Ahead of Canada’s 2025 FATF evaluation, CMPAC submitted a detailed analysis of Canada’s implementation of Recommendation 8 on non-profit organizations. The submission demonstrates how Canada’s reliance on “inherent risk” assessments and the CRA’s Review and Analysis Division (RAD) has disproportionately targeted Muslim-led charities without evidence of terrorist financing. CMPAC highlights flaws in Canada’s risk methodology, lack of genuine engagement with the non-profit sector, and the harmful unintended consequences of financial exclusion, derisking, and reputational harm. To address these systemic issues, CMPAC recommends shifting to a residual risk framework, reforming or disbanding RAD, and ensuring inclusive sector engagement with due process protections. This rights-based approach would bring Canada in line with FATF’s “do no harm” principle and international best practices.

Access the full submission below.