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The first step is the interest belongs to the clients whose money it is. Are they to be deprived of this interest? The rest of the interest, on small balances and sums held for a very few days, helps defray the cost of running a client account.

I no longer hold client money but, when I did, if such a scheme had been in force I would have asked my bank to pay either no interest on client account (that was not in a designated account for a client) and use the interest that would have been paid to reduce the bank charges or first deduct the bank charges before crediting any interest - producing the same result and leaving little, if anything for the MoJ/government.