Advocacy Recommendations

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.: Applicable Bodies: Department of Finance Canada ACMLTF
Recommendation 2: Make financial inclusion, transparency and the limiting of unintended consequences of AML/CTF regulations explicit priorities in all AML/CTF policy discussions/frameworks/policies, ensuring anti-terrorism financing measures do not unnecessarily restrict banking access for nonprofits.: Applicable Bodies: Department of Finance Canada ACMLTF
Recommendation 3: Collaborate with the charitable sector to assess the impact of AML/CTF policies due to especially de-Banking and de-Risking. Co-develop sector-specific guidance and establish a standing forum for ongoing feedback, dialogue, and policy improvement.: Applicable Bodies: 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.: Applicable Bodies: 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.: Applicable Bodies: Banks
Recommendation 6: Train compliance officers on equity, human rights, international humanitarian law, operational realities of humanitarian work, and applicable risk mitigation approaches. This training should focus on preventing unintended consequences of AML/CTF oversight and addressing the systemic impact of de-Risking.: Applicable Bodies: Banks
Recommendation 7: Develop education practices that help nonprofit clients—especially humanitarian organizations—understand the specific financial sector compliance considerations.: Applicable Bodies: Banks

Recommendation 8: Represent Canadian nonprofit concerns in international forums like the Financial Action Task Force (FATF) and advocate for proportionate, inclusive standards.: Applicable Bodies: Department of Finance Canada

Recommendation 9: Amend Canada’s AML regulations and National Inherent Risk Assessment to embed proportionality and financial inclusion as core principles.: Applicable Bodies: Department of Finance Canada
Recommendation 10: Introduce legislation to enact a right to banking and ensure fair and impartial banking services while preventing banks from using subjective or biased criteria to deny service and linking fair practices.: Applicable Bodies: Department of Finance Canada
Recommendation 11: Hold hearings to study the practice of bank de-risking and its impact on the nonprofit sector — with a specific focus on Muslim charities and other disproportionately affected communities.: Applicable Bodies: House of Commons Finance Committee
Recommendation 12: Hold hearings to study how federal corporate governance and innovation policy can better support financial access for Canada’s nonprofit sector.: Applicable Bodies: ISED committee

Recommendation 13: Require Financial Institutions to offer internal appeal mechanisms for account closures or service denials.: Applicable Bodies: Banks
Recommendation 14: Mandate anonymized, sectoral data collection and publication on account closures and complaints.: Applicable Bodies: Department of Finance Canada FINTRAC FCAC OBSI
Recommendation 15: 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.: Applicable Bodies: FCAC OBSI
Recommendation 16: Expand OSFI’s oversight role to include equity and fairness in risk modeling, and assess sector-level disparities.: Applicable Bodies: OSFI

Recommendation 17: Issue clear, public guidance that blanket or sector-wide de-risking — including of nonprofit organizations such as Muslim charities — is inconsistent with Canada’s risk-based approach. The guidance should explicitly require that all risk scoring and account closure decisions be individualized, evidence-based, and aligned with Canada’s commitment to financial inclusion.: Applicable Bodies: Department of Finance Canada FINTRAC OSFI Canadian Bankers Association

Advocacy Recommendations for Fair Banking
and Financial Access