How exactly does it put him in more jeopardy then previously. If he's retaining them, people need to know so try know who to go to if they have withdrawal problems. If he's passing them onto some other escrow the. It'll also be publicly known for the same reasons.
The principal part of the law is that it regulates Bitcoin as
a Money Services Business. As such it would be subject to the requirement to report to the government cash transactions over CAD$10,000. I am sure that dooglus is hoping that the holders of roughly 16 accounts that are over that amount will withdraw their bitcoins before the law goes into effect.
If that happens, the idea of creating an escrow for thousands of accounts of very small value , many of which will never be settled, may be better deal with legally by considering them as personal loans.
Well since no business is currently in operation he is holding the coins as an escrow holder
Considering there are no interest for for holding these coins he would just be considered a retainer now of the balances.
Safe from the MSB status but I guess he could press the emergency withdraw button whenever he needs to.
It's still fairly early to do that though give them a few months to do it btct's shutdown and burnsides took around a year or so before it calmed down with a little bit remaining here and there.