Ontario (Attorney General) v. $10,000.00 in Canadian Currency (In Rem), 2014 ONSC 944:
 “Unlawful activity” is defined in the Act as an act or omission that is an offence under an act of Canada, Ontario or another province or territory of Canada or even outside of Canada, if a similar act or omission would be an offence in Ontario if committed here. The Attorney General does not have to prove that the property in question is related to any particular offence: Chatterjee v. Ontario (Attorney General), 2009 SCC 19 (CanLII),  1 S.C.R. 624, at para. 21. However, in this case, the Attorney General relies mainly on evidence of drug trafficking.
 Section 3 of the Act requires the court to make an order forfeiting property if it finds that the property is proceeds of unlawful activity, with certain exceptions. The parties agree that none of the exceptions apply in this case, at least with respect to Paquette.
 The term “proceeds of unlawful activity” is defined in s. 2 as meaning “property acquired, directly or indirectly, in whole or in part, as a result of unlawful activity”.
 Section 8 of the Act requires the court to make a forfeiture order if it finds that the property is an instrument of unlawful activity, again with certain exceptions that the parties agree do not apply here.
 The term “instrument of unlawful activity” is defined in s.7 as meaning “property that is likely to be used to engage in unlawful activity that, in turn, would be likely to or is intended to result in the acquisition of other property or in serious bodily harm to any person, and includes any property that is realized from the sale or other disposition of such property”.
 A proceeding under the Act is a civil proceeding. Therefore, the Attorney General must prove the requisite grounds on a balance of probabilities: Civil Remedies Act, 2001, S.O. 2001, c. 28, s. 16; Chatterjee, at para. 23. I am persuaded that he has done so in this case, for the following reasons.