As an "escrow" holding coins he is transferring currency now and thus would need to get information on the people he is transferring too. Remember having to send license ID, utility bills to Gox and Bitstamp last year to get your funds out. Pretty much the same thing imo now.
I'm going to assume your right about this, seeing as I haven't had a good look at the new law myself yet.
@doog: Given this, I'm curious how are you going to manage the funds which are still owned by those people who have not yet claimed. I'm doubtful every single person will claim their coins before the bill comes into effect (unless it has already - can't find any sources to say when the law is in effect).