Islamophobic Audit

How was the Audit tainted by Islamophobia?

Systemic Islamophobia within Canadian government agencies and regulatory bodies is the result of legislation and directives. For example, the antiterrorism laws have broadened the executive power of the government with little or no oversight and gave the government and its agencies far-reaching powers in the process.

In 2015, the Anti-Terrorism Act (Bill C-51) underwent a major overhaul under the Harper government resulting in even more massive expansion of state power without oversight or safeguards. 

The lack of transparency and accountability has allowed for the kinds of structural and institutional Islamophobia throughout the Audit process. The audit was tainted by Islamophobia in the way MAC was selected for audit, how the CRA determined the risk of terrorism finance, how the audit team was onboarded, the audit itself, and finally in the preliminary findings themselves.

Starting Point - The National Inherent Risk Assessment (NIRA)

The NIRA is a review of money laundering and terrorist financing risks faced by Canada, conducted by the Government of Canada, to identify and assess the risks associated with terrorist financing in Canada, including the charitable sector.

The Government of Canada’s own publications on counter-terrorism overwhelmingly point to groups comprised of visible minorities – and predominantly Muslims – as being the leading threats to Canada’s national security.

The identification of MAC as a charity necessitating an audit was only possible because of the Government of Canada’s national “risk-based assessment” that consistently identifies Muslims as a source of terrorist financing risk.

RAD’s starting point is three publications that overtly identify Muslim organizations as a threat of terrorist financing risk.

  1. The first publication is a 2013 publication of the federal government entitled Building Resilience Against Terrorism: Canada’s Counter-Terrorism Strategy, which is described as a “coordinated national strategy to counter terrorism”. This document states that “[v]iolent Islamist extremism is the leading threat to Canada’s national security” and lists as “The Terrorist Threat” Islamist extremist groups, violent homegrown Sunni Islamist extremists, as well as the Air India bombers and the Liberation Tigers of Tamil Eelam – all minority groups in Canada. It lists primarily Muslim organizations as terrorist threats, and refers to “ongoing struggles in the Middle East” as “another example where foreign conflicts pose a threat of international terrorism”.

  2. The second publication is a report from the Financial Action Task Force (“FATF”), an intergovernmental organization (of which Canada is a founding member) formed by the G7 group of countries to combat money laundering, which “informs RAD’s work and understanding of risk, including the audit selection process.” The FATF report refers to 10 terrorist groups, eight of which are Muslim organizations. 

  3. The third publication was issued by the federal government in 2015 and is entitled The Assessment of Inherent Risks of Money Laundering and Terrorist Financing in Canada. It is often referred to by the acronym “NIRA”, which refers to “National Inherent Risk Assessment”. This document is “the key policy tool by which Canada identifies, assesses and understands its money laundering and terrorist financing risks” in accordance with the FATF. This document lists 10 terrorist groups, of which eight are Muslim and two are non-Muslim (one Sikh and one Tamil)


Details to further explain these claims can be found in the Charter Challenge documents. 

The Team - The Review and Analysis Division (RAD)

The Charities Directorate of the CRA has two separate groups that conduct audits of charities and have the power to revoke charitable status. The first is known as “Compliance Division”. It handles the bulk of audits, and addresses most issues in respect of the income tax act as it relates to registered charities (such as the requirement to keep adequate books and records). The second group is the “Review and Analysis Division”, known almost universally by the acronym “RAD”. RAD is responsible to prevent the abuse of registered charities for the financing of terrorism, and has its own, specially trained team of auditors to conduct investigations relating to charitable organizations who may be abusing the charitable registration system.

There is limited online information about RAD, but this page provides further details.

While RAD claims not to track religious affiliations of charities audited, a study by the International Civil Liberties Monitoring Group found that between 2008 and 2015, 75% of the charities who had their charitable status revoked by RAD were Muslim charities. In a hearing before the Standing Senate Committee on Human Rights, senior CRA personnel testified that, since 2008, RAD has completed 39 audits, and 12 of the 14 revocations of charitable status were Muslim charities.

RAD’s scrutiny of Muslim charities is based on a problematic government risk assessment that unfairly characterizes Muslims as the primary risk for financing terrorism. Furthermore, RAD’s investigation of the Muslim Association of Canada (MAC) has heavily relied on Islamophobic sources throughout every stage of the audit process, including the use of a “link analysis” technique that attempts to draw connections and insinuate associations.

Details to further explain these claims can be found in the Charter Challenge documents. 

Stage 1 - The Risk Assessment

In this stage, CRA analysts conduct research to identify risk indicators that may suggest a charity is not complying with its obligations under the Income Tax Act. The risk indicators may include issues related to financial reporting, fundraising, political activities, or non-charitable activities. Based on the risk indicators, the CRA assigns a risk level to the charity. The risk level helps to determine the priority and extent of the audit. Risk assessments completed by the Review and Analysis Division (RAD) also identify risk indicators for terrorism financing and abuse.

By the time MAC was informed that it had been selected for a RAD audit, RAD had already undertaken significant planning for its audit of MAC. A key part of this preparation is a remarkable, and troubling, 65 page document entitled “RAD Audit Referral Analysis”, created on April 22, 2013 – two years before MAC was notified of the audit – and was modified prior to the start of the audit on August 27, 2015.

The Risk Assessment heavily relied on very problematic sources. The CRA’s failure to even conduct the most basic due diligence on the sources being considered and relied on, is shameful and would never be contemplated with respect to any other faith or ethnic group, a fact highlighted by MAC’s lawyer in closing arguments.

Who did the CRA rely on?

Tom Quiggin

Tom Quiggin is a far-right agitator and media personality. His work is blatantly Islamophobic, and it is difficult to imagine that anyone takes his writings seriously (although apparently RAD did so).

In 2014, Quiggin published a report called “The Muslim Brotherhood in North America” which the CRA references. In  it, Quiggin alleges widespread links between Canadian Muslim civic organizations, including charities, and terrorist organizations around the world.

Reputable Canadian media (Maclean’s magazine) calls the Quiggin report “far-fetched” and notes that it “risks vilifying an already at-risk community”.  Under cross- examination, a senior member of the RAD’s audit team, [Name Redacted], acknowledged that she was given the report to read when she was onboarded and also conceded Mr. Quiggin’s posts were racist and Islamophobic.

In 2017, in the aftermath of the Quebec City mosque massacre, he published a despicable blog posting which seemed to insinuate that the mosque attacked had terrorist links and that the massacre may have been an “inside job” by a member of the Muslim Brotherhood. In 2018, he was quick to claim that the April 2018 Toronto van attack was an act of “Islamist terror”, and specifically blamed it on the Muslim Brotherhood. He claimed that the Toronto Star and CBC have ties to “Islamist terror networks” and that CBC “willfully promotes Islamist extremism/terrorism”.  Quiggin has also claimed that there are only two types of Muslims, “extremist” and “not yet extremist.” 

He has claimed that “Justin Trudeau supports terrorist front groups” and is “politically accountable & responsible for Islamist terror attacks.” He claims that the January 6, 2021 attack on the U.S. Capitol had an “entrapment element”. He has tweeted, “Justin Trudeau is found dead in his bed, strangled with a pair of Halal socks, given to him by Cabinet Minister Omar Alghabra.” 

Quiggin is also a former military intelligence officer most recently known as one of three named leaders of the Truckers Convoy in 2022. 

Lorenzo Vidino

The CRA has heavily relied upon the testimony of Lorenzo Vidino who is another unreliable source with many questionable links to numerous anti-Muslim think tanks in the United States and Europe, and has published in various anti-Muslim outlets. Most of his publications are with anti-Muslim institutions, with a history of producing anti-Muslim research and promoting voices supporting anti-Muslim legislation. 

The CRA references a report published by Mr. Vidino called “The Muslim Brotherhood In Austria”. This report was financed by Austria’s domestic intelligence agency—the Office for the Protection of the Constitution and Counterterrorism (Bundesamt für Verfassungsschutz und Terrorismusbekämpfung)—as well as the Austrian Integration Fund (Österreichischer Integrationsfonds), which has a history of producing anti-Muslim research and promoting Muslims who support anti-Muslim legislation.

Mr. Vidino’s report served as a catalyst for the Austrian government’s anti-Muslim policies, and particularly the drive against “political Islam” and the “Muslim Brotherhood” in Austria. The report effectively elevated the Muslim Brotherhood’s threat level to that of terrorist groups such as al-Qaeda and ISIS. Following this, the Austrian police launched “Operation Luxor” against a Muslim Brotherhood network, leading to dozens of arrests after a former ISIS sympathizer killed four people in Vienna.

This has had devastating consequences for the Muslim civil society and human rights groups currently challenging Islamophobia in Europe.

Mr. Vidino promotes conspiracy theories about the Muslim Brotherhood and has been exposed as a paid tool for smear campaign against Muslims, to the point where other academics are refusing to be associated with him.

Brian Daly

The CRA makes repeated references to Islamophobic articles from the Toronto Sun written by journalist Brian Daly.  Mr. Daly’s articles contain false and misleading information and wrongly accuse MAC of supporting terrorist groups. Mr. Daly’s articles have been retracted by the publisher of the Toronto Sun.

The 2014 articles published by Daly were a smear campaign to damage the reputation of the organization.

Point de Bascule

The CRA makes repeated references to blog posts from Point de Bascule, an Islamophobic website. The CRA themselves note that it “is a Montreal based website known to depict Muslim organizations unfavourably and to level accusations against a number of them for allegedly supporting terrorism and undermining Western values” such that “articles from this source may display important editorial biases in their content and coverage.” Despite this, the CRA relies upon it.


The CRA makes a reference to what the CRA admits in the document itself is another “blog of questionable reliability” called BlazingCatFur. “Questionable reliability” is a considerable understatement. “Blatantly Islamophobic” would be closer to the mark.

Alternative Angle

The CRA makes reference to another unverified post in the blog Alternative Angle, authored by an author named Jonathan Halevi, a retired lieutenant-colonel and intelligence officer with the Israel Defense Forces, and who published a misleading translation of a Toronto imam’s prayer, alleging the prayer was antisemitic. This was later disproven by the Toronto Star. 

It is very troubling and problematic that government agencies like CRA and RAD are resorting to questionable and unreliable sources to make serious accusations about reputed organizations and many leaders in the Muslim community. This defies and ignores any “Norms of Fairness” that form the bedrock of justice and the rule of law.

Details to further explain these claims can be found in the Charter Challenge documents. 

Stage 2 - The Desk Review

The desk review is a document prepared by the audit team based on the risk assessment. The report outlines the objectives and scope of the audit. It provides information related to the charity for auditors to read prior to a field visit in order to familiarize themselves with the file and any potential issues. The desk review serves as a roadmap for the audit team, outlining the areas that need to be examined in detail during the audit.

The CRA Desk Review included the same Islamophobic sources that were in the Risk Assessment, such as Mr. Lorenzo Vidino, Mr. Tom Quiggin, Point de bascule, and Mr. Brian Daly. However, there is an important distinction with the Desk Review. 

The Risk Assessment identified some of these sources as possibly problematic and anti-Muslim (but still relied upon them), whereas the Desk Review relied upon them without any qualification. 

Specifically, the sources relied upon by the CRA in the CRA Desk Review were problematic for a number of reasons. Firstly, they consistently present a picture that Muslims are taking over the West, variation on the white supremacist Great Replacement Theory, which perpetuates the false and harmful narrative that Muslims are a threat to Western societies. This not only fuels anti-Muslim sentiment but also undermines the efforts of Muslims and Muslim charities who are trying to integrate and contribute to their communities.

Secondly, these sources often suggest that Muslims cannot be trusted and are dishonest, which is not only unfair and baseless but also contributes to the marginalization and stigmatization of Muslim individuals and communities. This type of rhetoric was clearly present in the audit preliminary findings.

Thirdly, these sources often present Muslims as suspicious of wrongdoing, which is not only untrue but also contributes to the harmful and discriminatory targeting of Muslims. 

This lack of qualification and acknowledgment of potential biases carried the prejudice against MAC and Muslims from the analysts to the auditors who relied on the Desk Review as their starting point for the audit. By relying on such sources that may have an inherent bias against Muslims, the auditors undermined the integrity and fairness of the audit process.

Details to further explain these claims can be found in the Charter Challenge documents. 

Stage 3 - Audit Team Onboarding

Once the desk review is complete an audit team is onboarded and audit plan is prepared.

It became clear during the charter challenge cross examinations that Mr. Tom Quiggin was central to the onsite audit team’s approach. In cross examination, a CRA auditor admitted that she was given the Tom Quiggin report called “The Muslim Brotherhood in North America” to read when she was onboarded into the MAC audit team. 

If the alleged relationship between MAC and the Egyptian Muslim Brotherhood was central to the audit and the fact that the auditors were given the Tom Quiggin report before auditing MAC, then clearly the audit was biased against MAC from the outset. 

  • The Quiggin report is part and parcel of his conspiratorial approach and claims to identify Muslim Brotherhood adherent individuals and organizations in Canada. Quiggin was and continues to be subject to several defamation lawsuits. He was able to escape responsibility for several of them by claiming bankruptcy before the matter proceeded to trial. 

  • The central claim of the report is that Muslim groups have a policy and process of denial and cannot be trusted. This claim effectively subverts any effective means of Muslims defending themselves. 

  • Ultimately, the report suggests that the Muslim Brotherhood and its adherent organizations in Canada pose a threat to Canadian security and the values of Canadian democracy. The Quiggin report is known to be controversial and has been criticized for its lack of evidence and for promoting anti-Muslim sentiments. The Quiggin report has been accused of using sweeping generalizations and making unsubstantiated claims about the Muslim Brotherhood and Muslim organizations in North America. 

According to cross examinations, the CRA did not filter the report, or offer alternative expert reports on the topic for audits. The report’s claims were the starting point of the audit without critically evaluating them or seeking alternative perspectives, which undermined the integrity and fairness of their audit.

As observed in the AFL, this resulted in a confirmation bias, where CRA auditors only looked for information that supported their preconceived notions and ignored evidence that contradicted their initial impressions. They referred to responses given by MAC as “less than clear” and “prepared”. The CRA even implies deception on the part of MAC in its responses about the Muslim Brotherhood.

Details to further explain these claims can be found in the Charter Challenge documents. 

Stage 4 - The Onsite Audit

In this stage, the audit team conducts onsite visits to the charity and interviews key personnel. The team may also request documentation such as financial statements, bank statements, donation receipts, and other records. The audit team examines the charity’s books and records to ensure that it is complying with the requirements of the Income Tax Act. The team also verifies that the charity’s activities are consistent with its stated charitable purpose.

The audit was extensive and thorough. The CRA auditors traveled the country visiting every Mosque, school, and community center that MAC operated. They audit team interviewed many individuals. 

The CRA’s approach may have been biased from the start, with auditors looking for any information that could be used to justify their suspicions about MAC. Some examples include:

  • Auditors searched every office, room, closet and drawer in every MAC location, often without informing MAC representatives. They took photographs of all books and teaching materials, particularly those in Arabic. 

  • CRA auditors were caught copying files from a MAC official’s computer without consent, for which they later apologized through legal correspondence. 

  • CRA auditors pressured MAC officials with administrative requirements that were not in regular practice. 

  • CRA officers also requested personal emails of several MAC employees and volunteers, which was not standard practice.

  • Upon comparison, CRA interview transcripts were inconsistent with MAC interview notes. MAC complained about the discrepancies. MAC observed that the CRA’s notes transcript had misconstrued answers provided by MAC and the CRA had inserted statements that were never said. Some instances appeared malicious to create a false set of facts. After submitting a complaint, the CRA refused to fix the documents, but instead renamed the documents from interview transcripts to interview notes.

Details to further explain these claims can be found in the Charter Challenge documents.

Stage 5 - The Administrative Fairness Letter

After completing the audit, the CRA prepares an administrative fairness letter that summarizes its preliminary findings and evidence. The letter provides the charity with an opportunity to respond to the CRA’s findings and provide additional information or clarification. The CRA considers the charity’s response before making a final decision on whether the charity is complying with its obligations under the Income Tax Act.

The CRA AFL’s language and framing are clearly rooted in the Quiggin and Vidino narratives. The CRA also continues to rely on the Brian Daly Sun articles. 

However, the AFL introduces additional biased and Islamophobic sources that are deeply problematic. The use of such sources in a CRA audit is particularly concerning, as it raises questions about the impartiality and fairness of the audit process. These are some examples:

Haras Rafiq

Haras Rafiq is the managing director of Quilliam Foundation based in the United Kingdom. The CRA has relied on comment by Haras Rafiq given in a 2015 Senate report “Countering The Terrorist Threat In Canada” that suggests that the fundamentalist brand of Islam – Wahhabism – is being spread in in Canada through wealthy Saudis, Qataris and Kuwaitis using Canadian charities as a conduit.

The Quilliam Foundation is a “counter-extremism” think-tank that has worked with a number of individuals and organizations that promote anti-Muslim views. One of its primary areas of focus is “emphasizing the difference between Islamism and Islam.”

The organization has been criticized by many civil rights organizations because the think-tank’s views are based on faulty science and only seek to criminalize and securitize Muslims. Quilliam has historically supported the U.K. government’s Prevent strategy aimed at preventing “radicalization.” Prevent has been criticized by government officials, human rights experts, academics, teachers, and community organizers for securitizing and criminalizing Muslims. 

In 2015, Haras Rafiq, criticized the Prevent strategy for not doing enough, stating the U.K. has “half a prevent strategy,” and that “we don’t have a strategy preventing people from radicalization in the first place.”

In 2010, a Guardian article revealed that a document prepared by Quilliam was sent to a top British security official, accusing a number of peaceful Muslim organizations with sharing terrorist ideologies. This included the Muslim Council of Britain, the primary mainstream organization in the U.K.  

Quilliam has worked with the Gatestone Institute. In October 2013, Quilliam organized a press conference alongside Tommy Robinson and his cousin, Kevin Carroll. Robinson and Carroll at the time were part of the far-right English Defense League (EDL). 

Middle East Media Research Institute (MEMRI)

The CRA has relied upon reports and videos by MEMRI, and translated texts offered by this organization, to draw conclusions in areas of public benefit related to MAC.

MEMRI was co-founded in 1998 by Yigal Carmon and Meyrav Wurmser, former members of Israeli Defense Forces that supplies translations relied upon by many members of the Islamophobia network defined by American Progress.

MEMRI has an established reputation for distributing highly selective, distorted, and inaccurate translations of Arabic and Persian media. Through these selections the organization attempts to portray Muslims and Arabs as being inherently irrational and violent. MEMRI is part of the inner core of the U.S. Islamophobia network.

Similarly, Brian Whitaker, former Middle East editor (2000-2007) for The Guardian newspaper, MEMRI “poses as a research institute when it’s basically a propaganda operation,” and goes on to say that the items it translates are chosen largely suited to its political agenda, and “are unrepresentative and give an unfair picture of the Middle Eastern media as a whole.”

MEMRI offers research on media in the Arab world, which those in the Islamophobia network depend on to make the case that Islam is inherently violent and promotes extremism. Jihad Watch’s Robert

Spencer hails MEMRI as “a goldmine of translated material from the Arabic speaking world which really gives one some amazing insights into what our opponents in the war on terror are thinking.”  Frank Gaffney at the Center for Security Policy calls MEMRI “indispensable” and relies on its translations to exaggerate the threat of the Muslim Brotherhood and radical Islam’s infiltration of America. The antiMuslim grassroots organization ACT! for America uses a MEMRI-supplied video of a Muslim woman being stoned in Sudan as evidence of the brutality of Sharia law.

MEMRI’s selective translations have contributed to Islamophobia. 

Egyptian Embassy in Canada

The CRA relies upon comments made by the Egyptian Embassy in Canada to draw conclusions in the AFL, particularly on sections related to the Egyptian revolution.

The Egyptian Embassy is an extension of the Egyptian regime which is responsible for overthrowing a democratically elected president. Two large sit-ins in Cairo and smaller protests across Egypt took place to denounce the military takeover and demand the reinstatement of President Morsi. In response, it is this same Egyptian government that ordered forces to repeatedly open fire on demonstrators, killing over 1,150. It is the worst massacre in Egyptian history.

Furthermore the Egyptian Embassy in Ottawa is also responsible for bringing and hosting Egyptian Minister Nabila Makram in Canada who told an audience in Mississauga, Ontario, that anyone speaking “against Egypt abroad” will be “punished.” A video of Makram’s comments shows her making a slicing motion across her neck while making the remark. This comes after Egypt’s well documented record of arbitrary detentions, violence against political opponents and other human-rights abuses since General Abdel Fattah al-Sisi seized power via a military coup.

In response to this incident then Canada’s Foreign Affairs Minister stated “Canada continues to support the desire of the Egyptian people for democracy, human rights, the rule of law and greater economic opportunity. The rights to free speech and expression are fundamental to democracy and our government will always defend Canadians – and people around the world – in their ability to exercise these rights.”

Details to further explain these claims can be found in the Charter Challenge documents.

Other events that biased the CRA Audit

Arab Spring

After the 2011 revolution in Egypt that ended a three-decade-long presidency of Hosni Mubarak, the world celebrated. It was welcomed by the Canadian government and every country around the world. Many Canadians of Tunisian, Egyptian, Syrian and other origins choose to participate in democratic transitions in their home countries. This was a right these Canadians chose to exercise.

In Canada, Canadian citizens joined different political parties abroad, communities held election debates and discussions, participated in the media discourse, voted in the election through their embassies, and some travelled to their home countries to take part. 

Prior to 2012 and 2013, the Muslim Brotherhood was not considered a significant concern to Western countries, including Canada, the United Kingdom and the United States. However, with the rise of the Arab Spring in Egypt and the election of President Morsi, the Brotherhood gained international attention. Following Morsi’s ousting in a military coup in 2013, some countries began to push a false narrative linking the Brotherhood to terrorism, in an effort to support the Egyptian regime and the agenda of certain Gulf States.

The CRA’s AFL adopts this narrative. While the CRA did not express concerns about MAC prior to 2013 (MAC was always transparent in its website and its bylaws how its understanding of Islam connected to Imam Hassan Al-Banna), the agency’s interest in the organization and its relationship to the Muslim Brotherhood came after 2013. The CRA’s views towards the Muslim Brotherhood in its report echoes arguments made by far-right and authoritarian regimes, and individuals such as Quiggin and Vidino.

Transnational Islamophobia

In 2014 with a rise of Islamophobia in Canada, there was also a rise in state-sponsored campaigns abroad directed against mainstream Canadian and American Muslim organizations.

In November 2014 the United Arab Emirates issued a terrorist listing that included the Muslim Brotherhood and local affiliates as “terrorist groups”. It followed a similar move by Saudi Arabia in March 2014. Both targeted primarily religiously-affiliated groups. The UAE went as far as listing several organisations based in the US and Europe.

Human Rights Watch immediately condemned the designations. “In the UAE it’s now a case of ‘you’re with us or you’re a terrorist,’” said Sarah Leah Whitson, Middle East and North Africa director. 

The terrorist listing by the UAE was an attempt to to suppress Muslim democratic activism abroad, particularly those who share the ideology of the Muslim Brotherhood, in hopes that western countries would follow suit. However, such attempts in the United States and the United Kingdom have failed. This is particularly clear in the US. The State Department immediately rejected the UAE designations of US-based charities. More broadly, policy makers have advised against labelling the Muslim Brotherhood a terrorist entity or a group with links to violence because the implications would mean that almost all long-established U.S. Muslim organizations, with no ties to violence, ranging from the civil society organizations, non-profits and charities, to campus groups, could conceivably be linked to funding and promoting terrorism.


Canada has not listed the Muslim Brotherhood as a terrorist entity, despite Parliamentary discussion under the Harper government on this topic.

Yet, the CRA chooses to take a different position than the Government of Canada and argues that the Egyptian Muslim Brotherhood is a listed entity according to other countries.

[Name Redacted], a senior auditor within RAD, during her cross examination explicitly acknowledged that Syria, Russia, Egypt, Saudi Arabia, the United Arab Emirates, Bahrain and Libya are all dictatorships, use violence against their citizens, and suppress democracy, yet RAD relied upon actions taken by these states in its audit of MAC and in the AFL to draw its conclusions about the Muslim Brotherhood.

The United Kingdom's Muslim Brotherhood Review

The CRA has relied upon references from the UK Government’s Muslim Brotherhood Review commissioned on December 17, 2015 and the UK House of Commons Foreign Affairs Committee review on “Political Islam” and the Muslim Brotherhood.

In 2014, the United Kingdom announced a ‘Government Review’ into the activities of the Brotherhood, under pressure from its partners in the Gulf. The timing of this announcement was questionable considering it came right after the U.A.E. and Saudi Arabia denounced the Brotherhood as a terrorist group, rendering membership and support of the group as unlawful.

The 2015 commissioned report by the British government and led by the UK ambassador to Saudi Arabia Sir John Jenkins, was triggered by influence from the United Arab Emirates, who played a significant role in the commissioning of the report. In November 2015, the Guardian reported that the UAE had lobbied former Prime Minister Cameron to crack down on the Brotherhood in exchange for lucrative arms and oil contracts. In March 2014, UAE’s Mohammed Bin Zayed met Cameron on the sidelines of the Nuclear Security Summit in the Netherlands and discussed “a number of regional and international issues”. Less than a month later, on 17 April, Cameron announced the review into the Brotherhood and nine days after that, Jenkins met with senior Abu Dhabi official Khaldoon al-Mubarak in his first UAE visit as part of the review.

The report was also lobbied for by the head of the Egyptian regime, Abdel Fatah al-Sisi. On the day Sisi arrived in Britain for a visit in 2015, the UK Foreign Office confirmed the key findings of the review. 

Academics have criticized this report as deeply flawed, misleading, and a mischaracterization of the Brotherhood.  Foreign policy experts and academics told the British parliament’s foreign affairs committees that the report “overemphasized the group’s connection to violence and was at times inaccurate” and that it “overplayed the connection between the Brotherhood and violence and violent groups.”

In 2016 the UK Parliamentary Foreign Affairs Committee (FAC) completed an inquiry into the government’s policy towards “Political Islam” which concluded that political Islamists were a “firewall” against violent extremism and should be engaged with, either when in power or in opposition. The parliamentary committee review is seen as more credible and it strongly criticised the UK Muslim Brotherhood Review that was headed by Sir John Jenkins and also called into question the credibility of its methodology that was lacking in transparency. The parliamentarians accuse the UK government of mishandling the review and criticise it for its failure to provide their committee with a full copy of the report.

Having said all this, it is important to emphasize that even the flawed Jenkins report concluded that it was inappropriate to label the Brotherhood as a terrorist organization. Having failed to find backing for this extreme course, the commission instead opted to use language to connect the Brotherhood to violence and extremism, to which experts reacted as noted above.

The CRA's Problematic Terrorism Financing Audit Approach

This links analysis used by the CRA, however, has been severely criticized in the academic literature on financial surveillance as prejudicial and contrary to core values around associational rights of citizens.

The AFL is centered around the allegation that an organizational link between MAC and the “Muslim Brotherhood Organization” exists. 

In contrast, any given church group would be expected to maintain contacts and engage in correspondence, visits, exchanges of experience, meetings, conferences, joint campaigns, and other activities with churches around the World belonging to the same denomination. The same is true of labour unions, political parties, environmental movements, athletic associations, boy scouts, girl guides, hobbyist clubs of all kinds, and any other organization that professes a commitment to ideals, beliefs, values, or goals that are transnational in character. 

In the case of MAC, the CRA interprets such activity as sinister, deceptive, and evidence of MAC furthering the goals of a foreign organization. This is discriminatory on the face of it.

CRA Ignores Vast Body of Expert Literature

The AFL relies on a small number of thoroughly discredited sources and ignores the vast body of expert analyses in the literature. This is especially problematic since the CRA is not an authority to evaluate an individual’s or group’s understanding of Islam, as explained by Dr. Mohammed Iqbal Alnadvi, the chairman of the Canadian Council of Imams and one of the leading Islamic scholars in Canada. He states:

“Would it be acceptable for the CRA to criticize a Catholic Church’s recommendations to sacrifice something for Lent? Or a synagogue’s celebration of Passover by abstaining from leavened bread? These are common faith positions for people practicing these religions which a government agency has no business or jurisdiction debating.

The CRA refers to their practice as a “public benefit test,” but it is essentially subjecting Islam in particular to a quasi-values test that undermines the Canadian value we can all agree on despite our differences—a value enshrined in our Charter: freedom of religion.

It’s time for the CRA to better define its mandate and guidelines for charities and acknowledge that it is not within its purview to be auditing the religious beliefs and practices of Canadians.”

The CRA is also not a competent authority to evaluate the history of a group such as the Muslim Brotherhood or to situate that group within the mainstream Muslim community. In fact, having failed to reach a conclusion as to what is MAC’s understanding of Islam (or even the Brotherhood’s understanding of Islam for that matter) the AFL has simply fallen back on Islamophobic tropes that seek to exclude Islam from public life.

AFL Smears Respected Community Leaders

The CRA is aware that MAC is a national organization made of respected community members, volunteers and staff. Rather than offer objective findings that allow for a fair response, the language and tone of the AFL continuously attempts to paint individuals as deceitful, dishonest, and condemnable for unsupported and unsubstantiated allegations.

MAC’s leadership are individuals with integrity who have committed their lives to serving Canadians. The AFL is prejudiced and has overstepped in smearing the reputations of people.

The CRA has maliciously included names of committed employees, volunteers, and youth workers who work tirelessly to serve their community. The CRA has inappropriately included the names of donors.

This practice and is not the first time the CRA is accused of this inappropriate practice. A complaint against the CRA has been brought further by the Canadian Council of Imams as a result of the content in the AFL of the Ottawa Mosque revocation.