getting, and because of now this activity on anti-money-laundering, I think things are starting to move in the right direction.

Julia: That’s why I was asking, I was kind of – my question was more [with hope? 00:15:25], and it was like are we a tax haven or no, but OK, yeah. I see we are still [unintelligible 00:15:30]. That’s good. And can you also tell us a bit more about what is Canada’s integrity regime or the integrity framework, and how effective is it, or ineffective?

Noah: Sure, yeah. So the – I mean, so switching gears a little bit, the integrity regime is – it’s the federal government’s policy that dictates when a supplier is barred from contracting with the federal government. So, it contains a suspension policy where companies who are convicted of certain listed offences will face an automatic ten-year debarment period. So, for example, if you’re convicted of a corruption offence under the Corruption of Foreign Public Officials Act, the CFPOA, you will be automatically debarred from contracting with the Canadian government for a ten-year period. It sounds like strong punishment. And it is, but then there’s the question of its effectiveness. And, you know, if you ask me is it effective, my view is no. And the reason is because it’s too rigid. It’s the equivalent of like a mandatory minimum sentence but baked into policy rather than legislation.

So, for example, I’ll give you an example. So, if you take two companies – OK, let’s just use our names, Julia. So, Noah Inc. Noah Inc. paid a $10,000 bribe to an official, let’s say, in Uzbekistan. OK? To receive favourable visa treatment for my employees. So, we have lots of business in Uzbekistan, but I want my employees to get their visas really quickly, be painless, so I’ve paid an Uzbeki public official $10,000 to get that. Basically, I bribed them to get that treatment. OK. Now, Noah Inc. is then going to – will be prosecuted and convicted under the CFPOA. We’ll be convicted for bribery. OK. Now, let’s take Julia Inc. OK? I’m going to make you the evil one here, sorry.

Julia: OK, that’s good, that’s fine. I can take it. [Laughs]

Noah: [Laughs]. So, let’s say Julia Inc. has paid bribes in 15 countries, totalling $200 million, and it’s been over a ten-year period. OK? So really, what that means is that corruption is endemic to the culture at Julia Inc. OK? So now Julia. Inc. is also convicted for bribery under the CFPOA. Now, what happens is that under the integrity regime, both Noah Inc. and Julia Inc. would be debarred for ten years.

Julia: OK.

Noah: Does that make sense?

Julia: No, so, I mean, as the villain, I should be debarred for way longer. Or forever.

Noah: Well, that’s it, right? So, I think the problem here is you’re treating two unlike circumstances the same, and you’re not taking into account factual differences. And so, I think the end result and the problem with the integrity regime that we’ve witnessed is that it acts almost as a dissuasive policy, making companies really question whether they should come forward to the authorities if they discover any wrongdoing. Because the entire purpose of the integrity regime is to promote self-disclosure, but if the threat of automatic debarment without recourse is seen as worse than the conviction, then it’s actually the opposite. It becomes a dissuasive policy. That’s my long-winded answer, but I think it’s an easy fix. There’s lots of department regimes around the world, the most famous is probably the World Bank’s, but the World Bank’s basically mandatory period is a two to three period. OK, so you’ll get de barred for two to three periods.

So, let’s make that Noah Inc. and Julia Inc. start at two or three years. OK? Then we’ll look at the facts. And then we’ll say, oh, Julia Inc., oh, yeah, no, you guys are really bad. Now you’re going to be – you’re going to be debarred for 10 years. But Noah Inc. was more of a one-off thing, one place, a much lower amount, much fewer victims of corruption, so we’ll make that just a three-year debarment. I think if you allow companies to kind of plead their case, and treat it more like you do in the legal case, where you take the factual circumstances into account, it would fix that policy pretty quickly.

Julia: Yeah, and give them the chance, actually, if they have a chance to plead their case, and they have a reason to try to have something to plea, and just say, well, we haven’t done that and that. So yeah, that’s a really good example, actually. Thank you very much. And well, I mean, we use like fake names, and I don’t know if you can say it here on a podcast, but who’s Canada’s worst scumbags when it comes to very …? Yeah, if you can. If you can’t, it’s fine too.

Noah: Well, OK, I’ll give you the unpopular answer here, probably not the one you’re looking for. Because I don’t think there’s any one or two particular companies, really, that are the evil companies, I think corruption seeps into a culture, and then it has to be changed. But I think the – to use your terminology, the scumbags, the worst – no, but really, because corruption requires people to enable corruption, and it’s the enablers that are the worst at it. And so, you know, unfortunately, lawyers are also put in that bucket, because you can’t really move money without lawyers, and accountants and bankers, and all those people involved. That’s not me saying that lawyers are corrupt. In fact, I think it’s the opposite. I think 99.9 percent of lawyers are not, but it’s the 0.1 percent who are helping corruption that I think are really the worst of the worst. And those are – I think that’s where we need to probably focus some efforts, is on the enablers of corruption.

Julia: I love the answer, actually. Thank you very much.

Noah: OK.

Julia: Noah, I also I have a question for you, because recently the Superior Court of Quebec published its reasons approving Canada’s first remediation agreement under the Criminal Code. It was with SNC-Lavalin, and honestly, I’m not quite sure I understood everything. So, could you please tell us more about Canada’s remediation agreement regime, and why implementing it required an amendment to the Criminal Code?

Noah: So, remediation agreements are – at least in Canada’s criminal law, are a new tool to combat corruption. They’re not a new tool overall in anti-corruption, though. So, the United States has made use of them for several years, the UK has had them since about 2010, France since about 2016, so there are several large jurisdictions that have used an equivalent of a remediation agreement. And I think the big difference is it’s about treating organisations and individuals differently through criminal law, because you can’t treat them the same. And just to give you the – so this is the brief background, but criminal law is basically designed for individuals, right? So, you commit a crime, that crime has a certain severity to it, and then you’re given a sentence, and the sentence often involves imprisonment. OK? So, maybe it’s one year, maybe it’s ten years, whatever it might be. That’s fine when you’re talking about an individual.

You can’t, though, imprison a brand. Right? You can’t send a logo to prison; it doesn’t work. It’s not an effective punishment. So, you need something else. You need something else. You need some other adequate tool to deal with organisational offenders who have engaged in corruption. And so, that’s where remediation agreements came in. So, what they are is they’re basically agreements whereby the prosecution imposes a series of terms and conditions on the organisation, and they’ll suspend the prosecution. When the term of the agreement is up – so let’s say it’s a three-year long agreement – if the prosecution agrees that the organisation has fulfilled those terms and conditions, it will drop the charges. So, there will be no criminal conviction at the end of the remediation agreement. OK?

But the big thing is the impact that a remediation agreement can have on our organisation. That’s what makes all the difference. So, terms, the terms in an agreement can include things like a complete overhaul of management, complete overhaul of the board, a requirement to implement robust compliance procedures with third party oversight. A company can be subjected to regular audits, and of course, they’ll be subject to a fine, paying a fine. And hope – you know, ideally, you’re going to have a fine that’s in line with the severity of the corruption that took place. So, in a way, it doesn’t sound all that different from a guilty plea. The main difference, though, is that there’s no admission of guilt to a criminal offence. Right? So, in an RA, a remediation agreement, the offender will admit responsibility for their actions, but they will be spared a conviction. And I think that’s why an amendment to the Criminal Code was needed.

Because before, prosecutors basically have three options: you could either prosecute, you could seek a guilty plea, or you could drop the charges. Now they have a fourth; now they can negotiate a remediation agreement. And I think – just one – sorry, just to wrap up that thought, there’s one important thing to keep in mind about remediation agreements, in Canada, at least, is that they’re only available to organisations. So, individuals cannot sign a remediation agreement. And I think part of the purpose is to be able to separate out the guilty individuals from the organisation, and prosecute those individuals under the traditional criminal law, and then sign a remediation agreement with the organisation so that the terms and conditions and the fine, and all that stuff that will impact the organisation, will be in place.

Julia: It makes sense, though. I think it’s quite logical. And when you explain it like that, way more clear for me. Thank you. So, a bit of looking in your crystal ball here and talking about the future, which is never easy, but what are some of the most pressing concerns you have about the challenges Canada and the world in general are facing at the moment, and down the row – and down the road, sorry, when it comes to corruption? So, what is … What do you see as challenges?

Noah: Well, the challenges are kind of like looking at the ocean and watching the waves roll in. One comes in, and then there’s one right behind it. So, alright, let’s see if I can focus on a few. I think enforcement, enforcement is a big one. Enforcement truly can’t keep up with demand. I don’t think the public sector by itself is necessarily capable of enforcing everything anti-corruption related. I just think it’s almost impossible to do that. So, the solutions have to come from beyond legislative tools and policymaking. We need those things, but we need industries as a whole to gather together and say no to corruption. We need to counter corruption through channels such as trade agreements. Right? I think we need to get a little bit creative. We need to leverage international organisations that have clout and ability to hold corrupt actors accountable.

On the industry side, what I’ll say is that without the full involvement of – let’s say, like the financial sector. Right? If we don’t have the full buy-in of the financial sector, we’re always going to be scrambling. And I think industries have more power in this than they necessarily think. You know, if – another example, if Airbus and Boeing decided not to pay bribes, and to call them out when they encountered a request, the aerospace industry would be nearly free of corruption overnight. Right? So, the power, to me, often resides with the pocketbook, not the requester. It’s the organisations that have the money to pay the bribes that are the ones that hold the key to it. And the last one is that – well, I guess so there’s two more, but one really important one is education. I’m a big believer in that. And I think, you know, you need education in law, you need it in business, you need it in accounting programs. And I think it’s too late to begin educating lawyers about anti-corruption when they’re kind of five years into their career.

I mean, not – I shouldn’t say too late, but I think you should strive to do it earlier. And when that happens, when people are educated about it earlier – so if you have – you know, if there’s an anti-corruption law course at your university, that’s when you develop the ability to spot something wrong, and potentially take action, or begin to drive a culture change when you’re in the workforce. Right? Because you kind of – it gets implanted there into your head of this – kind of this different way of thinking. And the last, the very last thing – and this relates to your previous question – we need economic might that pushes its weight around in the form of, I think, strong democratic countries saying no to corruption, and the various mechanisms that it uses. That might be, at this particular moment in time, the hardest thing with what looks like a more and more polarised world. That’s going to be a real task that I think won’t go away for the next, you know, five, maybe ten, maybe longer years.

Julia: And what I hear also about what you say is that you as a teacher of anti-corruption law, I mean, we can be very grateful to know that you are teaching that and that you are having little minions that are going to go spread the good word [laughs] all around. That’s very great. Thank you for the work. And so, you talked about corruption, you talked about anti-corruption, you talked about these scumbags, the good ones. But how do you avoid becoming cynical when you are confronted with human corruption on a daily basis? How do you do it?

Noah: Oh, I’m cynical.

Julia: Oh, yeah, that’s it, huh?

Noah: [Laughs] I’m cynical because – you know, there’s the saying, I’m only human. And I think that says it all, right? We’re all only human. We may all react differently under similar circumstances, and that’s what creates kind of the possibility for corruption to manifest itself. But then again, I do also believe in a basic moral concept of goodness and fairness. And I think most people do too. Right? It’s just how do we get on board of having the same concept of goodness and fairness? You know, so I mean, I’m – I don’t know, can you be cynical with optimism? Is that a thing?

Julia: Yeah, you can say that, yeah. I will define myself like that as well. But you’re totally right, and I think it’s very – it’s a positive note to end this podcast. But before we really let you go, do you have any resources that you want to share with lawyers who would like to fight international corruption, but might not know where to start?

Noah: I think a really fantastic place is the NGOs. So, I know you’ll like that answer Julia, but …

Julia: Yes, I love that answer. [Unintelligible 00:30:06] I didn’t ask anyone to say that. Just on the record. [Laughs]

Noah: [Laughs]. There are some fantastic, fantastic NGOs that are doing really, really good work in anti-corruption. In Canada, we have Transparency International Canada, a phenomenal organisation that punches well above its weight. So really, I think that’s a great place to start. Check out their website. I mean, you can get involved as a volunteer, you can – you know, if you’re a lawyer, you can – there’s a legal committee that you might be able to get involved with. So, there’s lots of ways to get involved with TI Canada. There’s the CBA. I mean, the CBA anti-corruption team, we have a lot of discussions about various issues concerning anti-corruption. That’s another good way. Internationally, if you just want a resource to look at, one of my favourites is the Basel Institute on Governance, based in Switzerland. Just doing phenomenal, phenomenal work.

It almost operates a bit more like a think tank necessarily than an NGO, but just – I mean, it has projects all over the world. So, there’s a – that’s a really good resource to look at. What else can – oh, so I’m – the one other place I would say is there’s the Canadian Centre of Excellence for Anti-Corruption, which is a not for profit. I mean, I do happen to be on the board of that, but – but again, it’s an organisation that’s really designed to provide a toolkit, really, for everyone to learn about anti-corruption, but also to contribute as experts in the area, or just – or really just to learn about it. Those would be my suggestions. I mean, I’ll say this, too. I mean, you know, ask to speak with someone or be put in touch with someone. I mean, heck, reach out to me if you’d like, and I’ll happily try and connect people to other people.

Julia: Oh, love that. That’s really good. Thank you very much. Our listeners will – maybe we’ll be reached by some CBA’s listeners now. Thank you very much, Noah, for your time. That was very interesting. Seriously. Thank you.

Noah: Well, thank you, Julia. Appreciate it. Thank you very much.

Male 1: This is The Every Lawyer, presented by the Canadian Bar Association.