Report launch: on structural biases and prejudicial policies in CRA audits of Muslim-led charities

March 30, 2021

We at the IIS are proud to launch a new research report, in partnership with National Council of Canadian Muslims (NCCM), called “Under Layered Suspicion: A Review of CRA Audits of Muslim-led Charities”. The report can be found at:

The report finds potential biases and prejudicial policies that influence the Canada Revenue Agency’s (CRA) selection of Muslim-led charities for audit, the practices within those audits, and their findings.

The report was principally funded by a grant from the Social Sciences and Humanities Research Council (SSHRC) and received supplementary funding from the Reading Muslims project, funded by the university of Toronto’s Connaught Secretariat.

Below is an excerpt from the Executive Summary:

Muslim-led charities have for years expressed concerns about the selection, frequency, and reasoning behind audits of their organizations.

The findings from Under Layered Suspicion suggest that there is a basis for these concerns. The report identifies whole-of-government policies and patterns of audit practices that together evince potential biases in Canada Revenue Agency (CRA) audits of Muslim-led charities.

Under Layered Suspicion draws attention to the Government of Canada’s anti-terrorism financing and anti-radicalization policies. When these policies are operationalized by the CRA’s Charities Directorate and the Review and Analysis Division (RAD), they create the conditions for potential structural bias against Muslim-led charities. The study shows that in the crosshairs of these policies, Muslim-led charities are uniquely vulnerable to penalties or even deregistration at the hands of the CRA.

This vulnerability takes shape through ordinary auditing techniques that occur in complicated global times. Under Layered Suspicion analyzes the evidence and interpretive frameworks of three audits in light of the political context within which they took place.

This report questions whether Muslim-led charities can be treated fairly in the course of audits that occur under the shadow of Canada’s anti-terrorism financing and anti-radicalization regimes.

The recommendations emphasize the need for the Government of Canada to formally investigate patterns of bias within the machinery of its agencies and bureaucracies, and create mechanisms of accountability. 


To the Canada Revenue Agency

  1. Suspend the Review and Analysis Division (RAD) pending review of Canada’s Risk-Based Assessment (RBA) model and its National Strategy to combat extremism and radicalization.
  2. Suspend discretionary use of revocation power in audits of Muslim-led Charities where anti-terrorism financing or counter-radicalization policies inform the audit.
  3. Enhance transparency between the CRA’s Charities Directorate and charities audited under suspicion of terrorism financing and/or radicalization.

To Finance Canada 

Review and revise Canada’s risk-based assessment of terrorism financing in Canada. 

To Public Safety 

Provide greater guidance to government officers on how its counter-radicalization strategy is to be applied in a non-discriminatory fashion. 

Read the full report at: