–This modified
definition could impact charities carrying on activities
outside of Canada where their programs in a foreign
jurisdiction include a “related business” activity permitted
under the ITA, or a charitable program that involves an
inherently commercial element, such as microfinance
•A
second important amendment will repeal the “facilitation payment”
exemption provision of the Corruption of Foreign Public
Officials Act on a date to be fixed by order of the
Governor in Council
–Currently, such facilitation
payments are excluded from the prohibition on bribery
–As a result, in the future,
charities could be exposed to possible criminal liability for
activities which, up to now, have been permitted
•