Names of directors and like officials of revoked charities
are not maintained in a single publicly available database
Not likely that an individual who
otherwise controlled or managed the operation
of a charity would be identified in
publicly available documents likely
information solely in CRAs control
Onus is now shifted to charities to
comply in a situation where it is
impossible to ensure 100% compliance
because the necessary information is not available
This new cause for revocation is similar
to a strict liability offence no due
diligence defence is available in the
legislation
Charities will be required to undertake
other forms of due diligence and hope
CRA will excuse any inadvertent
non-compliance