Advocacy Recommendations 2

Recommendation 1: Establish a dedicated working group on nonprofit de‑risking and financial access within the Advisory Committee on Money Laundering and Terrorist Financing (ACMLTF), expanding its membership to include nonprofit and civil society representatives.: Applies to: Department of Finance Canada ACMLTF
Recommendation 2: Make financial inclusion and transparency explicit priorities in all AML/CTF policy discussions, ensuring anti‑terrorism financing measures do not unnecessarily restrict banking access for nonprofits.: Applies to: Department of Finance Canada ACMLTF
Recommendation 3: Collaborate with civil society to establish risk mitigation protocols for humanitarian and Muslim‑led charities.: Applies to: Canadian Bankers Association

Recommendation 4: Develop and enforce internal policies requiring individualized, evidence‑based risk assessments of nonprofit clients. Blanket exclusions based on sector, faith, or indirect associations must be prohibited.: Applies to: Banks
Recommendation 5: Audit algorithmic risk tools regularly to eliminate bias, including hidden patterns in AI‑based decisions. Training data must reflect current realities and be free from historical prejudice.: Applies to: Banks
Recommendation 6: Train compliance officers on equity, human rights, and the systemic impact of de‑risking.: Applies to: Banks
Recommendation 7: Develop transparent protocols allowing nonprofit clients to identify and address risk concerns before service restrictions or account termination.: Applies to: Banks

Recommendation 8: Represent Canadian nonprofit concerns in international forums like the Financial Action Task Force (FATF) and advocate for proportionate, inclusive standards.: Applies to: Department of Finance Canada
Recommendation 9: Champion clear humanitarian carve‑outs under sanctions frameworks and coordinate international safe financial corridors.: Applies to: Global Affairs Canada

Recommendation 10: Amend Canada’s AML regulations and National Inherent Risk Assessment to embed proportionality and financial inclusion as core principles.: Applies to: Department of Finance Canada
Recommendation 11: Conduct a Charter compliance review of AML/CTF laws and publish legal guidance to safeguard equality rights.: Applies to: Department of Justice
Recommendation 12: Hold parliamentary hearings on de‑risking’s impact on nonprofits, with a focus on Muslim charities. Topics: Evaluating discriminatory data‑sharing and surveillance loops Investigating algorithmic bias in compliance tools Amending the Bank Act to require closure explanations, extended notice, and appeals Publishing anonymized closure data and sector impact Strengthening consumer protections for de‑banked entities: Applies to: House of Commons Finance Committee
Recommendation 13: Hold hearings to evaluate how innovation and corporate governance policies can support nonprofit financial access. Topics: Interoperability of nonprofit registries and AML systems Innovation in digital ID and KYC Fintech solutions for humanitarian finance Expansion of the federal beneficial ownership registry: Applies to: ISED Committee

Recommendation 14: Require banks to offer internal appeal mechanisms for account closures or service denials.: Applies to: Banks
Recommendation 15: Create a public clearance mechanism for charities that pass CRA audits and reform the release of Administrative Fairness Letters.: Applies to: CRA
Recommendation 16: Mandate anonymized, sectoral data collection and publication on account closures and complaints.: Applies to: Department of Finance Canada FINTRAC FCAC OBSI
Recommendation 17: Legislate clear written explanations for account closures (except during active investigations), longer notice periods, and an appeals process. Expand FCAC’s mandate to review discriminatory closure patterns.: Applies to: FCAC OBSI
Recommendation 18: Require periodic audits to assess how banks implement the risk‑based approach, ensuring alignment with FINTRAC’s guidance discouraging indiscriminate closures.: Applies to: FINTRAC
Recommendation 19: Expand OSFI’s oversight role to include equity and fairness in risk modeling, and assess sector‑level disparities.: Applies to: OSFI
Recommendation 20: Create formal policies guiding law enforcement interactions with financial institutions to prevent account closures based on informal or leaked information.: Applies to: RCMP CSIS

Advocacy Recommendations for Fair Banking and Financial Access