1.1.1 The Muslim Brotherhood

The AFL at page 11 begins with the law as expressed in Vancouver Society of Immigrant and Visible Minority Women v. Minister of National Revenue in relation to a review of a charity’s purpose and whether those purposes are charitable at law, whether there is a clear relationship and link between the activities and the purposes, and whether the activities themselves do not fall outside the bounds of what has been judicially recognized as charitable. In this regard, at page 11 the AFL states that, “Where an activity is, or becomes, a substantial focus of an organization, it may no longer advance a stated purpose. Rather, the activity may be in support of a separate or collateral unstated purpose—or form a separate or collateral purpose in and of itself.” However, with respect to the Muslim Brotherhood, the AFL then produces neither any qualitative or quantitative analysis with respect to how under the ITA the Charity “advanced” the Muslim Brotherhood, but instead produces a series of emails and correspondence rather than any material qualitative or quantitative use of resources that would advance such purpose.

The AFL at page 13 lists the charitable purposes of the Charity as set out in its governing document, and then concludes that during the Audit Period the Charity operated beyond these purposes in two aspects, i.e., advancement of the Muslim Brotherhood organization and the purchase of real estate as an end in and of itself.

The AFL states at page 14 that, “…based on the information available to CRA, it appears as though many of the Organization’s activities appear to be in furtherance of the Muslim Brotherhood organization, and the extent to which they occur, would constitute the advancement of a non-charitable, collateral, purpose.” As well, at page 18, the AFL states that, “preliminary audit findings appear to suggest that the Organization has connections to individuals or groups associated with extremism, violence, and/or terrorism.” Further, on page 20 the AFL concludes that, “In the Organization’s case, for example, advancing the Muslim Brotherhood ideology is more than advancing religion, it also appears to mean advancing the Muslim Brotherhood organization”. Lastly, on the same page the AFL indicates that, “…support for the Muslim Brotherhood by the Organization’s senior leadership appears to be manifesting itself in the activities and decisions made within the Organization”.

We should also note that at page 20 of the AFL, the CRA states that, with respect to any link with Muslim Brotherhood as an ideology as opposed to an organization, “During the registration process, very little was mentioned about what this meant. Common law has established that not everything done in the name of religion is charitable”. This comment suggests that somehow when the Charity obtained charitable status in 1999 it misled or was not transparent to CRA. However, later at page 42 of the AFL when stating that the Charity cannot rely on charitable registration as a means of due diligence when making gifts to other qualified donees, CRA states that, “Simply put, being a registered charity means that at the time of registration, an organization’s purposes were deemed to be charitable and that they produced a public benefit”. In this regard, it is inconsistent and unfair to suggest that the Charity was being non-transparent all the way back to its registration in 1999 while also declaring that the CRA’s role in the registration process is limited to confirmation that an entity’s purposes are charitable.

In concluding on this area, at page 32 of the AFL the CRA alleges that, “The audit found that the Organization appears to conduct and support activities that further the advancement of the Muslim Brotherhood organization,” and that, “…the Organization appears to be advancing the interests of the Muslim Brotherhood Organization and its political party the Freedom and Justice Party.”

As indicated in our letter of August 12, 2021, the AFL fails to provide any evidence of even a single transaction between MAC and the Muslim Brotherhood or that it is a division of the Muslim Brotherhood. No evidence is provided to indicate that MAC’s charitable property, including its funds, personal property, real property, volunteers or employees, provided any support to the Muslim Brotherhood. As well, the allegation that support for the Muslim Brotherhood manifested itself in activities or decisions by MAC is completely unsupported by any facts whatsoever. The only things the AFL points to in support of these conjectures are communications received by [REDACTED], a former director and officer of MAC, and [REDACTED], the current executive director of MAC. In this regard, these individuals have been singled out for receiving unsolicited mass emails to their generic email accounts (president@macnet.ca and ed@macnet.ca respectively) based on which the CRA has attempted to cast serious allegations of associations and relationships.

In addition, in order to indicate that [REDACTED] or [REDACTED] were associated with the Muslim Brotherhood, and thereby influenced decisions made by MAC, the AFL would need to evidence that either individual has de facto or de jure control of MAC. However, no reference is made in the AFL to any section of the ITA or case law concerning de facto or de jure control. As [REDACTED] is an employee of the corporation and only has an officer position, he has no legal control of MAC. Further, [REDACTED] ceased being a director and officer of MAC on December 12, 2012 as noted in the AFL. As a director, [REDACTED] would have exercised only one vote on the board of directors of MAC, which would not be sufficient to exercise control. While [REDACTED] continued to be a corporate member of MAC thereafter, this would have provided him with only a single vote as a corporate member out of hundreds. The AFL notes at page 22 that [REDACTED] was present at a board meeting following his resignation as a director and officer, however, this is not true. [REDACTED] did not attend board meetings after his resignation. The single meeting referenced in the AFL was a meeting called by the Board of Directors and a cross section of members based on background, gender, age, etc. were selected to participate. Furthermore, the AFL does not provide any evidence to suggest that his mere presence indicated de jure or de facto control over the corporation, or that in his position as a corporate member he made any material decisions, in general or in support of the Muslim Brotherhood.

Furthermore, [REDACTED] was at all times transparent with MAC, the community, the public and the media about his role in Egypt. His story is well documented on the public record. [REDACTED]’s advisory role was with the President of Egypt, and not the Freedom and Justice Party or the Muslim Brotherhood. The Presidency was independent of any political party and included a number of individuals from various political backgrounds, such as the President’s Chief of Staff, Ambassador Rifa’a Tahtawi and others. In fact, President Morsi resigned as chairman of his party upon assuming the Presidency. [REDACTED] is recognized provincially and in his home city of London, Ontario, for his professionalism and dedication. Over the course of the past 15 months, he has been the primary leader of London, Ontario’s “Critical Care Covid-19” pandemic response overseeing mobilization of the city’s critical care resources to meet the overwhelming demand for healthcare. There has never been any suggestion whatsoever that his previous personal political work in Egypt was in any way unlawful or a security concern.

With respect to [REDACTED], again, the AFL does not demonstrate that he had any legal or effective control over MAC. The AFL alleges at page 22 that “…some communications appear to indicate that the leadership of the Muslim Brotherhood appears to exhibit some authority over Mr. [REDACTED]”, but no subsequent connection is made to allege extending that control over MAC. The AFL points to a number of invitations that were sent to Mr. [REDACTED]’s email as unsolicited mass emails that were invitations to various conferences. Invitations for the conferences have long been shared with Muslim organizations and community leaders across the world. These invitations are often sent to president@macnet.ca or ed@macnet.ca and are unsolicited, generally mass email broadcasts. Both these e-mail accounts are publicly available, widely known, and clearly associated with the organization’s leadership and as such anyone in the world can email them.

Having said that, the CRA extracted over 96,000 emails from [REDACTED]’s email account over the Audit Period but chose to highlight 4 unsolicited conference invitations that were sent to [REDACTED] by mass email broadcasts. None of these emails were responded to by [REDACTED]. These are a select few among many conference invitations that Mr. [REDACTED] receives annually.

At page 22 of the AFL, it states that, “on May 17, 2013, [REDACTED] received an email from [REDACTED].” The AFL then attempts to link [REDACTED] to Dr. Mahmoud Ezzat who is a member of the Muslim Brotherhood organization. However, this example ignores that [REDACTED] is a corporate member of MAC. This email was sent to [REDACTED] asking for a nomination for someone to attend the 2013 International Symposium for Muslim Women. This email was not responded to by [REDACTED] and neither were any follow-ups. It is important to note that the Charity had no prior precedent or practise of sending representatives to international conferences.

In addition, at page 26 and 27 of the AFL, the CRA purports to note a similarity between MACs general operating by-laws and those used by a Muslim Brotherhood organization, and also suggests that membership transferability between MAC and organizations outside Canada suggests a linkage to the Muslim Brotherhood. This conclusion is completely unsupported. MAC’s general operating by-laws are a legal document adopted to comply with the provisions of the Canada Not-for-profit Corporations Act under which it is incorporated. No registered charity is required to review corporate documents on a global basis to see if they might possibly appear to be similar to those used by other foreign organizations. Moreover, there are many organizations globally that adopt a similar understanding of Islam, and some adopt the ideology of Imam Hassan Al-Banna. MAC has no connection with any of these organizations. Some of these organizations abroad may have practises of giving weight to “reference letters,” however MAC’s membership process as per MAC’s regulation clearly explains the purpose of a reference letter. As well, MAC has hundreds of members, many who are transitional families who immigrated to Canada and others who are second and third generation. Over the lengthy period of the audit, the CRA found 8 examples of requests, 5 are individuals who came to Canada and 3 are individuals leaving Canada. This clearly demonstrates that this is not a standard practise for movement of members.

As well, the AFL at page 28 alleges that MAC supports groups that are openly pro- Egyptian Muslim Brotherhood or support the former Egyptian President Morsi of the Egyptian Muslim Brotherhood’s Freedom and Justice Party and points to Egyptian Canadian Coalition for Democracy (ECCD) and Egyptian Canadian Home Organization (ECHO) as being two such groups. The AFL alleges at page 30 that several of MACs directors, like officials, or members hold senior positions within the ECCD. However, the listed examples at page 30 only indicate individuals who are corporate members of MAC. Again, no evidence is provided to support that these 6 corporate members have de facto or de jure control over MAC as a result of their 6 corporate votes out of hundreds of members. As well, none of these individuals are directors or like officials of MAC so it is not clear why these references were used in the AFL other than to allege vague and speculative conjectures against MAC.

In addition, at page 31, the AFL alleges that these same individuals are conducting prohibited activities, i.e., directly, or indirectly, supporting or opposing a political party or a candidate for public office. However, this is only a prohibited activity for registered charities. ECCD and ECHO are Canadian registered non-profit organizations, and their activities cannot be said to be activities of MAC based upon an immaterial overlap in corporate membership only. As well, the AFL attributes use of MAC real properties by these members as unpaid use of the space by ECCD and ECHO. However, the space was booked by these members in their capacity as corporate members of MAC. MAC does not restrict any of its members from participating in external activities or organizations. This is their right to freedom of expression and association as Canadians and what they do or say in other capacities outside of MAC is not representative of or relevant to MAC.

The AFL also alleges that religious observances for President Morsi purportedly constituted support for the Muslim Brotherhood. According to Islamic teachings, when a Muslim is denied a proper religious funeral, as was the case with President Morsi, Muslims are permitted and encouraged to pray an absentee prayer, known as “salaat al ghaib”. Mosques across Canada (other registered charities), beyond just those operated by MAC, also held “salaat al ghaib” for President Morsi, an internationally renowned Muslim figure. As it relates to MAC, since this was a religious obligation, MAC had to provide to its mosques’ congregations the spiritual service to perform “salaat al ghaib”. This religious service had nothing to do with the affiliations that President Morsi had, whether it be to the Muslim Brotherhood or the Freedom and Justice Party. MAC unequivocally rejects this conclusion.

Problematic Sources Relied Upon by the CRA In Presenting Background on Muslim Brotherhood

 
In arguing that the Muslim Brotherhood is connected to violent extremism and terrorism, the CRA relied heavily on documentation provided by questionable sources. An assessment of these sources’ expertise, funding, mandate or ideological affiliation is required before reliance can be placed upon these sources, given the bias of the sources in question.

To underscore this, we briefly discuss eight examples of reports or individuals cited in the AFL as a primary source to argue that the Muslim Brotherhood is connected to violence.

In the AFL’s documentation of the Muslim Brotherhood and its links to extremism and violence, the CRA has relied solely on Islamophobic sources, without considering hundreds of sources available on the public record that speak to more credible and objective points of view.

 

Lorenzo Vidino

In presenting the background on the Muslim Brotherhood and its alleged connections to violent extremism and terrorism, the CRA has heavily relied upon the testimony of Lorenzo Vidino, an Italian American legal scholar whose research promotes conspiracy theories about the Muslim Brotherhood in Europe and the United States. Vidino is connected to numerous anti-Muslim think tanks in the United States and Europe, and has published in various anti-Muslim outlets.58 While Vidino has published a number of publications about the Muslim Brotherhood, in an interview with NPR in March 2017 Vidino stated, “I’ve been studying the brotherhood for 15 years…I maybe understand 10 percent of how it works.” Most of his publications are with anti-Muslim institutions, with a history of producing anti-Muslim research and promoting voices supporting anti-Muslim legislation. Vidino has a history of advancing unscientific theories and anti-Muslim tropes.59

In 2004 and 2005, Vidino served as Senior Analyst with Steve Emerson’s Investigative Project on Terrorism (IPT) in Washington. IPT is an anti-Muslim hate group that hallows itself for its collection of intelligence on Islamic terrorist groups, but the IPT’s chief function is presenting Islam as an inherently radical, violent, and antagonistic religion.60

In November 2005, Vidino gave an interview to the far-right, anti-Muslim website FrontPage Magazine. In late 2005, Vidino published an article titled “The Muslim Brotherhood’s Conquest of Europe” in the Middle East Quarterly (MEQ), which is published by Daniel Pipes’ anti-Muslim Middle East Forum (MEF). MEF is a research institute bankrolled by wealthy right-wing donors and MEF itself financially supports right-wing leaders and their activities.61

The CRA references an August 27 report published by Vidino called “The Muslim Brotherhood In Austria” (footnote 96 page 23). 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 research62 and promoting63 Muslims who support anti-Muslim legislation.

Vidino’s work is influenced, and it appears to be funded, by foreign states. According to MEMO, leaks reveal that in May 2017 Vidino and UAE Minister of Foreign Affairs Abdullah Bin Zayed arranged to meet, together with Mokhtar Awad, a research fellow in the GWU Program on Extremism. This meeting was organized by the UAE Ambassador to the United States, Yousef Al-Otaiba, who in email exchanges expressed his goal to “defeat the voices of islamism [sic]” in the U.S.64

Vidino is also accused of censoring research and statements by employees that criticize the UAE and Saudi Arabia, further evidence that these states exert influence over his research and activities. A former employee of George Washington’s Program on Extremism has accused Vidino of stifling academic freedom of speech. The former employee has stated that Vidino attempted to prevent him from writing a story about the death of journalist Jamal Khashoggi for The Atlantic. He said the director later asked editors at The Atlantic to remove all references to the Program on Extremism in the employee’s biography at the bottom of an article critical of Saudi Arabia and the United Arab Emirates.65

Vidino states in his testimony “In some cases they vehemently deny any link to the Brotherhood. If we keep the analysis on a formal level, they have a point…The Muslim Association of Canada would be the first name that comes to mind…They are not part of a pyramid with Cairo on top, but they have the same world view and the same MO as the Brotherhood.”66 Through the audit, it became obvious that the CRA relied on statements similar to this in order to infer links between the Charity and groups abroad. There are three serious problems with this. The first is that Vidino’s point of view is Islamophobic, and his position should have been contested and rejected in the Senate, not relied upon and validated by the CRA. It is no different than falsely claiming that all Protestants have ties to the IRA, or that the Italian-Canadian community’s charities have links to the mafia network, without any evidence supporting such spurious and prejudiced allegations. Certainly, the CRA would not adopt this stance and accuse Protestant Canadian charities of being nontransparent. The second problem is that Vidino’s comment attacks the Charity for sharing a common understanding of Islam with the founder of the Brotherhood and specifically rejects the notion of organizational links between the two. The CRA has used Vidino’s and others’ statements to reject this distinction. In fact, the CRA has responded to the Charity’s unwavering and clear stance on its ideology versus its affiliation with other organizations by accusing the Charity of a lack of transparency. As a result, the CRA has disregarded the Charity’s statements and tried to identify links where none exist, not even according to Vidino. Finally, Vidino is not a source that the CRA should rely upon to develop its understanding of the Muslim Brotherhood or MAC. Referring to an individual who has been repudiated by other academics and who appears to be a channel to foreign interference in Canadian affairs diminishes the credibility and conclusion of the CRA audit.

 

Thomas Quiggin

A 2019 ATIP request with the CRA has shown that in May 2014 Alastair Bland and Cathy Hawara were aware of Thomas Quiggin’s report “The Muslim Brotherhood in North America (Canada/USA)” before it was published and that it was flagged urgently for their attention. While the AFL does not reference Quiggin, based on the ATIP results, it appears that this report was a catalyst for the CRA to initiate an audit into MAC.

Through the language of the AFL, the CRA’s understanding of the Muslim Brotherhood and its unfounded allegations of links to organizations in Canada has been heavily influenced by this report.

According to a 2014 article in Maclean’s magazine: “Quiggin’s report reads more like a doomsday manifesto, predicting the end of Western civilization at the hands of Muslims” and portrays Canada’s Muslim community as “a secretive cabal plotting the downfall of Western civilization from within”.67

After publishing the report Quiggin was sued by a number of parties. Quiggin is currently the subject of defamation claims by other Canadian Islamic organizations and Muslim leaders for defamatory misinformation printed in his reports and on social media.

Quiggin is a writer and speaker at the Manning Centre, the Gatestone Institute, and the Mackenzie Institute. He writes for the blog site Globalbrief.ca. In general, Quiggin focuses on fear-tactics in his reports, warning his audience of a possible Islamization of Canada. As it relates to The Terrorism and Security Experts of Canada Network (“TSEC Network”)68, Maclean’s Magazine reported on June 2, 2014 “Muslim Brotherhood: the new Islamist bogeyman in Canada”, that Quiggin is a “member of the previously unknown Terrorism and Security Analysts of Canada Network”. According to the TSEC Network website, it is comprised of “Canadians who are concerned about the role of extremism and terrorism in Canada…” The website contains very general descriptions of services provided by this network. It does not identify the principals or leaders of this organization. The ‘Research Library’ page is currently under construction. A number of pages contain general articles; no author is credited. In a review of the blog postings, all are authored ‘by Tom’.

Stephanie Carvin, an assistant professor of international relations at the Norman Paterson School of International Affairs, Carleton University has described Quiggin as a guy “in a basement reading Breitbart.” She further states that “Tom Quiggin has not held a government job in almost two decades. Being a “court appointed expert” is not a professional designation/job. His most recent accomplishment is being suspended by YouTube.”69

Quiggin has been discredited for many claims he has made without evidence. For example, in reference to the The Quebec City mosque mass shooting on the evening of January 29, 2017 at the Islamic Cultural Centre of Quebec City, he claimed that the mosque was targeted because it was likely transmitting tens of thousands of Canadian Dollars to terrorist entities.70 Quiggin could not deliver any proof for his claim. Instead, he was discredited by different renowned analysts, other security and terrorism experts, and media outlets as self-styled and obscure.

Haras Rafiq

Haras Rafiq is the managing director of Quilliam Foundation based in the United Kingdom. The CRA has relied on comments 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 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.”71

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.

Quilliam received a grant totaling $1,080,997 from the John Templeton Foundation, covering the period from September 2014 to June 2017. A 2015 peer- reviewed study concluded that the Templeton Foundation was a “key player in the funding of right-wing organizations.”72

In 2010, a Guardian article73 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 Robinson74 and his cousin, Kevin Carroll. Robinson and Carroll at the time were part of the far-right English Defense League (EDL). Quilliam’s senior researcher, Usama Hasan, is listed as one of the founders of the Muslim Reform Movement, a global coalition of reformers who want to “take back the faith.” Other individuals in the movement include Asra Nomani and Zuhdi Jasser. In 2015, Hasan gave a detailed interview to the Clarion Project about the “global struggle against Islamism.” The Clarion Project is listed as an organization in the Islamophobia network, and has published a vast array of anti-Muslim material.75

Middle East Media Research Institute (MEMRI)

The AFL relies upon reports and videos by MEMRI, and translated texts offered by this organization, to draw conclusions in areas of public benefit related to the Charity.

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.76

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.

Brian Whitaker, former Middle East editor (2000-2007) for The Guardian newspaper, has said that 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.”77

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.

TVA Nouvelle

The AFL relies on videos published by TVA Nouvelle to draw conclusions on speeches given by an Imam and whether the speech was contrary to public policy. In 2017, TVA Nouvelles was called out for being complicit in Islamophobia and the rise of the far-right. Protestors accused the media outlet suggesting that “the narrative they’re really pushing is that Muslim women need to be saved from our culture.”78

“It’s time to denounce the completely unethical way in which Québecor has steadily nurtured Islamophobia in Quebec,” organizers said.79 TVA Nouvelles has been accused of routinely broadcasting fake news and fomenting Islamophobia. Protesters called for the channel and journalists involved to be sanctioned for their role in intensifying Quebec’s already Islamophobic climate. They claimed the problem has been persistent for years. There are many reports of TVA Nouvelles’ Islamophobia and links to far-right individuals.

 

UK Government MB Review Report

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 former 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.80 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.81

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 released the key findings of the review.82

Academics have criticized this report as deeply flawed, misleading, and a mischaracterization of the Brotherhood.83 Foreign policy experts and academics told the British Parliament’s Foreign Affairs Committee 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.”84

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 accused the UK government of mishandling the review and criticized it for its failure to provide their committee with a full copy of the report.85

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 ambiguous language to connect the Brotherhood to violence and extremism, to which experts reacted as noted above.

Transnational Islamophobia

In 2014 with a rise of Islamophobia in Canada, there was a similar yet different state-sponsored campaign from 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. But what was surprising was that the UAE listed several organizations based in the US and Europe.86

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.87

The reality of this terrorist listing by the UAE was an attempt to suppress Muslim democratic activism abroad and the Muslim Brotherhood and those who share its ideology, in hopes that western countries would follow suit. However, such attempts in the United States and the United Kingdom have resulted in the opposite. 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, nonprofits and charities, to campus groups, could conceivably be linked to funding and promoting terrorism. Why? Almost any Muslim civil society organizations, charities, or student groups could theoretically be linked to the Muslim Brotherhood based on their shared understanding of Islam or the role played in their founding by immigrants affiliated with the Muslim Brotherhood in the 1960s and 1970s who had recently arrived in the United States. As a result, such a bill has been, rightly, seen to be an attempt to establish a legal rationale for closing down almost any U.S. Muslim organization.88 The same is true for Canadian organizations.

The AFL states on page 17 “The Organization is seemingly aware of the Muslim Brotherhood’s increasing presence on lists of terrorist entities in countries around the world. When the United Arab Emirates (UAE) announced its decision to list the Muslim Brotherhood, Al Qaeda, and Daesh, as terrorist entities in November 2014, the Director of the Masjid Toronto.. “MAC is not included in the list. You can go and fund raise over there (sic) in UAE.” It is not clear why the Organization would be concerned about the possibility of it being included on a list of terrorist organizations if it were not concerned about the activities it were undertaking or with the groups it is associating.” The CRA’s interpretation of this email that the organization may be concerned about the activities it was undertaking is cynical and removed from any context of global events. The email from the Director of Masjid Toronto was not sent out of concern of being listed by the UAE. Rather, it was a sarcastic response to the UAE’s overreach in listing US and Europe based Muslim civil society organizations that are similar to MAC.

In the US, attempts to designate the Muslim Brotherhood have failed. However, like MAC’s audit and false allegations of links to between MAC and the Muslim Brotherhood, these efforts have a chilling effect on the social and religious life of Muslims; that is, individuals and organizations consciously limit their constitutionally protected freedom of expression and activity out of fear of possible sanctions, such as revocation.

UCLA Law Professor Khaled Abou El Fadl has noted, “In the Muslim World, the bogeyman of the Muslim Brotherhood has been exploited by authoritarian governments to repress their citizens for more than half a century.” What is more recent, however, is the increasingly transnational efforts of these authoritarian governments and, in the case of the UAE, the connection with those who advocate for religious freedom in the Arab World. Generally, transnational authoritarianism refers to the phenomenon whereby regimes seek out dissidents and activists among diaspora communities beyond their borders in order to threaten or assasinate, as in the case of the brutal murder of Saudi Arabian journalist and U.S. resident Jamal Khashoggi (himself backed the opinion that the Muslim Brotherhood is a movement for democracy in the region).89

The transnational authoritarianism of the UAE is somewhat different from other states in the region in that the Emirati regime targets threatening ideas rather than individuals or diaspora communities, notably the Islamically informed democratic activism promulgated by the Muslim Brotherhood and other Islamic organizations. Transnationally, through an army of PR firms, lobbyists, and supportive think tanks, the UAE aspires to become a “soft superpower” by changing the very nature of the conversations in North America and Europe around the subject of Islamically informed social and democratic activism in order to promote support for wider clampdowns on Muslim speech, association, and religiosity that it considers a threat.

In trying to justify repression and appease Western audiences, some of these regimes and their supporters have forged an informal alliance with conservative and right-wing groups and figures in the West dedicated to advancing anti-Islamic bigotry. Arab regimes spend millions of dollars on think tanks, academic institutions, and lobbying firms in part to shape the thinking in Western capitals about domestic political activists opposed to their rule, many of whom happen to be religious.90

Prior to 2012 and 2013, the Brotherhood was of little concern to the West, particularly the United Kingdom and the United States. The Brotherhood was rarely covered in mass media and political circles prior to the rise of the Arab Spring in Egypt and the era of President Morsi. Once global attention turned to the Brotherhood, the UAE particularly has worked to create a false narrative of suspicion, mistrust and links to terrorism in an effort to support and legitimize the current Egyptian regime and the agenda of Gulf States.91 This Islamophobic narrative has been adopted by the CRA in its findings on the Muslim Brotherhood.

Misrepresentation of Zachary Laub at the Council on Foreign Relations

In the CRA’s attempt to demonstrate that the Muslim Brotherhood has connections to violent extremism and terrorism, it relies upon a report published by Zachary Laub at the Council on Foreign Relations. The AFL states on page 16 Concerns about the Muslim Brotherhood and its connections to violence have existed since the 1940’s and 1950’s when its members were connected to political violence in Egypt. While the group renounced violence in the 1970’s at the behest of Egyptian President Anwar el-Sadat, it has not always maintained this approach.” Laub’s report published in the Council on Foreign Relations called “Egypt’s Muslim Brotherhood” in fact paints a different conclusion.

Nader Hashemi, who published a report called “Political Islam: A 40 Year Retrospective,” quoted Laub’s report to state that “In contrast to the regime that rules over them, the Egyptian Muslim Brotherhood has officially rejected violence as a means of obtaining political power. Even their strongest critics grudgingly acknowledge this fact.” 92 Furthermore, he explains that there is a new narrative that has emerged. Notwithstanding the Muslim Brotherhood’s rejection of violence and its commitment to electoral politics, this narrative argues that the Muslim Brotherhood still poses an ominous threat and should be ostracized. Specifically, it is claimed that the Muslim Brotherhood acts as a “gateway drug” or “conveyor belt” toward radical fundamentalism. This narrative is adopted in a 2015 Egyptian government commissioned report by the British law firm 9 Bedford Row on the Muslim Brotherhood.

In Laub’s publication in May 2019 called “Blacklisting the Muslim Brotherhood: What to Know” he states “In Egypt, the original Muslim Brotherhood group continues to renounce violence, even in the face of repression.” This confirms that Laub’s research and point of view do not support the conclusion that the CRA has stated in reference to his work.

AFL Position Is Inconsistent with the Government of Canada and its Allies

The Charity has responded clearly about its position and understanding of the Muslim Brotherhood. However, the AFL position on its background of the Muslim Brotherhood is not in line with the Government of Canada’s position.

The AFL on page 17 points out a number of states who have listed the Muslim Brotherhood as a terrorist entity. However, the CRA has ignored Canada’s position and that of its security allies. Despite being specifically asked to designate the Muslim Brotherhood a terrorist organization, Canada has not done so. Parliament’s perspective is again seen in February 2015, when the Minister of Public Safety and Emergency Preparedness, Steven Blaney, was asked to consider designating the Muslim Brotherhood a terrorist organization. The Minister declined. (See attached Schedule “19”) Despite undergoing Parliamentary review and updating Canada’s list of designated terrorist organizations in February 2021, the Muslim Brotherhood was again not designated.93 Clearly Parliament’s judgement is to be trusted.

Parliament has demonstrated a clear and consistent approach to these organizations: they are not terrorist groups.

Similarly, the United Nations, European Union, United Kingdom, United States, Australia, and Germany have all agreed, and not designated Egypt’s Muslim Brotherhood a terrorist organization.94 Some countries, like the United States, United Kingdom, and Germany have specifically engaged in a formal process of considering the conduct of the Brotherhood. Experts were called upon. Documents were considered. The conclusions reached was that the Muslim Brotherhood is not a terrorist organization.95

However, Egypt’s allies and those that feared the public support of the Muslim Brotherhood in their countries jumped on board and made concerted efforts to sway international public opinion.96 For example, Saudi Arabia declared the Brotherhood a terrorist organization in March 2014. The New York Times reports: “The decree was the Saudi monarchy’s latest gesture of support for attempts by the new military-backed government in Egypt to crush the Brotherhood.”97 Saudi Arabia tried to pressure Algeria into following suit, but Algeria refused.98

Furthermore, the AFL references Austria’s decision in 2019 to ban the logo of the Muslim Brotherhood. However, in August 2021 Austria’s court explicitly ruled that the Muslim Brotherhood is not to be regarded as a terrorist organisation in the country.99

In the Washington Post, Marc Lynch, a professor of Political Science and International Affairs at George Washington University and the director of both the Institute for Middle East Studies and the Middle East Studies Program, declares that “there is near universal consensus in the analytical, academic and intelligence communities that the Brotherhood is not a terrorist organization. This is notable given the widespread and fierce disagreement among those experts about other questions, such as whether the Brotherhood is committed to democracy or can serve as a firewall against violent extremism.”100

Significant number of reports have demonstrated that the Muslim Brotherhood has consistently shown respect for democracy and commitment to peaceful participation. There is consensus in academia that the Muslim Brotherhood has represented moderation.101 The defining characteristic of the Muslim Brotherhood is precisely its moderation, its decision to peacefully respect democracy.102

The Charity has been consistent in Description of Muslim Brotherhood

The Charity clearly defines in all of its organizational documents and in its educational material how the organization understands Islam. While the language may have been updated from time to time, the Charity has always stated that it adopts “an understanding of Islam, based on the Quran and Sunnah, as a holistic way of life, articulated in the work of Imam Hassan al-Banna. His articulation of these values is the most comprehensive and most balanced in modern times.”

This was stated in the preamble of the Charity’s governing documents: “An important manifestation of this revival culminated in the writings of the late Imam Hassan al-Banna. Al-Banna’s core messages of balance and moderation, constructive engagement in society, focus on personal and communal empowerment, and organizational development had a deep impact on much of the Muslim world.”

In the Charity’s statement of identity, also found in the governing documents, the Charity more clearly explains the works of Hasan Al-Banna: “We share a framework of understanding of Islam that emphasizes holism, faith-inspired action, justice, and service. This framework is articulated in 20 guiding principles included in The Message of the Teachings by Hasan al-Banna and is meant to enshrine diversity and enable consensus building and team-based activism.”

Some of Al-Banna’s writings are specific to the cultural, social and political context of Egyptian society in the early 20th century, or reflect his own religious views on some issues. Reference is only made to that which is relevant to the Canadian context. The Charity’s interpretation of Imam Al-Banna’s approach to understanding Islam and building a grassroots movement for the benefit of society, takes it beyond his specific context. Much of this is not only applicable to the Charity, but is the mainstream understanding of Islam held by Muslims worldwide.

Since Al-Banna’s ideology was articulated, and first manifested in the Egyptian Muslim Brotherhood, the ideology and understanding of Islam has spread across the world. It is important to note that there are millions of Muslims who adopt this understanding of Islam all over the world, among whom are thousands of renowned figures such as politicians, thought leaders, academics and religious scholars.

Furthermore, many organizations worldwide including religious national and local groups, political parties (some are ruling parties), non-government organizations, and schools, adopt this understanding of Islam. This is not a narrow interpretation of Islam limited to a specific, organized group of people. As MAC understands and teaches it, it is an emphasis on putting faith in action in every aspect of life, which is why it has resonated with Muslims throughout the World as reflecting their own connection with their faith.

By the 1970s – 1980s, there was mass immigration from the Middle East to Europe, the United States, and Canada. Many of these people had experienced Al-Banna’s ideology in one way or another before immigrating from their home country. When they realized that they would not be returning to their countries of origin, at least in the near future, they began to work towards establishing permanent organizations reflecting this understanding that faith must be put in action. Most of these organizations sought to teach this understanding and instill this commitment in a manner prioritizing the needs of new generations of Muslims born and raised in the West.

As such, like many organizations in Europe and the United States, the Charity shares the ideology of Al-Banna but does not maintain or have organizational connections with the Muslim Brotherhood organization. The Charity has remained independent and without influence from the Muslim Brotherhood organization or any other organization.

However, the adoption of this particular understanding of Islam creates an environment for intellectual and academic discourse and debate across borders, such as seminars and conferences where topics and causes related to religion, family, education, global relief, human rights and justice are discussed.

The Charity has always been clear in both external and internal material about its adoption of Imam Al-Banna’s ideology as a modern interpretation of Islam and its teachings. The Charity has furthermore consistently said that it has no organizational ties with the Muslim Brotherhood organization or any other organization. The Charity is a completely independent Canadian organization that does not receive any directives and has no oversight from any other organization. The Charity is only accountable to its members as per its governing document and Canada’s charitable regulations.

The Charity has been, and continues to be, completely consistent and transparent about promoting and advancing Islam as explained above. Every claim by CRA in this section, can be directly tied to promoting the above object of advancing this specific understanding of religion. Any attempt to make a non-existing connection should be considered an attempt to construct a pre-determined conclusion that suggests an unfortunate Islamophobic interpretation.

Political Participation of Individuals

The Charity is not aware of any organization in Canada that has any organizational ties with the Muslim Brotherhood elsewhere. However, there are many Muslims who worked within grassroots movements inspired by the ideas of Al-Banna and the brotherhood in their countries before immigrating to Canada. In fact, some of them came as immigrants or as refugees to escape the repression to which Arab regimes subject individuals affiliated with such groups. There are many more Muslims, individuals and organizations that are inspired by the ideas of Al-Banna.

The Charity’s understanding of Islam represents the mainstream understanding of Islam that is adopted by the vast majority of Muslims. It is distinct because it adds a strong emphasis on pushing outwards: activism for social justice and societal reform.

The Charity has hundreds of members across the country who subscribe to this understanding of Islam. It is only natural that some of them may serve with the Charity in its capacity for religious, educational, and social purposes, but also serve in other organizations who have a focus on relief, social justice, human rights and democracy.

Furthermore, the Muslim community, like any community has been growing to establish the wide range of services and organizations any mature community depends on. It is natural that the Charity’s members who have leadership and organizational skills choose to participate in leading other organizations.

The Charity does not restrict any of its members from participating in external activities or organizations. This is their freedom of expression and association as Canadians and what they do or say in other capacities outside of the Charity is not representative of the Charity.

In this regard, the popular uprisings of the Arab Spring, including the 2011 revolution in Egypt that ended the three-decade-long presidency of Hosni Mubarak, were welcomed by the Canadian government and most countries around the world. Many Canadians of Tunisian, Egyptian, Syrian and other origins chose to participate in democratic transitions in their home countries. Canadian citizens joined different political parties abroad; communities held policy debates and discussions, participated in the media discourse, and voted in elections; and some Canadians travelled to their countries of origin to take part. Canadians publicly participated in the political process in their home countries without concern.

This is no different than the Coptic Egyptian community that played a very public and active role in Egyptian politics or the Ukrainian community that played an active role in Ukrainian politics abroad, or the Jewish community that is actively invested in Israel’s state of affairs.

As the Arab Spring progressed, and the situation evolved, Canadian Egyptians continued to participate. The Charity took the position that members are free to participate as they choose whether in activities in Canada or abroad, and maintain their membership as long as it was legal and within their rights. In December 2012, the Charity’s board of directors adopted a recommendation that anyone in leadership (board of directors or executive council) who takes on a leadership role in a political party abroad should resign from their leadership position. They were not required to resign from membership in the organization.

The AFL has made a number of unfounded allegations in relation to key individuals, specifically [REDACTED] and [REDACTED] as mentioned above.

[REDACTED] was engaged in support for a nascent democratic process by bridge building between Egypt and western anglophone countries. That the CRA would take issue with this is exactly the kind of Islamophobic positioning for which [REDACTED] sought to minimize public attention to his role. [REDACTED] is recognized provincially and in his home city of London Ontario for his professionalism and dedication.

The AFL on page 22 asserts that “No person appears to have had more of an influence on the direction of the Organization than [REDACTED].” Prior to responding to this statement by the CRA, it is important to note that the CRA does not provide any explanation of what its concern is with “MAC’s direction.” MAC has always remained compliant with its charitable purpose and delivered its own charitable activities to its beneficiaries, and always sought to comply with the necessary direction and control required by the ITA. As the CRA is aware, the executive director of any charity manages all of the day-to-day operations of the organization. [REDACTED] acted as the president and CEO from 2002 to 2010, and has acted as Executive Director since 2011. He has contributed and sacrificed for the organization’s growth. He has substantially advanced the organization nationally and expanded its programming, policies, and infrastructure.

He and his executive team work with leadership across the country to develop the organization’s strategic plan that informs the various programs to fulfill the organization’s charitable purpose. He and his team oversee regular reporting on programming, goals and targets across the organization. Like any charity, this is the role of a CEO or ED. Even though [REDACTED] maintains a high degree of institutional knowledge of the organization’s operations, it is inaccurate for the CRA to state that he has the most influence over the direction of the organization.

This ignores and undermines the governance model of the organization. The Annual General Meeting (AGM) elects the Board who then puts forward priorities and objectives. This is prepared with the support of the Executive Director but is ultimately owned by and approved by the Board. The AGM each year approves the annual reports and the financial reports. The AGM is actively involved in discussing and approving proposals on direction of the organization. While the Executive Director is the ultimate decision maker on operational matters, there is not one example that the CRA has been able to present in which a major decision was made without the approval of the Board. The CRA has been provided with all minutes of the AGM, the Board and the Executive Council.

In addition, in footnote 87, the AFL claims that “prominent members of the Organization who have gone to work with Morsi include [REDACTED] (Morsi Policy Advisor) and [REDACTED].” This claim is incorrect. [REDACTED] was not an active member of the Charity and he had left Canada to return to Egypt in 2005. [REDACTED] became active with the Charity a couple of years after his return to Canada in 2019. [REDACTED] left Canada in 2010. [REDACTED] was not a policy advisor to President Morsi, rather he was involved with the Freedom and Justice party. Both were no longer members once they left the country for several years before the revolution in 2011. This is a particularly egregious example of the bias that frames the entire methodology of the AFL. Not only is the CRA suggesting that members of MAC be proscribed from legitimate political participation, in citing these particular examples, it appears to be suggesting that MAC bears responsibility for the lifetime activities of any former member, even ones who no longer live in Canada.

This claim and its respective footnote 87 refer to an email chain among a number of people communicating with their personal emails including [REDACTED] and [REDACTED]. The scope of the audit and email requests did not include personal emails for any of the individuals on this email chain. Furthermore, the choices of individuals to support legal and legitimate activities in their personal capacities is outside the scope of this audit. The Charity rejects the CRA’s notion that the personal activities of leaders in the organization is evidence that the “organization is advancing the Muslim Brotherhood organization” and that “support for the Muslim Brotherhood is manifested in the organization’s activities.”

 

Allegations Concerning Membership Transfers or Shared Membership

CRA alleges at page 27 that, “a review of the Organization’s records appears to indicate that membership in the Organization is not only transferrable to organizations outside of Canada, but that members of other organizations, in other countries, appear to be granted membership in the Organization on the basis of their membership in the foreign organization.”

The AFL concludes on page 28 that, “It is not entirely clear how the Organization, which purports to be entirely Canadian based with no foreign activities, is able to transfer memberships to and from foreign organizations. Considering the Organization’s leadership’s interaction with Muslim Brotherhood leaders, it would appear reasonable to conclude that the transfer of memberships is possible due to the Organization’s close association with these seemingly foreign Muslim Brotherhood organizations.”

Not only is this claim not reasonable, it is simply contrary to the facts and unsupported by the material cited in the AFL. Individuals that come to Canada, become a permanent resident or citizen, have the right and freedom to join the Charity if they are eligible. Without exception, each individual must complete the Charity’s multi-year educational program for new members and if done successfully they are welcome to join the Charity as a member.

There are many organizations globally that adopt similar understandings of Islam, and some adopt the ideology of Imam Hassan Al-Banna. The Charity has no connection with any of these organizations. Some of these organizations abroad may have practises of giving weight to “reference letters,” However, such a letter has a particular consideration in the Charity’s membership process in accordance with its governing documents. The AFL cites in one example that the individual “appeared to have fast-tracked membership” at page 27. However, no evidence to support this speculation is found in the AFL, as each example cited clearly states that each of these individuals who immigrated to Canada completed the Charity’s educational program before becoming eligible for membership.

The Charity provided CRA with its “Newcomers, Relocations in Canada Regulations” (the “Regulations”). This has been completely dismissed by CRA, as the accusations in the AFL make no consideration of this document. It has been provided once again in Schedule “20” to this AFL response.

The Regulations provides as follows:

The Board of Directors or the Executive Council shall have the discretion to waive the time requirements for all classes of membership and all positions of authority set out in these bylaws. In considering whether to exercise this discretion, the Board of Directors shall assess the following factors:

  • The applicant’s Islamic character;
  • The applicant’s special capabilities;
  • The applicant’s record of committed participation with other Islamic organizations pursuing objectives and goals similar to those held by the Association.

The Association may waive these conditions based on interviewing, evaluation orientation of these applicants and satisfying itself with their qualities and knowledge. It may ask them for references in Canada or overseas. The Executive Council will find the means to accommodate newcomers as well as returnees.

Despite a consistent application of the Charity’s membership process, the board has the authority to waive time requirements based on the above requirements. Criteria 1c is sometimes provided by a newcomer to demonstrate a person’s commitment to participation with other Islamic organizations.

In the case of the Charity providing a “reference” letter, the letter simply states that an individual who was a member of the Charity was in good standing.

As it relates to the Muslim American Society (“MAS”), a US-based organization, there are historical ties with the Charity. In this regard, some individuals were members of MAS before the Charity was established, at which point they resigned and joined the Charity. Both organizations have similar objectives and understanding of Islam.

In the early years of the Charity’s establishment, both the Charity and MAS cooperated on community and youth programming in the space of training and development. With respect to membership, since this organization and its leadership is known to the Charity and is the largest grassroots Islamic organization in the US, the organization may be contacted to inform them that a member of the Charity is moving to the US. MAS has a strong support network within its Muslim community. The Charity offers this gesture to its membership, not to “transfer” membership as the CRA has alleged, but to request that the community support the individual and his/her family during their move and as they settle into their new home.

The Charity has hundreds of members, many of whom are transitional families who immigrated to Canada and others who are second and third generation. Over the lengthy period of the audit, the CRA found 8 examples of requests, 5 are individuals who came to Canada and 3 are individuals leaving Canada. This clearly demonstrates that this is not a standard practise with movement of members. In addition, all 8 cases conform to the facts as we have set them out in the foregoing paragraphs.

Finally, when the AFL alleges at page 28 that, “Considering the Organization’s leadership’s interaction with Muslim Brotherhood leaders, it would appear reasonable to conclude that the transfer of memberships is possible due to the Organization’s close association with these seemingly foreign Muslim Brotherhood organizations,” this remark is completely unfounded. There is no evidence found in the AFL that demonstrates that the Charity’s leadership has “interaction” with Muslim Brotherhood leaders, other than the receipt of mass emails for which there is no reply to be found from the Charity as referenced above.

Allegations Concerning Support for pro-Egyptian Muslim Brotherhood Organizations

As noted earlier, the AFL at page 28 alleges that MAC supports groups that are “openly pro-Egyptian Muslim Brotherhood or support the former Egyptian President Morsi of the Egyptian Muslim Brotherhood’s Freedom and Justice Party” and points to Egyptian Canadian Coalition for Democracy (ECCD) and Egyptian Canadian Home Organization (ECHO) as being two such groups.

After the military coup in Egypt in 2013, Egyptian Canadians rightfully spoke out for the respect of democracy and human rights. Shortly after, in August 2013, the Egyptian regime killed thousands of protestors peacefully calling for a return to democracy. These events triggered a global response particularly from human rights organizations. With thousands of innocent people killed, detention and torture of thousands more, many Egyptians were escaping the country from persecution. Within the Egyptian diaspora, including Canada, many organizations were established to advocate for democracy and the respect of human rights in Egypt.

The AFL on page 14 claims “The Organization appears to be supporting mainly two groups: the Ottawa-based Egyptian Canadian Coalition for Democracy (ECCD), the Montreal-based Egyptian Canadian Home Organization (ECHO).” and on page 48 that “These two groups appear to operate in support and advancement of the Egyptian Muslim Brotherhood in Egypt.” With regards to the Egyptian Canadian Coalition for Democracy, the organization is clear on its mandate (vision, mission, and core principles). It states that its mission is “to create and mobilize an advocacy network that is committed to the universal values of freedom, justice, democracy, peace, prosperity, and rule of law, enshrined in Canada in the Charter, and brought to life by the Egyptian revolution. This network will work to raise awareness and mobilize broad-based support in Canada for Egyptians struggling to attain these values in their country. This network will become a model for others and will cooperate in this cause with like-minded individuals and groups around the world.”

The ECCD further states on its website and its press releases that “The Egyptian Canadian Coalition for Democracy (ECCD) is a politically independent, non- affiliated pan Canadian organization that advocates for democracy and human rights in Egypt.”

With regards to the Egyptian Canadian Home Organization (ECHO), the organization states on its website that it “is a Canadian non-profit organization that aims to enrich the cooperation between Egypt and Canada in the fields of scientific and academic research and commercial activity and investment in addition to the consolidation of social relations between the Egyptians in Canada.” The AFL on page 29 takes concern with ECHO’s “supports former Egyptian President Mr. Morsi and opposes the military coup, and has made public statements opposing the Canadian Conservative government.”

The CRA has approached its interpretations of the activities of both these groups from a biased political lens, which is improper for the CRA. The CRA has chosen to view these groups as supporting a particular party or politician, rather than supporting democracy and human rights in Egypt, in order to demonstrate that such activities appear to be “activities that a registered charity are prohibited from undertaking; namely, direct or indirect support of, or opposition to, any political party or candidate for public office.” (page 30)

To the best of the Charity’s knowledge, these groups called for condemning a military coup, respecting democratic institutions, and reinstating a President who was elected by the people of Egypt.

The Egyptian government has attempted to create a narrative that links the Muslim Brotherhood to violent Islamism, legitimize the post-coup labelling of the Muslim Brotherhood as a terrorist organization, and therefore justify the Egyptian government’s violent crackdown on dissent and human rights abuses, and the worst massacre in Egyptian history in which over 1000 protestors were killed by the military regime.103 The ultimate goal is to legitimize President el-Sisi’s coup d’état against Mohammad Morsi, the first democratically elected president of Egypt, and dehumanize the thousands of Egyptians in Egypt and around the world who continue to protest against the coup.104 The CRA has drawn its conclusions about these groups based on this narrative, rather than acknowledge the military coup in Egypt as well as the egregious human rights violations that have occurred in that country.

The CRA’s bias projects an Islamophobic narrative, that organizations opposing the military coup in Egypt and pro-democracy are organizations connected to or supporting of the Muslim Brotherhood.

MAC has no connection to the ECCD. The CRA has identified 6 members of MAC who also volunteer with the ECCD. As stated earlier, MAC does not restrict any of its members from participating in external activities or organizations. This is their freedom of expression and association as Canadians and what they do or say in other capacities outside of MAC is not representative of MAC.

The AFL on page 28 alleges that, “The unpaid use of the Organization’s premises and the extent of cross membership appears to indicate that the Organization is not only aware of the activities of these groups, but is also supportive of their overriding purpose.”

As noted above, unlike many places of worship that congregations attend once a week, mosques have a call to prayer five times a day and additional prayers on specific other days of the week and special occasions. Furthermore, the Charity does not operate strictly mosques, but its facilities are operated as community centers in accordance with its charitable purposes.

With this in mind, the CRA should consider the participation of community members in the Charity’s facilities and the diversity of attendance as well. Usage of the facilities vary and could include at different times:

Often, congregation members who are associated with external organizations may meet in a facility owned by the Charity. This is normal as these congregation members are donors and active participants of the centre. When a meeting room is booked on arrival the individuals are responsible to maintain the room, clean it, and leave it on time and therefore require minimal resources from the organization.

The CRA states at page 31

“As detailed above, there were no records of payment for use of the property in the general ledger and there appears to be a significant overlap in membership between the Organization and the ECCD and ECHO. This would appear to indicate that the Organization is permissive of the activities and events occurring at its properties and is supportive of the ECCD and ECHO’s purpose in general.”

Allowing community groups, such as ECCD and ECHO whose members are regular congregation attendees of MAC’s centre to use the facility without payment is not indicative of the Charity being “supportive of the ECCD and ECHO’s purpose in general.”

In general, the Charity does not usually charge congregation members who request the usage of a meeting room. The specific events listed by the CRA are responded to in detail below, but the examples the CRA has highlighted include special prayers in the mosque, social gatherings, or community discussions, all of which are reasonable uses of the Charity’s centres not related to the support of any political party or group. In the case of a large gathering the AFL has shown that a rental application was submitted.

The following are some comments regarding each example: 

November 2013 – ICCO – Campaign for [REDACTED]

January 25, 2014 – Rahma Mosque – “Edmonton Car Rally” hosted by the ECCD

March 1, 2014 – Abraar School – “Shaheed Night” hosted by ECCD

August 15, 2014 – ICCO – “First BBQ Event” by the ECCD

December 25, 2014 – Abraar School – The ECCD Iftar

August 13, 2016 – Centre Communautaire Laurentien – ECCD / February 19, 2017

                                 – Centre Communautaire Laurentien (CCL) – ECCD/ECHO

CRA also alleges the use of the Charity’s facilities as being partisan support of a political party, but does not provide any specific examples as to how the Charity directly or indirectly did so, and instead refers the Charity to CRA’s draft guidance on public policy dialogue and development activities which reflects statutory changes to the ITA that occurred well after the Audit Period. In this regard, CRA is retroactively applying provisions of the ITA which did not exist at the time of the audit.

Discriminatory Approach in Relation to Other Faith Groups

The Charity reaffirms that it does not have any links with organizations outside of Canada.

Overall, the AFL treats the Charity in a discriminatory manner by suggesting that a faith-based organization in Canada having any linkage with an organization overseas is to be a suspect. In this regard, there are many Canadian faith-based charities that have explicit connections that may result in influence on the charity.

The Charity is further concerned that the CRA is prejudiced to the Charity in a manner that it does not apply to other charities. The examples below demonstrate that in the charitable sector it is common that charities maintain connection to any organization abroad, and some examples where it can be argued may result in undue influence on the charity.

The Evangelical Fellowship of Canada (EFC)106

The EFC has hundreds of affiliate CRA registered charities that subscribe to its objects and statement of faith. However, the EFC is a member of The World Evangelical Alliance (WEA). Its staff and former staff serve in the WEA leadership. Some senior examples include:

The EFC is affiliated with The Peace & Reconciliation Network of the World Evangelical Alliance. The EFC is part of the EFC Global Mission Roundtable that seeks to maximize the effectiveness of the Canadian evangelical community in global mission.

The United Church of Canada

The United Church works with over 100 partners in God’s mission around the world. Global partnerships are formal relationships with national churches, ecumenical organizations, Christian councils, church agencies, and civil society organizations around the world.107 The United Church of Canada states “The United Church of Canada and its predecessors have been engaged in global partnerships for more than 150 years. Over that time a lot has changed, including the church’s understanding of itself and its mission in the world. In 2008, the Executive of the United Church’s General Council approved a “Statement and Affirmations on Global Partnership,” including 10 guiding principles.”108 Therefore, it is clear that its global partnerships have influence over the Canadian charity and its members.

Friends of Simon Wiesenthal Center for Holocaust Studies

The Friends of Simon Wiesenthal Center for Holocaust Studies state “In all this, we celebrate and advocate for the existence, safety and security of the State of Israel – the homeland of the Jewish people. We attend national and international meetings to reinforce our friendship and advocate our affection for the Jewish state.” They also state “We defend Israel against antisemitic motivated campaigns that aim to delegitimize,boycott, and defame the nation and place its security in jeopardy.” The charity is clearly spending charitable resources on attending international conferences that could result in influence over its leadership.109 Charitable resources are spent on defending a foriegn state or possibly given to the State of Israel.

According to the Canadian Foreign Policy Institute, a mid-1990s survey found there were more than 300 registered Canadian charities with ties to Israel and in 1991 the Ottawa Citizen estimated Canadian Jews sent more than $100 million a year to Israel and possibly as much as $200 million110

Jewish Federations of Canada 111

The Jewish Agency for Israel (JAFI) is a primary agent for JFC-UIA in carrying out its mandate. Keren Hayeso, a UIA representative, works to further the national priorities of the State of Israel and Israeli society.

There are many examples of Canadian charities that have explicit links or partnerships to international organizations or movements. There are many examples of individuals who serve as leadership for Canadian charities also serving on international entities that have clear influence over the Canadian charity. In the case of MAC, the organization has neither. Yet, CRA has singled out the Charity accusing it of advancing non-charitable purpose due to unsubstantiated allegations of ties to the Muslim Brotherhood, despite its transparency since the day of its charitable registration, updates in amending its governing documents, and during the audit.

56  https://www.fatf-gafi.org/media/fatf/documents/reports/mer4/MER-Canada-2016.pdf

57  https://www.fatf-gafi.org/media/fatf/documents/reports/fur/Follow-Up-Report-Canada-2021.pdf

58 https://bridge.georgetown.edu/research/factsheet-lorenzo-vidino/

59  https://bridge.georgetown.edu/research/factsheet-common-anti-muslim-tropes-2/

60 https://islamophobianetwork.com/organization/investigative-project-on-terrorism/

61 https://www.nytimes.com/2021/04/23/world/europe/uk-far-right-tommy-robinson-russia.html

62 European Islamophobia Report 2017 https://www.islamophobiaeurope.com/wp-content/uploads/2018/04/Austria.pdf

63 European Islamophobia Report 2018 http://www.islamophobiaeurope.com/wp-content/uploads/2019/09/AUSTRIA.pdf

64 https://www.middleeastmonitor.com/20171109-exclusive-uae-works-to-defeat-voices-of-islamism-in-the-west-reveal- leaked-emails/

65 https://www.gwhatchet.com/2019/10/16/former-program-on-extremism-employee-criticizes-director-for-attempted- censorship/

67  https://www.macleans.ca/news/world/the-muslim-brotherhood-the-new-islamist-bogeyman-in-canada/

68 https://web.archive.org/web/20161105214447/http://tsecnetwork.blogspot.com (the site has been removed)

69 https://twitter.com/i/web/status/1138326975385354240 70https://pressprogress.ca/manning_centre_hosts_bonkers_panel_claiming_quebec_city_mosque_was_actually_helping_terrori sts/

71 https://bridge.georgetown.edu/research/factsheet-quilliam/

72 http://www.ncsociology.org/sociationtoday/v131/tea.html

73  https://www.theguardian.com/uk/2010/aug/04/quilliam-foundation-list-alleged-extremism

74  https://www.nytimes.com/2021/04/23/world/europe/uk-far-right-tommy-robinson-russia.html

75 https://islamophobianetwork.com/organization/clarion-project/

76 https://cdn.americanprogress.org/wp-content/uploads/issues/2011/08/pdf/islamophobia_chapter4.pdf

77  https://islamophobia.org/islamophobic-organizations/middle-east-media-research-institute/

78  https://thelinknewspaper.ca/article/tva-nouvelles-complicit-in-islamophobia-and-rise-of-far-right-protesters-sa

79  https://montrealgazette.com/news/local-news/debunked-mosque-story-rally-targets-tva-nouvelles-islamophobia

80  https://www.theguardian.com/world/2015/nov/06/uae-told-uk-crack-down-on-muslim-brotherhood-or-lose-arms-deal

81  https://www.middleeasteye.net/fr/news/muslim-brotherhood-review-tale-uk-uae-relations-378120043

82  https://www.theguardian.com/world/2015/nov/06/uae-told-uk-crack-down-on-muslim-brotherhood-or-lose-arms-deals

83 Written evidence from Alison Pargeter, Researcher and Middle East Analyst, to UK Parliament (May 2016), online:

<http://data.parliament.uk/writtenevidence/committeeevidence.svc/evidencedocument/foreign-affairs-committee/political- islam/written/32762.html>

84 See also United Kingdom, Parliament, The Foreign Affairs Committee, “’Political Islam’ and the Muslim Brotherhood Review” in Committee Publications (3 November 2016), online:

<https://publications.parliament.uk/pa/cm201617/cmselect/cmfaff/118/11810.htm#footnote-037>.

85  https://www.middleeasteye.net/opinion/between-two-reviews-reading-uk-parliamentary-report-political-islam

86 https://www.aljazeera.com/news/2014/11/16/uae-lists-scores-of-groups-as-terrorists

87 https://www.hrw.org/news/2014/12/04/uae-terrorism-law-threatens-lives-liberty

88 https://religionandpolitics.org/2021/04/06/when-promoting-religious-freedom-abroad-threatens-minority-communities-back- home/ 

89 https://religionandpolitics.org/2021/04/06/when-promoting-religious-freedom-abroad-threatens-minority-communities-back- home/

90  https://foreignpolicy.com/2019/03/29/arab-regimes-are-the-worlds-most-powerful-islamophobes/

91 TMC Advisory Group, Muslim Brotherhood and the Myth of Violence and Terrorism (2015)

92 Nader Hashemi, Political Islam: A 40 Year Retrospective, https://www.mdpi.com/2077-1444/12/2/130/html

93 https://www.ctvnews.ca/politics/canada-adds-proud-boys-to-terror-list-bringing-range-of-legal-financial-implications-

1.5293967

94  https://www.middleeastmonitor.com/20190221-germany-muslim-brotherhood-peaceful-movement/

95 https://carnegieendowment.org/2019/05/03/nine-reasons-why-declaring-muslim-brotherhood-terrorist-organization-would- be-mistake-pub-79059

https://www.hrw.org/news/2013/12/28/egypt-terrorist-tag-politically-driven

96 https://myemail.constantcontact.com/CSID-Bulletin—Why-the-Muslim-Brotherhood-is-NOT-a-terrorist-organization—by- John-L–Esposito.html?soid=1102084408196&aid=SNDS2q96CIk

97  https://www.nytimes.com/2014/03/08/world/middleeast/saudis-put-terrorist-label-on-muslim-brotherhood.html

98  https://www.echoroukonline.com/algeria-refuses-to-consider-muslim-brotherhood-as-terrorist-organization

99  https://www.middleeastmonitor.com/20210806-austria-court-rules-muslim-brotherhood-not-a-terrorist-group/

100 https://www.washingtonpost.com/politics/2019/05/01/designating-muslim-brotherhood-terrorist-organization-has-failed- before-why-is-it-returning-now/

101 TMC Advisory Group, Muslim Brotherhood and the Myth of Violence and Terrorism (2015), 37

102 TMC Advisory Group, Muslim Brotherhood and the Myth of Violence and Terrorism (2015), 39 

103  https://www.hrw.org/report/2014/08/12/all-according-plan/raba-massacre-and-mass-killings-protesters-egypt

104 https://blog.oup.com/2014/08/terror-metanarrative-rabaa-massacre/ 

105https://www.cbc.ca/news/canada/toronto/a-dream-come-true-khaled-al-qazzaz-stuck-in-egypt-since-2013-arrest-finally- home-1.3744932 

106 https://www.evangelicalfellowship.ca/About-us/Global-Initiatives

107  https://united-church.ca/community-and-faith/welcome-united-church-canada/partners-mission/global-partners

Summary of AFL Finding:

 

The AFL at page 11 begins with the law as expressed in Vancouver Society of Immigrant and Visible Minority Women v. Minister of National Revenue in relation to a review of a charity’s purpose and whether those purposes are charitable at law, whether there is a clear relationship and link between the activities and the purposes, and whether the activities themselves do not fall outside the bounds of what has been judicially recognized as charitable. In this regard, at page 11 the AFL states that, “Where an activity is, or becomes, a substantial focus of an organization, it may no longer advance a stated purpose. Rather, the activity may be in support of a separate or collateral unstated purpose—or form a separate or collateral purpose in and of itself.” However, with respect to the Muslim Brotherhood, the AFL then produces neither any qualitative or quantitative analysis with respect to how under the ITA the Charity “advanced” the Muslim Brotherhood, but instead produces a series of emails and correspondence rather than any material qualitative or quantitative use of resources that would advance such purpose.

The AFL at page 13 lists the charitable purposes of the Charity as set out in its governing document, and then concludes that during the Audit Period the Charity operated beyond these purposes in two aspects, i.e., advancement of the Muslim Brotherhood organization and the purchase of real estate as an end in and of itself.

The AFL states at page 14 that, “…based on the information available to CRA, it appears as though many of the Organization’s activities appear to be in furtherance of the Muslim Brotherhood organization, and the extent to which they occur, would constitute the advancement of a non-charitable, collateral, purpose.” As well, at page 18, the AFL states that, “preliminary audit findings appear to suggest that the Organization has connections to individuals or groups associated with extremism, violence, and/or terrorism.” Further, on page 20 the AFL concludes that, “In the Organization’s case, for example, advancing the Muslim Brotherhood ideology is more than advancing religion, it also appears to mean advancing the Muslim Brotherhood organization”. Lastly, on the same page the AFL indicates that, “…support for the Muslim Brotherhood by the Organization’s senior leadership appears to be manifesting itself in the activities and decisions made within the Organization”.

We should also note that at page 20 of the AFL, the CRA states that, with respect to any link with Muslim Brotherhood as an ideology as opposed to an organization, “During the registration process, very little was mentioned about what this meant. Common law has established that not everything done in the name of religion is charitable”. This comment suggests that somehow when the Charity obtained charitable status in 1999 it misled or was not transparent to CRA. However, later at page 42 of the AFL when stating that the Charity cannot rely on charitable registration as a means of due diligence when making gifts to other qualified donees, CRA states that, “Simply put, being a registered charity means that at the time of registration, an organization’s purposes were deemed to be charitable and that they produced a public benefit”. In this regard, it is inconsistent and unfair to suggest that the Charity was being non-transparent all the way back to its registration in 1999 while also declaring that the CRA’s role in the registration process is limited to confirmation that an entity’s purposes are charitable.

In concluding on this area, at page 32 of the AFL the CRA alleges that, “The audit found that the Organization appears to conduct and support activities that further the advancement of the Muslim Brotherhood organization,” and that, “…the Organization appears to be advancing the interests of the Muslim Brotherhood Organization and its political party the Freedom and Justice Party.”

Summary of MAC Response:

As indicated in our letter of August 12, 2021, the AFL fails to provide any evidence of even a single transaction between MAC and the Muslim Brotherhood or that it is a division of the Muslim Brotherhood. No evidence is provided to indicate that MAC’s charitable property, including its funds, personal property, real property, volunteers or employees, provided any support to the Muslim Brotherhood. As well, the allegation that support for the Muslim Brotherhood manifested itself in activities or decisions by MAC is completely unsupported by any facts whatsoever. The only things the AFL points to in support of these conjectures are communications received by [REDACTED], a former director and officer of MAC, and [REDACTED], the current executive director of MAC. In this regard, these individuals have been singled out for receiving unsolicited mass emails to their generic email accounts (president@macnet.ca and ed@macnet.ca respectively) based on which the CRA has attempted to cast serious allegations of associations and relationships.
 

In addition, in order to indicate that [REDACTED] or [REDACTED] were associated with the Muslim Brotherhood, and thereby influenced decisions made by MAC, the AFL would need to evidence that either individual has de facto or de jure control of MAC. However, no reference is made in the AFL to any section of the ITA or case law concerning de facto or de jure control. As [REDACTED] is an employee of the corporation and only has an officer position, he has no legal control of MAC. Further, [REDACTED] ceased being a director and officer of MAC on December 12, 2012 as noted in the AFL. As a director, [REDACTED] would have exercised only one vote on the board of directors of MAC, which would not be sufficient to exercise control. While [REDACTED] continued to be a corporate member of MAC thereafter, this would have provided him with only a single vote as a corporate member out of hundreds. The AFL notes at page 22 that [REDACTED] was present at a board meeting following his resignation as a director and officer, however, this is not true. [REDACTED] did not attend board meetings after his resignation. The single meeting referenced in the AFL was a meeting called by the Board of Directors and a cross section of members based on background, gender, age, etc. were selected to participate. Furthermore, the AFL does not provide any evidence to suggest that his mere presence indicated de jure or de facto control over the corporation, or that in his position as a corporate member he made any material decisions, in general or in support of the Muslim Brotherhood.

Furthermore, [REDACTED] was at all times transparent with MAC, the community, the public and the media about his role in Egypt. His story is well documented on the public record. [REDACTED]’s advisory role was with the President of Egypt, and not the Freedom and Justice Party or the Muslim Brotherhood. The Presidency was independent of any political party and included a number of individuals from various political backgrounds, such as the President’s Chief of Staff, Ambassador Rifa’a Tahtawi and others. In fact, President Morsi resigned as chairman of his party upon assuming the Presidency. [REDACTED] is recognized provincially and in his home city of London, Ontario, for his professionalism and dedication. Over the course of the past 15 months, he has been the primary leader of London, Ontario’s “Critical Care Covid-19” pandemic response overseeing mobilization of the city’s critical care resources to meet the overwhelming demand for healthcare. There has never been any suggestion whatsoever that his previous personal political work in Egypt was in any way unlawful or a security concern.

With respect to [REDACTED], again, the AFL does not demonstrate that he had any legal or effective control over MAC. The AFL alleges at page 22 that “…some communications appear to indicate that the leadership of the Muslim Brotherhood appears to exhibit some authority over Mr. [REDACTED]”, but no subsequent connection is made to allege extending that control over MAC. The AFL points to a number of invitations that were sent to Mr. [REDACTED]’s email as unsolicited mass emails that were invitations to various conferences. Invitations for the conferences have long been shared with Muslim organizations and community leaders across the world. These invitations are often sent to president@macnet.ca or ed@macnet.ca and are unsolicited, generally mass email broadcasts. Both these e-mail accounts are publicly available, widely known, and clearly associated with the organization’s leadership and as such anyone in the world can email them.

Having said that, the CRA extracted over 96,000 emails from [REDACTED]’s email account over the Audit Period but chose to highlight 4 unsolicited conference invitations that were sent to [REDACTED] by mass email broadcasts. None of these emails were responded to by [REDACTED]. These are a select few among many conference invitations that Mr. [REDACTED] receives annually.

At page 22 of the AFL, it states that, “on May 17, 2013, [REDACTED] received an email from [REDACTED].” The AFL then attempts to link [REDACTED] to Dr. Mahmoud Ezzat who is a member of the Muslim Brotherhood organization. However, this example ignores that [REDACTED] is a corporate member of MAC. This email was sent to [REDACTED] asking for a nomination for someone to attend the 2013 International Symposium for Muslim Women. This email was not responded to by [REDACTED] and neither were any follow-ups. It is important to note that the Charity had no prior precedent or practise of sending representatives to international conferences.

In addition, at page 26 and 27 of the AFL, the CRA purports to note a similarity between MACs general operating by-laws and those used by a Muslim Brotherhood organization, and also suggests that membership transferability between MAC and organizations outside Canada suggests a linkage to the Muslim Brotherhood. This conclusion is completely unsupported. MAC’s general operating by-laws are a legal document adopted to comply with the provisions of the Canada Not-for-profit Corporations Act under which it is incorporated. No registered charity is required to review corporate documents on a global basis to see if they might possibly appear to be similar to those used by other foreign organizations. Moreover, there are many organizations globally that adopt a similar understanding of Islam, and some adopt the ideology of Imam Hassan Al-Banna. MAC has no connection with any of these organizations. Some of these organizations abroad may have practises of giving weight to “reference letters,” however MAC’s membership process as per MAC’s regulation clearly explains the purpose of a reference letter. As well, MAC has hundreds of members, many who are transitional families who immigrated to Canada and others who are second and third generation. Over the lengthy period of the audit, the CRA found 8 examples of requests, 5 are individuals who came to Canada and 3 are individuals leaving Canada. This clearly demonstrates that this is not a standard practise for movement of members.

As well, the AFL at page 28 alleges that MAC supports groups that are openly pro- Egyptian Muslim Brotherhood or support the former Egyptian President Morsi of the Egyptian Muslim Brotherhood’s Freedom and Justice Party and points to Egyptian Canadian Coalition for Democracy (ECCD) and Egyptian Canadian Home Organization (ECHO) as being two such groups. The AFL alleges at page 30 that several of MACs directors, like officials, or members hold senior positions within the ECCD. However, the listed examples at page 30 only indicate individuals who are corporate members of MAC. Again, no evidence is provided to support that these 6 corporate members have de facto or de jure control over MAC as a result of their 6 corporate votes out of hundreds of members. As well, none of these individuals are directors or like officials of MAC so it is not clear why these references were used in the AFL other than to allege vague and speculative conjectures against MAC.

In addition, at page 31, the AFL alleges that these same individuals are conducting prohibited activities, i.e., directly, or indirectly, supporting or opposing a political party or a candidate for public office. However, this is only a prohibited activity for registered charities. ECCD and ECHO are Canadian registered non-profit organizations, and their activities cannot be said to be activities of MAC based upon an immaterial overlap in corporate membership only. As well, the AFL attributes use of MAC real properties by these members as unpaid use of the space by ECCD and ECHO. However, the space was booked by these members in their capacity as corporate members of MAC. MAC does not restrict any of its members from participating in external activities or organizations. This is their right to freedom of expression and association as Canadians and what they do or say in other capacities outside of MAC is not representative of or relevant to MAC.

The AFL also alleges that religious observances for President Morsi purportedly constituted support for the Muslim Brotherhood. According to Islamic teachings, when a Muslim is denied a proper religious funeral, as was the case with President Morsi, Muslims are permitted and encouraged to pray an absentee prayer, known as “salaat al ghaib”. Mosques across Canada (other registered charities), beyond just those operated by MAC, also held “salaat al ghaib” for President Morsi, an internationally renowned Muslim figure. As it relates to MAC, since this was a religious obligation, MAC had to provide to its mosques’ congregations the spiritual service to perform “salaat al ghaib”. This religious service had nothing to do with the affiliations that President Morsi had, whether it be to the Muslim Brotherhood or the Freedom and Justice Party. MAC unequivocally rejects this conclusion.

Detailed MAC Response:

Problematic Sources Relied Upon by the CRA In Presenting Background on Muslim Brotherhood

 
In arguing that the Muslim Brotherhood is connected to violent extremism and terrorism, the CRA relied heavily on documentation provided by questionable sources. An assessment of these sources’ expertise, funding, mandate or ideological affiliation is required before reliance can be placed upon these sources, given the bias of the sources in question.

To underscore this, we briefly discuss eight examples of reports or individuals cited in the AFL as a primary source to argue that the Muslim Brotherhood is connected to violence.

In the AFL’s documentation of the Muslim Brotherhood and its links to extremism and violence, the CRA has relied solely on Islamophobic sources, without considering hundreds of sources available on the public record that speak to more credible and objective points of view.

 

Lorenzo Vidino

In presenting the background on the Muslim Brotherhood and its alleged connections to violent extremism and terrorism, the CRA has heavily relied upon the testimony of Lorenzo Vidino, an Italian American legal scholar whose research promotes conspiracy theories about the Muslim Brotherhood in Europe and the United States. Vidino is connected to numerous anti-Muslim think tanks in the United States and Europe, and has published in various anti-Muslim outlets.58 While Vidino has published a number of publications about the Muslim Brotherhood, in an interview with NPR in March 2017 Vidino stated, “I’ve been studying the brotherhood for 15 years…I maybe understand 10 percent of how it works.” Most of his publications are with anti-Muslim institutions, with a history of producing anti-Muslim research and promoting voices supporting anti-Muslim legislation. Vidino has a history of advancing unscientific theories and anti-Muslim tropes.59

In 2004 and 2005, Vidino served as Senior Analyst with Steve Emerson’s Investigative Project on Terrorism (IPT) in Washington. IPT is an anti-Muslim hate group that hallows itself for its collection of intelligence on Islamic terrorist groups, but the IPT’s chief function is presenting Islam as an inherently radical, violent, and antagonistic religion.60

In November 2005, Vidino gave an interview to the far-right, anti-Muslim website FrontPage Magazine. In late 2005, Vidino published an article titled “The Muslim Brotherhood’s Conquest of Europe” in the Middle East Quarterly (MEQ), which is published by Daniel Pipes’ anti-Muslim Middle East Forum (MEF). MEF is a research institute bankrolled by wealthy right-wing donors and MEF itself financially supports right-wing leaders and their activities.61

The CRA references an August 27 report published by Vidino called “The Muslim Brotherhood In Austria” (footnote 96 page 23). 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 research62 and promoting63 Muslims who support anti-Muslim legislation.

Vidino’s work is influenced, and it appears to be funded, by foreign states. According to MEMO, leaks reveal that in May 2017 Vidino and UAE Minister of Foreign Affairs Abdullah Bin Zayed arranged to meet, together with Mokhtar Awad, a research fellow in the GWU Program on Extremism. This meeting was organized by the UAE Ambassador to the United States, Yousef Al-Otaiba, who in email exchanges expressed his goal to “defeat the voices of islamism [sic]” in the U.S.64

Vidino is also accused of censoring research and statements by employees that criticize the UAE and Saudi Arabia, further evidence that these states exert influence over his research and activities. A former employee of George Washington’s Program on Extremism has accused Vidino of stifling academic freedom of speech. The former employee has stated that Vidino attempted to prevent him from writing a story about the death of journalist Jamal Khashoggi for The Atlantic. He said the director later asked editors at The Atlantic to remove all references to the Program on Extremism in the employee’s biography at the bottom of an article critical of Saudi Arabia and the United Arab Emirates.65

Vidino states in his testimony “In some cases they vehemently deny any link to the Brotherhood. If we keep the analysis on a formal level, they have a point…The Muslim Association of Canada would be the first name that comes to mind…They are not part of a pyramid with Cairo on top, but they have the same world view and the same MO as the Brotherhood.”66 Through the audit, it became obvious that the CRA relied on statements similar to this in order to infer links between the Charity and groups abroad. There are three serious problems with this. The first is that Vidino’s point of view is Islamophobic, and his position should have been contested and rejected in the Senate, not relied upon and validated by the CRA. It is no different than falsely claiming that all Protestants have ties to the IRA, or that the Italian-Canadian community’s charities have links to the mafia network, without any evidence supporting such spurious and prejudiced allegations. Certainly, the CRA would not adopt this stance and accuse Protestant Canadian charities of being nontransparent. The second problem is that Vidino’s comment attacks the Charity for sharing a common understanding of Islam with the founder of the Brotherhood and specifically rejects the notion of organizational links between the two. The CRA has used Vidino’s and others’ statements to reject this distinction. In fact, the CRA has responded to the Charity’s unwavering and clear stance on its ideology versus its affiliation with other organizations by accusing the Charity of a lack of transparency. As a result, the CRA has disregarded the Charity’s statements and tried to identify links where none exist, not even according to Vidino. Finally, Vidino is not a source that the CRA should rely upon to develop its understanding of the Muslim Brotherhood or MAC. Referring to an individual who has been repudiated by other academics and who appears to be a channel to foreign interference in Canadian affairs diminishes the credibility and conclusion of the CRA audit.

 

Thomas Quiggin

A 2019 ATIP request with the CRA has shown that in May 2014 Alastair Bland and Cathy Hawara were aware of Thomas Quiggin’s report “The Muslim Brotherhood in North America (Canada/USA)” before it was published and that it was flagged urgently for their attention. While the AFL does not reference Quiggin, based on the ATIP results, it appears that this report was a catalyst for the CRA to initiate an audit into MAC.

Through the language of the AFL, the CRA’s understanding of the Muslim Brotherhood and its unfounded allegations of links to organizations in Canada has been heavily influenced by this report.

According to a 2014 article in Maclean’s magazine: “Quiggin’s report reads more like a doomsday manifesto, predicting the end of Western civilization at the hands of Muslims” and portrays Canada’s Muslim community as “a secretive cabal plotting the downfall of Western civilization from within”.67

After publishing the report Quiggin was sued by a number of parties. Quiggin is currently the subject of defamation claims by other Canadian Islamic organizations and Muslim leaders for defamatory misinformation printed in his reports and on social media.

Quiggin is a writer and speaker at the Manning Centre, the Gatestone Institute, and the Mackenzie Institute. He writes for the blog site Globalbrief.ca. In general, Quiggin focuses on fear-tactics in his reports, warning his audience of a possible Islamization of Canada. As it relates to The Terrorism and Security Experts of Canada Network (“TSEC Network”)68, Maclean’s Magazine reported on June 2, 2014 “Muslim Brotherhood: the new Islamist bogeyman in Canada”, that Quiggin is a “member of the previously unknown Terrorism and Security Analysts of Canada Network”. According to the TSEC Network website, it is comprised of “Canadians who are concerned about the role of extremism and terrorism in Canada…” The website contains very general descriptions of services provided by this network. It does not identify the principals or leaders of this organization. The ‘Research Library’ page is currently under construction. A number of pages contain general articles; no author is credited. In a review of the blog postings, all are authored ‘by Tom’.

Stephanie Carvin, an assistant professor of international relations at the Norman Paterson School of International Affairs, Carleton University has described Quiggin as a guy “in a basement reading Breitbart.” She further states that “Tom Quiggin has not held a government job in almost two decades. Being a “court appointed expert” is not a professional designation/job. His most recent accomplishment is being suspended by YouTube.”69

Quiggin has been discredited for many claims he has made without evidence. For example, in reference to the The Quebec City mosque mass shooting on the evening of January 29, 2017 at the Islamic Cultural Centre of Quebec City, he claimed that the mosque was targeted because it was likely transmitting tens of thousands of Canadian Dollars to terrorist entities.70 Quiggin could not deliver any proof for his claim. Instead, he was discredited by different renowned analysts, other security and terrorism experts, and media outlets as self-styled and obscure.

Haras Rafiq

Haras Rafiq is the managing director of Quilliam Foundation based in the United Kingdom. The CRA has relied on comments 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 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.”71

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.

Quilliam received a grant totaling $1,080,997 from the John Templeton Foundation, covering the period from September 2014 to June 2017. A 2015 peer- reviewed study concluded that the Templeton Foundation was a “key player in the funding of right-wing organizations.”72

In 2010, a Guardian article73 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 Robinson74 and his cousin, Kevin Carroll. Robinson and Carroll at the time were part of the far-right English Defense League (EDL). Quilliam’s senior researcher, Usama Hasan, is listed as one of the founders of the Muslim Reform Movement, a global coalition of reformers who want to “take back the faith.” Other individuals in the movement include Asra Nomani and Zuhdi Jasser. In 2015, Hasan gave a detailed interview to the Clarion Project about the “global struggle against Islamism.” The Clarion Project is listed as an organization in the Islamophobia network, and has published a vast array of anti-Muslim material.75

Middle East Media Research Institute (MEMRI)

The AFL relies upon reports and videos by MEMRI, and translated texts offered by this organization, to draw conclusions in areas of public benefit related to the Charity.

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.76

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.

Brian Whitaker, former Middle East editor (2000-2007) for The Guardian newspaper, has said that 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.”77

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.

TVA Nouvelle

The AFL relies on videos published by TVA Nouvelle to draw conclusions on speeches given by an Imam and whether the speech was contrary to public policy. In 2017, TVA Nouvelles was called out for being complicit in Islamophobia and the rise of the far-right. Protestors accused the media outlet suggesting that “the narrative they’re really pushing is that Muslim women need to be saved from our culture.”78

“It’s time to denounce the completely unethical way in which Québecor has steadily nurtured Islamophobia in Quebec,” organizers said.79 TVA Nouvelles has been accused of routinely broadcasting fake news and fomenting Islamophobia. Protesters called for the channel and journalists involved to be sanctioned for their role in intensifying Quebec’s already Islamophobic climate. They claimed the problem has been persistent for years. There are many reports of TVA Nouvelles’ Islamophobia and links to far-right individuals.

 

UK Government MB Review Report

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 former 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.80 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.81

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 released the key findings of the review.82

Academics have criticized this report as deeply flawed, misleading, and a mischaracterization of the Brotherhood.83 Foreign policy experts and academics told the British Parliament’s Foreign Affairs Committee 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.”84

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 accused the UK government of mishandling the review and criticized it for its failure to provide their committee with a full copy of the report.85

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 ambiguous language to connect the Brotherhood to violence and extremism, to which experts reacted as noted above.

Transnational Islamophobia

In 2014 with a rise of Islamophobia in Canada, there was a similar yet different state-sponsored campaign from 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. But what was surprising was that the UAE listed several organizations based in the US and Europe.86

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.87

The reality of this terrorist listing by the UAE was an attempt to suppress Muslim democratic activism abroad and the Muslim Brotherhood and those who share its ideology, in hopes that western countries would follow suit. However, such attempts in the United States and the United Kingdom have resulted in the opposite. 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, nonprofits and charities, to campus groups, could conceivably be linked to funding and promoting terrorism. Why? Almost any Muslim civil society organizations, charities, or student groups could theoretically be linked to the Muslim Brotherhood based on their shared understanding of Islam or the role played in their founding by immigrants affiliated with the Muslim Brotherhood in the 1960s and 1970s who had recently arrived in the United States. As a result, such a bill has been, rightly, seen to be an attempt to establish a legal rationale for closing down almost any U.S. Muslim organization.88 The same is true for Canadian organizations.

The AFL states on page 17 “The Organization is seemingly aware of the Muslim Brotherhood’s increasing presence on lists of terrorist entities in countries around the world. When the United Arab Emirates (UAE) announced its decision to list the Muslim Brotherhood, Al Qaeda, and Daesh, as terrorist entities in November 2014, the Director of the Masjid Toronto.. “MAC is not included in the list. You can go and fund raise over there (sic) in UAE.” It is not clear why the Organization would be concerned about the possibility of it being included on a list of terrorist organizations if it were not concerned about the activities it were undertaking or with the groups it is associating.” The CRA’s interpretation of this email that the organization may be concerned about the activities it was undertaking is cynical and removed from any context of global events. The email from the Director of Masjid Toronto was not sent out of concern of being listed by the UAE. Rather, it was a sarcastic response to the UAE’s overreach in listing US and Europe based Muslim civil society organizations that are similar to MAC.

In the US, attempts to designate the Muslim Brotherhood have failed. However, like MAC’s audit and false allegations of links to between MAC and the Muslim Brotherhood, these efforts have a chilling effect on the social and religious life of Muslims; that is, individuals and organizations consciously limit their constitutionally protected freedom of expression and activity out of fear of possible sanctions, such as revocation.

UCLA Law Professor Khaled Abou El Fadl has noted, “In the Muslim World, the bogeyman of the Muslim Brotherhood has been exploited by authoritarian governments to repress their citizens for more than half a century.” What is more recent, however, is the increasingly transnational efforts of these authoritarian governments and, in the case of the UAE, the connection with those who advocate for religious freedom in the Arab World. Generally, transnational authoritarianism refers to the phenomenon whereby regimes seek out dissidents and activists among diaspora communities beyond their borders in order to threaten or assasinate, as in the case of the brutal murder of Saudi Arabian journalist and U.S. resident Jamal Khashoggi (himself backed the opinion that the Muslim Brotherhood is a movement for democracy in the region).89

The transnational authoritarianism of the UAE is somewhat different from other states in the region in that the Emirati regime targets threatening ideas rather than individuals or diaspora communities, notably the Islamically informed democratic activism promulgated by the Muslim Brotherhood and other Islamic organizations. Transnationally, through an army of PR firms, lobbyists, and supportive think tanks, the UAE aspires to become a “soft superpower” by changing the very nature of the conversations in North America and Europe around the subject of Islamically informed social and democratic activism in order to promote support for wider clampdowns on Muslim speech, association, and religiosity that it considers a threat.

In trying to justify repression and appease Western audiences, some of these regimes and their supporters have forged an informal alliance with conservative and right-wing groups and figures in the West dedicated to advancing anti-Islamic bigotry. Arab regimes spend millions of dollars on think tanks, academic institutions, and lobbying firms in part to shape the thinking in Western capitals about domestic political activists opposed to their rule, many of whom happen to be religious.90

Prior to 2012 and 2013, the Brotherhood was of little concern to the West, particularly the United Kingdom and the United States. The Brotherhood was rarely covered in mass media and political circles prior to the rise of the Arab Spring in Egypt and the era of President Morsi. Once global attention turned to the Brotherhood, the UAE particularly has worked to create a false narrative of suspicion, mistrust and links to terrorism in an effort to support and legitimize the current Egyptian regime and the agenda of Gulf States.91 This Islamophobic narrative has been adopted by the CRA in its findings on the Muslim Brotherhood.

Misrepresentation of Zachary Laub at the Council on Foreign Relations

In the CRA’s attempt to demonstrate that the Muslim Brotherhood has connections to violent extremism and terrorism, it relies upon a report published by Zachary Laub at the Council on Foreign Relations. The AFL states on page 16 Concerns about the Muslim Brotherhood and its connections to violence have existed since the 1940’s and 1950’s when its members were connected to political violence in Egypt. While the group renounced violence in the 1970’s at the behest of Egyptian President Anwar el-Sadat, it has not always maintained this approach.” Laub’s report published in the Council on Foreign Relations called “Egypt’s Muslim Brotherhood” in fact paints a different conclusion.

Nader Hashemi, who published a report called “Political Islam: A 40 Year Retrospective,” quoted Laub’s report to state that “In contrast to the regime that rules over them, the Egyptian Muslim Brotherhood has officially rejected violence as a means of obtaining political power. Even their strongest critics grudgingly acknowledge this fact.” 92 Furthermore, he explains that there is a new narrative that has emerged. Notwithstanding the Muslim Brotherhood’s rejection of violence and its commitment to electoral politics, this narrative argues that the Muslim Brotherhood still poses an ominous threat and should be ostracized. Specifically, it is claimed that the Muslim Brotherhood acts as a “gateway drug” or “conveyor belt” toward radical fundamentalism. This narrative is adopted in a 2015 Egyptian government commissioned report by the British law firm 9 Bedford Row on the Muslim Brotherhood.

In Laub’s publication in May 2019 called “Blacklisting the Muslim Brotherhood: What to Know” he states “In Egypt, the original Muslim Brotherhood group continues to renounce violence, even in the face of repression.” This confirms that Laub’s research and point of view do not support the conclusion that the CRA has stated in reference to his work.

AFL Position Is Inconsistent with the Government of Canada and its Allies

The Charity has responded clearly about its position and understanding of the Muslim Brotherhood. However, the AFL position on its background of the Muslim Brotherhood is not in line with the Government of Canada’s position.

The AFL on page 17 points out a number of states who have listed the Muslim Brotherhood as a terrorist entity. However, the CRA has ignored Canada’s position and that of its security allies. Despite being specifically asked to designate the Muslim Brotherhood a terrorist organization, Canada has not done so. Parliament’s perspective is again seen in February 2015, when the Minister of Public Safety and Emergency Preparedness, Steven Blaney, was asked to consider designating the Muslim Brotherhood a terrorist organization. The Minister declined. (See attached Schedule “19”) Despite undergoing Parliamentary review and updating Canada’s list of designated terrorist organizations in February 2021, the Muslim Brotherhood was again not designated.93 Clearly Parliament’s judgement is to be trusted.

Parliament has demonstrated a clear and consistent approach to these organizations: they are not terrorist groups.

Similarly, the United Nations, European Union, United Kingdom, United States, Australia, and Germany have all agreed, and not designated Egypt’s Muslim Brotherhood a terrorist organization.94 Some countries, like the United States, United Kingdom, and Germany have specifically engaged in a formal process of considering the conduct of the Brotherhood. Experts were called upon. Documents were considered. The conclusions reached was that the Muslim Brotherhood is not a terrorist organization.95

However, Egypt’s allies and those that feared the public support of the Muslim Brotherhood in their countries jumped on board and made concerted efforts to sway international public opinion.96 For example, Saudi Arabia declared the Brotherhood a terrorist organization in March 2014. The New York Times reports: “The decree was the Saudi monarchy’s latest gesture of support for attempts by the new military-backed government in Egypt to crush the Brotherhood.”97 Saudi Arabia tried to pressure Algeria into following suit, but Algeria refused.98

Furthermore, the AFL references Austria’s decision in 2019 to ban the logo of the Muslim Brotherhood. However, in August 2021 Austria’s court explicitly ruled that the Muslim Brotherhood is not to be regarded as a terrorist organisation in the country.99

In the Washington Post, Marc Lynch, a professor of Political Science and International Affairs at George Washington University and the director of both the Institute for Middle East Studies and the Middle East Studies Program, declares that “there is near universal consensus in the analytical, academic and intelligence communities that the Brotherhood is not a terrorist organization. This is notable given the widespread and fierce disagreement among those experts about other questions, such as whether the Brotherhood is committed to democracy or can serve as a firewall against violent extremism.”100

Significant number of reports have demonstrated that the Muslim Brotherhood has consistently shown respect for democracy and commitment to peaceful participation. There is consensus in academia that the Muslim Brotherhood has represented moderation.101 The defining characteristic of the Muslim Brotherhood is precisely its moderation, its decision to peacefully respect democracy.102

The Charity has been consistent in Description of Muslim Brotherhood

The Charity clearly defines in all of its organizational documents and in its educational material how the organization understands Islam. While the language may have been updated from time to time, the Charity has always stated that it adopts “an understanding of Islam, based on the Quran and Sunnah, as a holistic way of life, articulated in the work of Imam Hassan al-Banna. His articulation of these values is the most comprehensive and most balanced in modern times.”

This was stated in the preamble of the Charity’s governing documents: “An important manifestation of this revival culminated in the writings of the late Imam Hassan al-Banna. Al-Banna’s core messages of balance and moderation, constructive engagement in society, focus on personal and communal empowerment, and organizational development had a deep impact on much of the Muslim world.”

In the Charity’s statement of identity, also found in the governing documents, the Charity more clearly explains the works of Hasan Al-Banna: “We share a framework of understanding of Islam that emphasizes holism, faith-inspired action, justice, and service. This framework is articulated in 20 guiding principles included in The Message of the Teachings by Hasan al-Banna and is meant to enshrine diversity and enable consensus building and team-based activism.”

Some of Al-Banna’s writings are specific to the cultural, social and political context of Egyptian society in the early 20th century, or reflect his own religious views on some issues. Reference is only made to that which is relevant to the Canadian context. The Charity’s interpretation of Imam Al-Banna’s approach to understanding Islam and building a grassroots movement for the benefit of society, takes it beyond his specific context. Much of this is not only applicable to the Charity, but is the mainstream understanding of Islam held by Muslims worldwide.

Since Al-Banna’s ideology was articulated, and first manifested in the Egyptian Muslim Brotherhood, the ideology and understanding of Islam has spread across the world. It is important to note that there are millions of Muslims who adopt this understanding of Islam all over the world, among whom are thousands of renowned figures such as politicians, thought leaders, academics and religious scholars.

Furthermore, many organizations worldwide including religious national and local groups, political parties (some are ruling parties), non-government organizations, and schools, adopt this understanding of Islam. This is not a narrow interpretation of Islam limited to a specific, organized group of people. As MAC understands and teaches it, it is an emphasis on putting faith in action in every aspect of life, which is why it has resonated with Muslims throughout the World as reflecting their own connection with their faith.

By the 1970s – 1980s, there was mass immigration from the Middle East to Europe, the United States, and Canada. Many of these people had experienced Al-Banna’s ideology in one way or another before immigrating from their home country. When they realized that they would not be returning to their countries of origin, at least in the near future, they began to work towards establishing permanent organizations reflecting this understanding that faith must be put in action. Most of these organizations sought to teach this understanding and instill this commitment in a manner prioritizing the needs of new generations of Muslims born and raised in the West.

As such, like many organizations in Europe and the United States, the Charity shares the ideology of Al-Banna but does not maintain or have organizational connections with the Muslim Brotherhood organization. The Charity has remained independent and without influence from the Muslim Brotherhood organization or any other organization.

However, the adoption of this particular understanding of Islam creates an environment for intellectual and academic discourse and debate across borders, such as seminars and conferences where topics and causes related to religion, family, education, global relief, human rights and justice are discussed.

The Charity has always been clear in both external and internal material about its adoption of Imam Al-Banna’s ideology as a modern interpretation of Islam and its teachings. The Charity has furthermore consistently said that it has no organizational ties with the Muslim Brotherhood organization or any other organization. The Charity is a completely independent Canadian organization that does not receive any directives and has no oversight from any other organization. The Charity is only accountable to its members as per its governing document and Canada’s charitable regulations.

The Charity has been, and continues to be, completely consistent and transparent about promoting and advancing Islam as explained above. Every claim by CRA in this section, can be directly tied to promoting the above object of advancing this specific understanding of religion. Any attempt to make a non-existing connection should be considered an attempt to construct a pre-determined conclusion that suggests an unfortunate Islamophobic interpretation.

Political Participation of Individuals

The Charity is not aware of any organization in Canada that has any organizational ties with the Muslim Brotherhood elsewhere. However, there are many Muslims who worked within grassroots movements inspired by the ideas of Al-Banna and the brotherhood in their countries before immigrating to Canada. In fact, some of them came as immigrants or as refugees to escape the repression to which Arab regimes subject individuals affiliated with such groups. There are many more Muslims, individuals and organizations that are inspired by the ideas of Al-Banna.

The Charity’s understanding of Islam represents the mainstream understanding of Islam that is adopted by the vast majority of Muslims. It is distinct because it adds a strong emphasis on pushing outwards: activism for social justice and societal reform.

The Charity has hundreds of members across the country who subscribe to this understanding of Islam. It is only natural that some of them may serve with the Charity in its capacity for religious, educational, and social purposes, but also serve in other organizations who have a focus on relief, social justice, human rights and democracy.

Furthermore, the Muslim community, like any community has been growing to establish the wide range of services and organizations any mature community depends on. It is natural that the Charity’s members who have leadership and organizational skills choose to participate in leading other organizations.

The Charity does not restrict any of its members from participating in external activities or organizations. This is their freedom of expression and association as Canadians and what they do or say in other capacities outside of the Charity is not representative of the Charity.

In this regard, the popular uprisings of the Arab Spring, including the 2011 revolution in Egypt that ended the three-decade-long presidency of Hosni Mubarak, were welcomed by the Canadian government and most countries around the world. Many Canadians of Tunisian, Egyptian, Syrian and other origins chose to participate in democratic transitions in their home countries. Canadian citizens joined different political parties abroad; communities held policy debates and discussions, participated in the media discourse, and voted in elections; and some Canadians travelled to their countries of origin to take part. Canadians publicly participated in the political process in their home countries without concern.

This is no different than the Coptic Egyptian community that played a very public and active role in Egyptian politics or the Ukrainian community that played an active role in Ukrainian politics abroad, or the Jewish community that is actively invested in Israel’s state of affairs.

As the Arab Spring progressed, and the situation evolved, Canadian Egyptians continued to participate. The Charity took the position that members are free to participate as they choose whether in activities in Canada or abroad, and maintain their membership as long as it was legal and within their rights. In December 2012, the Charity’s board of directors adopted a recommendation that anyone in leadership (board of directors or executive council) who takes on a leadership role in a political party abroad should resign from their leadership position. They were not required to resign from membership in the organization.

The AFL has made a number of unfounded allegations in relation to key individuals, specifically [REDACTED] and [REDACTED] as mentioned above.

[REDACTED] was engaged in support for a nascent democratic process by bridge building between Egypt and western anglophone countries. That the CRA would take issue with this is exactly the kind of Islamophobic positioning for which [REDACTED] sought to minimize public attention to his role. [REDACTED] is recognized provincially and in his home city of London Ontario for his professionalism and dedication.

The AFL on page 22 asserts that “No person appears to have had more of an influence on the direction of the Organization than [REDACTED].” Prior to responding to this statement by the CRA, it is important to note that the CRA does not provide any explanation of what its concern is with “MAC’s direction.” MAC has always remained compliant with its charitable purpose and delivered its own charitable activities to its beneficiaries, and always sought to comply with the necessary direction and control required by the ITA. As the CRA is aware, the executive director of any charity manages all of the day-to-day operations of the organization. [REDACTED] acted as the president and CEO from 2002 to 2010, and has acted as Executive Director since 2011. He has contributed and sacrificed for the organization’s growth. He has substantially advanced the organization nationally and expanded its programming, policies, and infrastructure.

He and his executive team work with leadership across the country to develop the organization’s strategic plan that informs the various programs to fulfill the organization’s charitable purpose. He and his team oversee regular reporting on programming, goals and targets across the organization. Like any charity, this is the role of a CEO or ED. Even though [REDACTED] maintains a high degree of institutional knowledge of the organization’s operations, it is inaccurate for the CRA to state that he has the most influence over the direction of the organization.

This ignores and undermines the governance model of the organization. The Annual General Meeting (AGM) elects the Board who then puts forward priorities and objectives. This is prepared with the support of the Executive Director but is ultimately owned by and approved by the Board. The AGM each year approves the annual reports and the financial reports. The AGM is actively involved in discussing and approving proposals on direction of the organization. While the Executive Director is the ultimate decision maker on operational matters, there is not one example that the CRA has been able to present in which a major decision was made without the approval of the Board. The CRA has been provided with all minutes of the AGM, the Board and the Executive Council.

In addition, in footnote 87, the AFL claims that “prominent members of the Organization who have gone to work with Morsi include [REDACTED] (Morsi Policy Advisor) and [REDACTED].” This claim is incorrect. [REDACTED] was not an active member of the Charity and he had left Canada to return to Egypt in 2005. [REDACTED] became active with the Charity a couple of years after his return to Canada in 2019. [REDACTED] left Canada in 2010. [REDACTED] was not a policy advisor to President Morsi, rather he was involved with the Freedom and Justice party. Both were no longer members once they left the country for several years before the revolution in 2011. This is a particularly egregious example of the bias that frames the entire methodology of the AFL. Not only is the CRA suggesting that members of MAC be proscribed from legitimate political participation, in citing these particular examples, it appears to be suggesting that MAC bears responsibility for the lifetime activities of any former member, even ones who no longer live in Canada.

This claim and its respective footnote 87 refer to an email chain among a number of people communicating with their personal emails including [REDACTED] and [REDACTED]. The scope of the audit and email requests did not include personal emails for any of the individuals on this email chain. Furthermore, the choices of individuals to support legal and legitimate activities in their personal capacities is outside the scope of this audit. The Charity rejects the CRA’s notion that the personal activities of leaders in the organization is evidence that the “organization is advancing the Muslim Brotherhood organization” and that “support for the Muslim Brotherhood is manifested in the organization’s activities.”

 

Allegations Concerning Membership Transfers or Shared Membership

CRA alleges at page 27 that, “a review of the Organization’s records appears to indicate that membership in the Organization is not only transferrable to organizations outside of Canada, but that members of other organizations, in other countries, appear to be granted membership in the Organization on the basis of their membership in the foreign organization.”

The AFL concludes on page 28 that, “It is not entirely clear how the Organization, which purports to be entirely Canadian based with no foreign activities, is able to transfer memberships to and from foreign organizations. Considering the Organization’s leadership’s interaction with Muslim Brotherhood leaders, it would appear reasonable to conclude that the transfer of memberships is possible due to the Organization’s close association with these seemingly foreign Muslim Brotherhood organizations.”

Not only is this claim not reasonable, it is simply contrary to the facts and unsupported by the material cited in the AFL. Individuals that come to Canada, become a permanent resident or citizen, have the right and freedom to join the Charity if they are eligible. Without exception, each individual must complete the Charity’s multi-year educational program for new members and if done successfully they are welcome to join the Charity as a member.

There are many organizations globally that adopt similar understandings of Islam, and some adopt the ideology of Imam Hassan Al-Banna. The Charity has no connection with any of these organizations. Some of these organizations abroad may have practises of giving weight to “reference letters,” However, such a letter has a particular consideration in the Charity’s membership process in accordance with its governing documents. The AFL cites in one example that the individual “appeared to have fast-tracked membership” at page 27. However, no evidence to support this speculation is found in the AFL, as each example cited clearly states that each of these individuals who immigrated to Canada completed the Charity’s educational program before becoming eligible for membership.

The Charity provided CRA with its “Newcomers, Relocations in Canada Regulations” (the “Regulations”). This has been completely dismissed by CRA, as the accusations in the AFL make no consideration of this document. It has been provided once again in Schedule “20” to this AFL response.

The Regulations provides as follows:

The Board of Directors or the Executive Council shall have the discretion to waive the time requirements for all classes of membership and all positions of authority set out in these bylaws. In considering whether to exercise this discretion, the Board of Directors shall assess the following factors:

  • The applicant’s Islamic character;
  • The applicant’s special capabilities;
  • The applicant’s record of committed participation with other Islamic organizations pursuing objectives and goals similar to those held by the Association.

The Association may waive these conditions based on interviewing, evaluation orientation of these applicants and satisfying itself with their qualities and knowledge. It may ask them for references in Canada or overseas. The Executive Council will find the means to accommodate newcomers as well as returnees.

Despite a consistent application of the Charity’s membership process, the board has the authority to waive time requirements based on the above requirements. Criteria 1c is sometimes provided by a newcomer to demonstrate a person’s commitment to participation with other Islamic organizations.

In the case of the Charity providing a “reference” letter, the letter simply states that an individual who was a member of the Charity was in good standing.

As it relates to the Muslim American Society (“MAS”), a US-based organization, there are historical ties with the Charity. In this regard, some individuals were members of MAS before the Charity was established, at which point they resigned and joined the Charity. Both organizations have similar objectives and understanding of Islam.

In the early years of the Charity’s establishment, both the Charity and MAS cooperated on community and youth programming in the space of training and development. With respect to membership, since this organization and its leadership is known to the Charity and is the largest grassroots Islamic organization in the US, the organization may be contacted to inform them that a member of the Charity is moving to the US. MAS has a strong support network within its Muslim community. The Charity offers this gesture to its membership, not to “transfer” membership as the CRA has alleged, but to request that the community support the individual and his/her family during their move and as they settle into their new home.

The Charity has hundreds of members, many of whom are transitional families who immigrated to Canada and others who are second and third generation. Over the lengthy period of the audit, the CRA found 8 examples of requests, 5 are individuals who came to Canada and 3 are individuals leaving Canada. This clearly demonstrates that this is not a standard practise with movement of members. In addition, all 8 cases conform to the facts as we have set them out in the foregoing paragraphs.

Finally, when the AFL alleges at page 28 that, “Considering the Organization’s leadership’s interaction with Muslim Brotherhood leaders, it would appear reasonable to conclude that the transfer of memberships is possible due to the Organization’s close association with these seemingly foreign Muslim Brotherhood organizations,” this remark is completely unfounded. There is no evidence found in the AFL that demonstrates that the Charity’s leadership has “interaction” with Muslim Brotherhood leaders, other than the receipt of mass emails for which there is no reply to be found from the Charity as referenced above.

Allegations Concerning Support for pro-Egyptian Muslim Brotherhood Organizations

As noted earlier, the AFL at page 28 alleges that MAC supports groups that are “openly pro-Egyptian Muslim Brotherhood or support the former Egyptian President Morsi of the Egyptian Muslim Brotherhood’s Freedom and Justice Party” and points to Egyptian Canadian Coalition for Democracy (ECCD) and Egyptian Canadian Home Organization (ECHO) as being two such groups.

After the military coup in Egypt in 2013, Egyptian Canadians rightfully spoke out for the respect of democracy and human rights. Shortly after, in August 2013, the Egyptian regime killed thousands of protestors peacefully calling for a return to democracy. These events triggered a global response particularly from human rights organizations. With thousands of innocent people killed, detention and torture of thousands more, many Egyptians were escaping the country from persecution. Within the Egyptian diaspora, including Canada, many organizations were established to advocate for democracy and the respect of human rights in Egypt.

The AFL on page 14 claims “The Organization appears to be supporting mainly two groups: the Ottawa-based Egyptian Canadian Coalition for Democracy (ECCD), the Montreal-based Egyptian Canadian Home Organization (ECHO).” and on page 48 that “These two groups appear to operate in support and advancement of the Egyptian Muslim Brotherhood in Egypt.” With regards to the Egyptian Canadian Coalition for Democracy, the organization is clear on its mandate (vision, mission, and core principles). It states that its mission is “to create and mobilize an advocacy network that is committed to the universal values of freedom, justice, democracy, peace, prosperity, and rule of law, enshrined in Canada in the Charter, and brought to life by the Egyptian revolution. This network will work to raise awareness and mobilize broad-based support in Canada for Egyptians struggling to attain these values in their country. This network will become a model for others and will cooperate in this cause with like-minded individuals and groups around the world.”

The ECCD further states on its website and its press releases that “The Egyptian Canadian Coalition for Democracy (ECCD) is a politically independent, non- affiliated pan Canadian organization that advocates for democracy and human rights in Egypt.”

With regards to the Egyptian Canadian Home Organization (ECHO), the organization states on its website that it “is a Canadian non-profit organization that aims to enrich the cooperation between Egypt and Canada in the fields of scientific and academic research and commercial activity and investment in addition to the consolidation of social relations between the Egyptians in Canada.” The AFL on page 29 takes concern with ECHO’s “supports former Egyptian President Mr. Morsi and opposes the military coup, and has made public statements opposing the Canadian Conservative government.”

The CRA has approached its interpretations of the activities of both these groups from a biased political lens, which is improper for the CRA. The CRA has chosen to view these groups as supporting a particular party or politician, rather than supporting democracy and human rights in Egypt, in order to demonstrate that such activities appear to be “activities that a registered charity are prohibited from undertaking; namely, direct or indirect support of, or opposition to, any political party or candidate for public office.” (page 30)

To the best of the Charity’s knowledge, these groups called for condemning a military coup, respecting democratic institutions, and reinstating a President who was elected by the people of Egypt.

The Egyptian government has attempted to create a narrative that links the Muslim Brotherhood to violent Islamism, legitimize the post-coup labelling of the Muslim Brotherhood as a terrorist organization, and therefore justify the Egyptian government’s violent crackdown on dissent and human rights abuses, and the worst massacre in Egyptian history in which over 1000 protestors were killed by the military regime.103 The ultimate goal is to legitimize President el-Sisi’s coup d’état against Mohammad Morsi, the first democratically elected president of Egypt, and dehumanize the thousands of Egyptians in Egypt and around the world who continue to protest against the coup.104 The CRA has drawn its conclusions about these groups based on this narrative, rather than acknowledge the military coup in Egypt as well as the egregious human rights violations that have occurred in that country.

The CRA’s bias projects an Islamophobic narrative, that organizations opposing the military coup in Egypt and pro-democracy are organizations connected to or supporting of the Muslim Brotherhood.

MAC has no connection to the ECCD. The CRA has identified 6 members of MAC who also volunteer with the ECCD. As stated earlier, MAC does not restrict any of its members from participating in external activities or organizations. This is their freedom of expression and association as Canadians and what they do or say in other capacities outside of MAC is not representative of MAC.

The AFL on page 28 alleges that, “The unpaid use of the Organization’s premises and the extent of cross membership appears to indicate that the Organization is not only aware of the activities of these groups, but is also supportive of their overriding purpose.”

As noted above, unlike many places of worship that congregations attend once a week, mosques have a call to prayer five times a day and additional prayers on specific other days of the week and special occasions. Furthermore, the Charity does not operate strictly mosques, but its facilities are operated as community centers in accordance with its charitable purposes.

With this in mind, the CRA should consider the participation of community members in the Charity’s facilities and the diversity of attendance as well. Usage of the facilities vary and could include at different times:

Often, congregation members who are associated with external organizations may meet in a facility owned by the Charity. This is normal as these congregation members are donors and active participants of the centre. When a meeting room is booked on arrival the individuals are responsible to maintain the room, clean it, and leave it on time and therefore require minimal resources from the organization.

The CRA states at page 31

“As detailed above, there were no records of payment for use of the property in the general ledger and there appears to be a significant overlap in membership between the Organization and the ECCD and ECHO. This would appear to indicate that the Organization is permissive of the activities and events occurring at its properties and is supportive of the ECCD and ECHO’s purpose in general.”

Allowing community groups, such as ECCD and ECHO whose members are regular congregation attendees of MAC’s centre to use the facility without payment is not indicative of the Charity being “supportive of the ECCD and ECHO’s purpose in general.”

In general, the Charity does not usually charge congregation members who request the usage of a meeting room. The specific events listed by the CRA are responded to in detail below, but the examples the CRA has highlighted include special prayers in the mosque, social gatherings, or community discussions, all of which are reasonable uses of the Charity’s centres not related to the support of any political party or group. In the case of a large gathering the AFL has shown that a rental application was submitted.

The following are some comments regarding each example: 

November 2013 – ICCO – Campaign for [REDACTED]

January 25, 2014 – Rahma Mosque – “Edmonton Car Rally” hosted by the ECCD

March 1, 2014 – Abraar School – “Shaheed Night” hosted by ECCD

August 15, 2014 – ICCO – “First BBQ Event” by the ECCD

December 25, 2014 – Abraar School – The ECCD Iftar

August 13, 2016 – Centre Communautaire Laurentien – ECCD / February 19, 2017

                                 – Centre Communautaire Laurentien (CCL) – ECCD/ECHO

CRA also alleges the use of the Charity’s facilities as being partisan support of a political party, but does not provide any specific examples as to how the Charity directly or indirectly did so, and instead refers the Charity to CRA’s draft guidance on public policy dialogue and development activities which reflects statutory changes to the ITA that occurred well after the Audit Period. In this regard, CRA is retroactively applying provisions of the ITA which did not exist at the time of the audit.

Discriminatory Approach in Relation to Other Faith Groups

The Charity reaffirms that it does not have any links with organizations outside of Canada.

Overall, the AFL treats the Charity in a discriminatory manner by suggesting that a faith-based organization in Canada having any linkage with an organization overseas is to be a suspect. In this regard, there are many Canadian faith-based charities that have explicit connections that may result in influence on the charity.

The Charity is further concerned that the CRA is prejudiced to the Charity in a manner that it does not apply to other charities. The examples below demonstrate that in the charitable sector it is common that charities maintain connection to any organization abroad, and some examples where it can be argued may result in undue influence on the charity.

The Evangelical Fellowship of Canada (EFC)106

The EFC has hundreds of affiliate CRA registered charities that subscribe to its objects and statement of faith. However, the EFC is a member of The World Evangelical Alliance (WEA). Its staff and former staff serve in the WEA leadership. Some senior examples include:

The EFC is affiliated with The Peace & Reconciliation Network of the World Evangelical Alliance. The EFC is part of the EFC Global Mission Roundtable that seeks to maximize the effectiveness of the Canadian evangelical community in global mission.

The United Church of Canada

The United Church works with over 100 partners in God’s mission around the world. Global partnerships are formal relationships with national churches, ecumenical organizations, Christian councils, church agencies, and civil society organizations around the world.107 The United Church of Canada states “The United Church of Canada and its predecessors have been engaged in global partnerships for more than 150 years. Over that time a lot has changed, including the church’s understanding of itself and its mission in the world. In 2008, the Executive of the United Church’s General Council approved a “Statement and Affirmations on Global Partnership,” including 10 guiding principles.”108 Therefore, it is clear that its global partnerships have influence over the Canadian charity and its members.

Friends of Simon Wiesenthal Center for Holocaust Studies

The Friends of Simon Wiesenthal Center for Holocaust Studies state “In all this, we celebrate and advocate for the existence, safety and security of the State of Israel – the homeland of the Jewish people. We attend national and international meetings to reinforce our friendship and advocate our affection for the Jewish state.” They also state “We defend Israel against antisemitic motivated campaigns that aim to delegitimize,boycott, and defame the nation and place its security in jeopardy.” The charity is clearly spending charitable resources on attending international conferences that could result in influence over its leadership.109 Charitable resources are spent on defending a foriegn state or possibly given to the State of Israel.

According to the Canadian Foreign Policy Institute, a mid-1990s survey found there were more than 300 registered Canadian charities with ties to Israel and in 1991 the Ottawa Citizen estimated Canadian Jews sent more than $100 million a year to Israel and possibly as much as $200 million110

Jewish Federations of Canada 111

The Jewish Agency for Israel (JAFI) is a primary agent for JFC-UIA in carrying out its mandate. Keren Hayeso, a UIA representative, works to further the national priorities of the State of Israel and Israeli society.

There are many examples of Canadian charities that have explicit links or partnerships to international organizations or movements. There are many examples of individuals who serve as leadership for Canadian charities also serving on international entities that have clear influence over the Canadian charity. In the case of MAC, the organization has neither. Yet, CRA has singled out the Charity accusing it of advancing non-charitable purpose due to unsubstantiated allegations of ties to the Muslim Brotherhood, despite its transparency since the day of its charitable registration, updates in amending its governing documents, and during the audit.

Footnotes:

56  https://www.fatf-gafi.org/media/fatf/documents/reports/mer4/MER-Canada-2016.pdf

57  https://www.fatf-gafi.org/media/fatf/documents/reports/fur/Follow-Up-Report-Canada-2021.pdf

58 https://bridge.georgetown.edu/research/factsheet-lorenzo-vidino/

59  https://bridge.georgetown.edu/research/factsheet-common-anti-muslim-tropes-2/

60 https://islamophobianetwork.com/organization/investigative-project-on-terrorism/

61 https://www.nytimes.com/2021/04/23/world/europe/uk-far-right-tommy-robinson-russia.html

62 European Islamophobia Report 2017 https://www.islamophobiaeurope.com/wp-content/uploads/2018/04/Austria.pdf

63 European Islamophobia Report 2018 http://www.islamophobiaeurope.com/wp-content/uploads/2019/09/AUSTRIA.pdf

64 https://www.middleeastmonitor.com/20171109-exclusive-uae-works-to-defeat-voices-of-islamism-in-the-west-reveal- leaked-emails/

65 https://www.gwhatchet.com/2019/10/16/former-program-on-extremism-employee-criticizes-director-for-attempted- censorship/

67  https://www.macleans.ca/news/world/the-muslim-brotherhood-the-new-islamist-bogeyman-in-canada/

68 https://web.archive.org/web/20161105214447/http://tsecnetwork.blogspot.com (the site has been removed)

69 https://twitter.com/i/web/status/1138326975385354240 70https://pressprogress.ca/manning_centre_hosts_bonkers_panel_claiming_quebec_city_mosque_was_actually_helping_terrori sts/

71 https://bridge.georgetown.edu/research/factsheet-quilliam/

72 http://www.ncsociology.org/sociationtoday/v131/tea.html

73  https://www.theguardian.com/uk/2010/aug/04/quilliam-foundation-list-alleged-extremism

74  https://www.nytimes.com/2021/04/23/world/europe/uk-far-right-tommy-robinson-russia.html

75 https://islamophobianetwork.com/organization/clarion-project/

76 https://cdn.americanprogress.org/wp-content/uploads/issues/2011/08/pdf/islamophobia_chapter4.pdf

77  https://islamophobia.org/islamophobic-organizations/middle-east-media-research-institute/

78  https://thelinknewspaper.ca/article/tva-nouvelles-complicit-in-islamophobia-and-rise-of-far-right-protesters-sa

79  https://montrealgazette.com/news/local-news/debunked-mosque-story-rally-targets-tva-nouvelles-islamophobia

80  https://www.theguardian.com/world/2015/nov/06/uae-told-uk-crack-down-on-muslim-brotherhood-or-lose-arms-deal

81  https://www.middleeasteye.net/fr/news/muslim-brotherhood-review-tale-uk-uae-relations-378120043

82  https://www.theguardian.com/world/2015/nov/06/uae-told-uk-crack-down-on-muslim-brotherhood-or-lose-arms-deals

83 Written evidence from Alison Pargeter, Researcher and Middle East Analyst, to UK Parliament (May 2016), online:

<http://data.parliament.uk/writtenevidence/committeeevidence.svc/evidencedocument/foreign-affairs-committee/political- islam/written/32762.html>

84 See also United Kingdom, Parliament, The Foreign Affairs Committee, “’Political Islam’ and the Muslim Brotherhood Review” in Committee Publications (3 November 2016), online:

<https://publications.parliament.uk/pa/cm201617/cmselect/cmfaff/118/11810.htm#footnote-037>.

85  https://www.middleeasteye.net/opinion/between-two-reviews-reading-uk-parliamentary-report-political-islam

86 https://www.aljazeera.com/news/2014/11/16/uae-lists-scores-of-groups-as-terrorists

87 https://www.hrw.org/news/2014/12/04/uae-terrorism-law-threatens-lives-liberty

88 https://religionandpolitics.org/2021/04/06/when-promoting-religious-freedom-abroad-threatens-minority-communities-back- home/ 

89 https://religionandpolitics.org/2021/04/06/when-promoting-religious-freedom-abroad-threatens-minority-communities-back- home/

90  https://foreignpolicy.com/2019/03/29/arab-regimes-are-the-worlds-most-powerful-islamophobes/

91 TMC Advisory Group, Muslim Brotherhood and the Myth of Violence and Terrorism (2015)

92 Nader Hashemi, Political Islam: A 40 Year Retrospective, https://www.mdpi.com/2077-1444/12/2/130/html

93 https://www.ctvnews.ca/politics/canada-adds-proud-boys-to-terror-list-bringing-range-of-legal-financial-implications-

1.5293967

94  https://www.middleeastmonitor.com/20190221-germany-muslim-brotherhood-peaceful-movement/

95 https://carnegieendowment.org/2019/05/03/nine-reasons-why-declaring-muslim-brotherhood-terrorist-organization-would- be-mistake-pub-79059

https://www.hrw.org/news/2013/12/28/egypt-terrorist-tag-politically-driven

96 https://myemail.constantcontact.com/CSID-Bulletin—Why-the-Muslim-Brotherhood-is-NOT-a-terrorist-organization—by- John-L–Esposito.html?soid=1102084408196&aid=SNDS2q96CIk

97  https://www.nytimes.com/2014/03/08/world/middleeast/saudis-put-terrorist-label-on-muslim-brotherhood.html

98  https://www.echoroukonline.com/algeria-refuses-to-consider-muslim-brotherhood-as-terrorist-organization

99  https://www.middleeastmonitor.com/20210806-austria-court-rules-muslim-brotherhood-not-a-terrorist-group/

100 https://www.washingtonpost.com/politics/2019/05/01/designating-muslim-brotherhood-terrorist-organization-has-failed- before-why-is-it-returning-now/

101 TMC Advisory Group, Muslim Brotherhood and the Myth of Violence and Terrorism (2015), 37

102 TMC Advisory Group, Muslim Brotherhood and the Myth of Violence and Terrorism (2015), 39 

103  https://www.hrw.org/report/2014/08/12/all-according-plan/raba-massacre-and-mass-killings-protesters-egypt

104 https://blog.oup.com/2014/08/terror-metanarrative-rabaa-massacre/ 

105https://www.cbc.ca/news/canada/toronto/a-dream-come-true-khaled-al-qazzaz-stuck-in-egypt-since-2013-arrest-finally- home-1.3744932 

106 https://www.evangelicalfellowship.ca/About-us/Global-Initiatives

107  https://united-church.ca/community-and-faith/welcome-united-church-canada/partners-mission/global-partners