Question juridique clé
Whether the appellant had standing to challenge transmission of bank documents for accounts he only beneficially owned
Solution extraite
He had standing only for the accounts of which he was holder; he lacked standing for accounts held by companies where he was merely beneficial owner or proxy holder.
Motifs extraits
Under MLA rules, standing is limited to persons directly affected by coercive measures; the court followed case law denying standing to mere beneficial owners absent special circumstances.