The Canadian Muslim Public Affairs Council (CMPAC) acknowledges the release of the National Security and Intelligence Review Agency’s (NSIRA) report on the activities of the Canada Revenue Agency’s (CRA) Review and Analysis Division (RAD). This comprehensive review substantiates long-standing concerns raised by Muslim communities, civil society organizations, and academic research that Muslim-led charities have been disproportionately subjected to scrutiny under Canada’s counter-terrorism financing framework.

The NSIRA report identifies significant structural deficiencies in RAD’s approach. Investigators found that RAD “audited a number of charities that did not present with credible risks of terrorist abuse … despite the CRA’s public claims that only those charities at the highest risk of terrorist abuse are subject to RAD audits.”1 The review further noted that “RAD’s decision-making, especially when it impacts Charter rights like freedom of religion, must be reasonable. Reasonableness requires proportionality, and proportionality requires data.”2

Between 2009 and 2022, 67% of audited charities were discernibly Islamic, and a further 19% were Sikh.3 NSIRA also documented the use of dated information,4 unsubstantiated associations,5 and overly broad criteria6 that, in effect, captured a wide range of Muslim charities. These findings demonstrate how practices that appear neutral in design can have discriminatory effects in implementation.

For years, CMPAC has conducted research and policy analysis7 highlighting systemic issues within Canada’s counter-terrorism financing regime, including the lack of transparency, accountability, and proportionality in audits of Muslim charities. This report confirms that those concerns were well-founded and that the risks of bias and discrimination extend beyond individual cases to the structure and operation of the regime itself.

The implications of these findings are significant. The report warns that RAD’s practices “introduced risks of bias and discrimination”8 and may place the CRA at risk of contravening the Canadian Charter of Rights and Freedoms. Beyond legal implications, these practices undermine the trust and effectiveness of the charitable sector and impose material and reputational costs on organizations serving diverse communities.

CMPAC calls on the Government of Canada to respond with concrete and systemic measures:

  1. Implement all NSIRA recommendations in full, including the collection of demographic data, validation of risk indicators, and rigorous documentation of decision-making.
  2. Revise and revamp the National Inherent Risk Assessment (NIRA) methodology by applying FATF’s functional definition of NPOs, basing risk ratings on demonstrable evidence of terrorist financing vulnerability, integrating sector-led compliance measures into risk calculations, and shifting from an “inherent risk” framework to an evidence-based residual-risk assessment. 
  1. Suspend the use of RAD’s audit powers until reforms are enacted that ensure impartiality and protect against discriminatory practices.
  2. Establish independent oversight of the CRA’s national security functions, with accountability mechanisms accessible to Parliament and civil society.
  3. Engage in structured consultations with Muslim civil society organizations and other affected communities to restore confidence in the charitable sector’s regulatory framework.

The release of this report represents an important step toward accountability. It also underscores the need for structural reform to ensure that the rights of Canadian Muslims and of all communities are protected. CMPAC remains committed to working with policymakers, civil society, and affected organizations to ensure that Canada’s regulatory frameworks are transparent, proportionate, and consistent with the Canadian Charter of Rights and Freedoms.

    Footnotes:

    1. National Security and Intelligence Review Agency (NSIRA), Review of the Canada Revenue Agency’s Review and Analysis Division (Ottawa: NSIRA, 2025), iv, 5.
    2. NSIRA, Review of the Canada Revenue Agency’s Review and Analysis Division, iv, 5.
    3.  Ibid, and 8/13.
    4.  Ibid, and 2/7, para. 7.
    5.  Ibid, and 13/18, para. 51.
    6.  Ibid, and 14/19 para. 55.
    7.  See: Consultation Submission addressing the financial targeting of Muslim Communities and Charities (August 2023); Financial Action Task Force Submission on the Financial Abuse of Charities (August 2023); Financial Action Task Force preventing unintended regulatory consequences (August 2023); Senate Committee Testimony (September 2022)
    8.  NSIRA, Review of the Canada Revenue Agency’s Review and Analysis Division, 15/20.