In 2021, the Institute of Islamic Studies published Under Layered Suspicion, by IIS Director Anver M. Emon and Nadia Z. Hasan (YorkU), examining CRA audits of Muslim charities. That report was followed by another from the International Civil Liberties Monitoring Group, and together they contributed—along with public advocacy and litigation—to federal reviews of CRA audits by the Office of the Taxpayers Ombudsperson and the National Security and Intelligence Review Agency. That generation of scholarship (Charities 1.0) centred on the CRA and its audit practices.
On April 30, 2026, the IIS will publish the next generation of research (Charities 2.0) entitled Humanitarianism and the Exclusion of Muslim Charities from the Financial Sector: Unintended Consequences of Canada’s Anti-Money Laundering, Anti-Terrorist Financing, and Sanctions Regime. Authored by IIS Director and Professor of Law and History, Anver M. Emon, the report zooms out from the CRA and locates Canada’s not-for-profit sector within the broader, whole-of-government, anti-money laundering, anti-terrorist financing, and sanctions regimes. As the report explains, these regimes are not only governmental; they are constituted by a public-private partnership in which Canada’s financial institutions play an important part. Effectively conscripted into Canada’s sanctions commitments and its wars on drugs and terror, Canada’s financial institutions increasingly exclude charities from financial services often out of an abundance of caution given the uneven guidance federal regulators provide them. Not only are charities securitized by a federal national security regime, but also they are increasingly excluded from financial services and thereby precluded from fulfilling the very charitable purposes for which they are registered and remain in good standing with the CRA.
The report provides twelve recommendations to the federal government that are aimed at clarifying ambiguous and contradictory policies, upholding principled commitments to financial exclusion, and ensuring Canada’s financial services industry works for everyone, equally.
Launch Event: May 2, 2026
A launch event is scheduled for May 2, 2026 at University of Toronto Mississauga. For more details and registration please visit the event page here.
