The International Civil Liberties Monitoring Group (ICLMG), a coalition of 44 Canadian civil society organizations, has submitted its contribution to the Financial Action Task Force (FATF) ahead of Canada’s upcoming fifth mutual evaluation.

In the submission, ICLMG raises long-standing concerns with how Canada’s countering the financing of terrorism (CFT) measures disproportionately impact civil society, particularly Muslim-led charities and humanitarian organizations. Evidence shows that since 2003, Muslim charities have been subjected to biased audits and investigations, with at least 75% of revocations by the Canada Revenue Agency’s CFT division targeting Muslim-led organizations, despite no charges of terrorist financing.

The submission also warns that Canada's National Inherent Risk Assessment (NIRA 2023) continues to paint charities with too broad a brush, labeling the entire sector as “high risk” without recognizing safeguards that organizations already put in place or the sectoral mitigation measures that exist in law and regulation, including self-regulation. While the draft 2025 NIRA shows some improvements, including case-by-case evaluation and greater acknowledgment of mitigation measures, it still disproportionately singles out racialized and Muslim-led organizations for extra scrutiny.

The impacts extend beyond Canada’s borders. Restrictive interpretations of CFT laws have blocked humanitarian aid in crisis zones, most notably in Afghanistan after 2021, when Canadian groups were prevented from delivering life-saving assistance. Although new legislation has introduced exemptions, the process remains burdensome and continues to limit vital humanitarian and development work.

ICLMG calls on the FATF to ensure that Canada’s CFT measures are proportionate, non-discriminatory, and developed in consultation with civil society, in line with international standards.

Read the full submission here.