By Terrance S. Carter, Nancy E. Claridge, and Sean S. Carter

Canada’s 2024 Intelligence Priorities Framework: Implications for Charities and Non-Profits

In September 2024, the Canadian Privy Council Office released an updated framework for Canada’s intelligence priorities (2024 Framework), aiming to address an expanding array of security threats, including foreign interference, cyber risks, and economic vulnerabilities. While charities and non-profits may not immediately see themselves as a primary focus of these priorities, many aspects of this document are highly relevant for the sector, particularly as organizations operate in increasingly interconnected, digital, and internationally influenced environments.

The Canadian government’s 2024 Framework emphasize transparency, diversity, and inclusion in national security, acknowledging persistent challenges, such as unconscious bias and discrimination within intelligence organizations. Recognizing negative past experiences among marginalized communities, the government aims to rebuild trust through concrete action, including gender-based and identity-sensitive analysis (“GBA Plus”) to inform policy and mitigate unintended impacts on minority groups. Transparency efforts include information sharing, executive accountability, and policy engagement, with a focus on understanding and addressing the unique risks faced by vulnerable communities in Canada and globally.

The 2024 Framework outlines Canadian intelligence as a critical tool for government decision-making, supplying analyzed information on national security concerns, like foreign threats, cybersecurity, and organized crime. Intelligence is collected legally by agencies like CSIS and the RCMP, processed into reports, summaries, and assessments, then shared within government or, when appropriate, declassified for public awareness. This intelligence helps predict threats, supports policy, and guides responses to risks impacting Canada’s economy, infrastructure, and public safety. Additionally, the document highlights diversity and transparency commitments within intelligence, aiming for fair and inclusive security practices.

Canada’s intelligence oversight includes three main bodies: The National Security and Intelligence Committee of Parliamentarians, which examines intelligence frameworks and activities across agencies; the National Security and Intelligence Review Agency (NSIRA), ensuring activities by CSIS and the RCMP are lawful and reasonable; and the Intelligence Commissioner, who reviews ministerial authorizations before specific intelligence operations proceed. Together, these bodies maintain legal compliance and accountability in Canadian intelligence practices.

Canada’s 2024 Framework guides intelligence efforts across four main objectives: countering foreign threats, advancing prosperity and security, defending national interests, and protecting Canadians from serious risks. These priorities address issues, such as foreign interference, economic security, and cybersecurity. They also include environmental, health, and climate-related risks, acknowledging their growing impact on national security.

Canada’s intelligence priorities offer a framework for aligning intelligence efforts with national interests, aiming to improve transparency and public trust. This first publication reflects a commitment to engage Canadians in national security matters, supported by oversight and review bodies. Facing complex, evolving threats to security and prosperity, Canada’s intelligence community collaborates with domestic and international partners to build resilience and address future challenges. The government pledges ongoing efforts to enhance public understanding and confidence in intelligence activities.

Canada’s 2024 Framework provides charities and not-for-profits (NFPs) with a good understanding of the comprehensive security regime the Canadian Government and its priorities when considering how best to comply with Canada’s anti-terrorism legislation, In this regard, charities are reminded that the CRA Charities Directorate has recently posted an updated checklist on how charities can comply with Canada’s anti-terrorism legislation titled “Checklist: How to protect your charity against terrorist abuse” that was reported on in our September 2024 Charity and NFP Update.

A Review of Canada’s 2023-2026 AML/ATF Strategy

In addition to the report on Canada’s 2024 Intelligence Priorities Framework referenced above, it is worth mentioning that in March 2023, the Department of Finance Canada (“Finance”) released its 2023-2026 Anti-Money Laundering (AML) and Anti-Terrorist Financing (ATF) Strategy (“AML/ATF Strategy”), its first AML/ATF Regime Strategy published by the Government of Canada. The stated goal of the AML/ATF Strategy is to fortify the country’s defenses against financial crimes that fund terrorism, organized crime, and other unlawful activities. Central components are stated to include bolstering regulatory standards, increasing inter-agency collaboration, enhancing beneficial ownership transparency, and leveraging technology to identify and address risks in both traditional and emerging financial sectors.

The AML/ATF Strategy states that it aims to safeguard the financial system and national security by countering money laundering and terrorist financing. It outlines coordinated actions among federal, provincial, and international partners to address financial crime risks. The strategy emphasizes public accountability, regulatory improvements, intelligence sharing, and enforcement support to enhance transparency and efficiency. Priority areas are stated as including strengthening interagency cooperation, addressing high-risk sectors, and adapting to emerging threats, ensuring comprehensive, ongoing protection of Canada’s financial integrity and public safety.

Money laundering is stated as concealing the origin of criminal funds, benefiting criminals and organized crime, while terrorist financing involves gathering funds for terrorism, potentially leading to violent acts. Canada’s Anti-Money Laundering and Anti-Terrorist Financing (“AML/ATF”) Regime is stated as working on three pillars: policy and coordination (assessing risks and creating policies), prevention and detection (ensuring compliance and analyzing financial intelligence), and investigation and disruption (identifying and prosecuting offenses). Together, these pillars are intended to detect, prevent, and disrupt financial crimes, enhancing security and stability, both in Canada and internationally.

Canada’s AML/ATF Strategy is stated as emphasizing global partnerships to tackle international financial crimes. Canada works with the Financial Action Task Force (“FATF”), FATF-Style Regional Bodies (“FSRBs”), the Egmont Group Financial Intelligence Units, and the Five Eyes partnership with the US, the UK, Australia and New Zealand to identify trends, share intelligence, and establish AML/ATF standards. As an active contributor, Canada coordinates with these partners, supporting transnational investigations and adopting best practices to counter money laundering and terrorist financing. Collaborative international efforts are stated as helping to strengthen Canada’s domestic AML/ATF framework and enhance overall security and financial integrity.

Canada’s AML/ATF Strategy also emphasizes staying ahead of evolving money laundering and terrorist financing threats. With rapid digitalization across financial sectors, risks have emerged from technologies like virtual currencies, fintech, and digital identity systems, especially in the pandemic's wake. The National Inherent Risk Assessment (“NIRA”) identifies primary money laundering sources in Canada, such as drug trafficking and fraud, while highlighting groups like Hizballah as key terrorist financing threats. The NIRA, updated in March 2023, also addresses risks from ideologically motivated violent extremists and assesses sectors like banking and trade-based services for vulnerability, enhancing national AML/ATF readiness.

Recent evaluations   found Canada’s AML/ATF Regime to be effective, with improved coordination and reporting supervision, producing “good quality intelligence”. However, gaps remain in areas, like information sharing, convictions, and proceeds recovery. Reports, including the 2016 FATF evaluation, noted weaknesses, particularly around beneficial ownership transparency, recovery of the proceeds of crime, and information sharing. Non-profit organizations, distinct from registered charities, apparently face potential terrorist financing risks due to a monitoring gap. To address these, Canada’s AML/ATF Regime continues to adapt via its governance framework, improving standards based on international guidelines and internal assessments.

Though the AML/ATF Strategy was released last year, it is an ongoing progress and should be reviewed by charities and NFPs who might be at risk of terrorist financial abuse due to the nature of their activities and the geographic regions in which the operate.

Canada Lists Samidoun as a Terrorist Entity

On October 15, 2024, the Canadian government listed Samidoun, also known as the Palestinian Prisoner Solidarity Network, as a terrorist entity under Canada’s Criminal Code. This listing aligns with similar actions taken by the United States and Germany, as Samidoun is linked to the Popular Front for the Liberation of Palestine (“PFLP”), a listed terrorist organization. This classification criminalizes any form of support, including financial and material assistance, to Samidoun. Any charity or NFP that are continuing to deal with Samidoun should be seeking legal advice.

​Read the October 2024 Charity & NFP Law Update