CMPAC’s submission to the Department of Finance responds to a consultation on Canada’s Anti-Money Laundering and Anti-Terrorist Financing Regime. Our remarks challenge the assumption that Muslim charitable organizations are at an inherently elevated risk, pointing to the absence of evidence linking charities to terrorist financing and the overall compliance track record of the sector.
We call for acknowledgement of persistent systemic Islamophobia, tracing a line from flawed assumptions about risk to the disproportionate and damaging targeting of Muslim charitable organizations. CMPAC calls for an independent review of the Anti-Terrorism Financing regime’s impacts on the Muslim community and charitable sector, including reputational damage, financial exclusion, and the resulting disruption of charitable activities.
CMPAC recommends the proposed Canada Financial Crimes Agency replace the institutionally and culturally biased Review and Analysis division of the CRA in monitoring and investigating the non-profit sector, to address the failures and the disproportionate targeting of Muslim charitable organizations by RAD.