When you compare it to the FATF guidelines, and if you take a look at the U.S. Treasury guidelines, at the Charity Commission of England and Wales, they have much more comprehensive terms.
What you have is a very short list that does not give justice to the complexities of what's involved with the anti-terrorism legislation. It asks questions such as, do you have a good understanding of the background and affiliation of your volunteers? That's a question. How do you do that? How do you implement that on a practical basis? Do you know who's using your facilities and your office, and your telephone and fax, and what they're saying? How can you possibly take that from a practical context and put that into meaningful terms of reference?
For clients, we have prepared long policies—some 27 pages—trying to put that into context. What would be much better would be for CRA to work with the charitable sector to come up with something practical so it's not just the questions, but rather recommendations about what needs to be done similar to what's been done in the U.S., similar to the international FATF, and similar to England and Wales.