Research | Under Layered Suspicion

publication date: Apr 27, 2021
author/source: Anver M. Emon and Nadia Z. Hasan

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

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

Under Layered Suspicion draws attention to the Government of Canada’s anti-terrorism financing and anti-radicalization policies. When these policies are operationalized by the CRA's Charities Directorate and the Review and Analysis Division (RAD), they create the conditions for potential structural bias against Muslim-led charities.

The study shows that in the crosshairs of these policies, Muslim-led charities are uniquely vulnerable to penalties or even deregistration at the hands of the CRA.

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

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

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

Read the full report at

Anver M. Emon is Canada Research Chair in Islamic Legal History, and Professor of law and history at the Faculty of Law and Department of History at the University of Toronto, where he directs the Institute of Islamic Studies. A member of the College of the Royal Society of Canada, senior fellow at Massey College, and a Guggenheim fellow in 2014, Emon’s scholarship explores the history of Islamic law and its deployments in the present.

Nadia Z. Hasan is the Chief Operating Officer of the National Council of Canadian Muslims, a civil liberties and human rights organization that advocates against Islamophobia and racism in Canada. Hasan has a PhD in Political Science. Her research focuses on Islamophobia, gender and Muslim identities and practices.

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