arckit-ca-fitaa

name	arckit-ca-fitaa
description	[COMMUNITY] Generate a Canada FITAA (Foreign Influence Transparency and Accountability Act, Bill C-70 2024) compliance assessment — activity scoping, arrangement register design, public vs protected views, Commissioner liaison protocol, Charter §2 risk register.

⚠️ Community-contributed command — not part of the officially-maintained ArcKit baseline. Output should be reviewed by qualified Canadian counsel, your departmental ATIP coordinator, ITSEC officer, and (for FITAA matters) the Office of the Commissioner of Foreign Influence Transparency before reliance.

Statutory currency: FITAA was enacted June 2024 with regulations still emerging through 2025–2026. The Commissioner's office is newly stood up and operational guidance will evolve. Verify all citations against the current Justice Laws Website text and Commissioner's published guidance before relying on this output.

User Request

$ARGUMENTS

You are an enterprise architect generating a Canada FITAA Compliance Assessment for a federal entity.

Process

1. Read prerequisites:
   • projects/000-global/ARC-000-PRIN-*.md (federal principles, if present)
   • The project's REQ, STKE, DR, and DMOD artefacts (if present)
   • .arckit/templates/_partials/RENDERING.md
2. Read the template:
   • First, check .arckit/templates-custom/ca-fitaa-template.md (user override)
   • Then, .arckit/templates-custom/ca-fitaa-template.md
   • Fallback, .arckit/templates/ca-fitaa-template.md
3. Use node scripts/generate-document-id.mjs <PROJECT_ID> FITAA --filename for the artefact filename.
4. Resolve the <!-- DOC-CONTROL-HEADER --> marker per RENDERING.md before writing the artefact. RENDERING.md hard-routes the CA regime to _partials/document-control-ca.md, which already carries the Policy on Government Security categorization ladder — no per-command classification override is needed.
5. Generate the following sections (the template provides skeletons for each):
   • Activity Scoping — statutory triggers (covered arrangements with foreign principals to influence government / political processes / public discourse), excluded categories (journalism, academic research subject to standard exemptions), and a decision tree mapping the project's specific activities. Cite specific FITAA provisions where statute numbering is settled; mark as <TBC at draft time> where regulations are still pending.
   • Arrangement Register Design — data fields per registration (registrant identity, foreign principal, activity type, start/end dates, financial flows where required), public-facing fields (transparency objective), protected fields (national-security exemptions), and the 14-day update cadence for material changes.
   • Registration Workflow — submission channel (web / paper / both — bilingual per ca-ola), identity verification approach, acknowledgement and registration ID issuance, material-change update flow.
   • Public Register vs Protected Investigative Data — data flow diagram (textual or Mermaid), severance rules (cross-reference ca-atip), withdrawal/correction process.
   • Commissioner Liaison Protocol — interface with the Office of the Commissioner of Foreign Influence Transparency, reporting cadence (suspected non-registration, suspected falsification), RCMP / CSIS coordination touchpoints (cross-reference ca-soia).
   • Charter Risk Register (cross-reference ca-charter) — s.2(b) freedom of expression chilling-effect mitigations, s.2(d) freedom of association proportionality analysis, mitigation tracker.
   • Compliance Schedule (registrant-side) — arrangement triggers, the 14-day clock, penalty exposures (cite specific FITAA offence sections where settled; otherwise <TBC>).
   • Open Items — explicit list of statutory currency caveats: which regulations may post-date the artefact, which guidance from the Commissioner is still pending.
6. Populate the External References section per .arckit/references/citation-instructions.md. The Foreign Influence Transparency and Accountability Act (Bill C-70, 2024) MUST appear in the Document Register with its primary URL (Justice Laws Website) and the verification date.
7. Before writing the file, read .arckit/references/quality-checklist.md and verify all Common Checks plus the FITAA per-type checks pass. Fix any failures before proceeding.
8. Write the artefact via the Write tool to projects/<project-id>/<filename>.
9. Show only a summary to the user (one paragraph plus the headline Charter §2 risk findings and any open statutory-currency items).

Authoritative anchor

Foreign Influence Transparency and Accountability Act (FITAA), enacted June 2024 as part of Bill C-70 (An Act respecting countering foreign interference). Authority: Office of the Commissioner of Foreign Influence Transparency. Primary URL: https://laws-lois.justice.gc.ca/ (search for the consolidated FITAA text).

The FITAA Regulations status MUST be flagged as "verified as of [date]" in the External References section because regulations are still being made — see the FITAA-specific banner above for the warning.

Important notes

• Do NOT confuse FITAA with the Lobbying Act or the Conflict of Interest Act — those are separate transparency regimes with different scopes and registrars.
• Charter §2 engagement is mandatory — any registration scheme that captures advocacy, journalism, or political activity is presumptively engaging Charter §2(b) and §2(d). The ca-charter handoff is unconditional for FITAA outputs.
• Public vs protected severance is not optional — the public register and the investigative back-end must be designed as separate logical systems with audited severance rules; conflating them creates ATIP-Act exposure under §16 (law enforcement) and §15 (national security).
• Statutory cite numbering — where FITAA section numbers are not yet settled in the consolidated text, use <TBC at draft time> placeholders. The reviewer can fill these in once the consolidated text is published.
• Bilingualism is mandatory — the public-facing register, registration forms, acknowledgements, and notices must be available in both official languages per the Official Languages Act. Cross-reference ca-ola.

Suggested Next Steps

After completing this command, consider running:

• $arckit-ca-charter -- Charter §2 expression and association analysis is required for any registration scheme that engages protected speech or association.
• $arckit-ca-pia -- Privacy Impact Assessment for personal information collected during arrangement registration.
• $arckit-ca-atip -- Reconciles the public-facing register against the protected investigative dataset; required severance design for hybrid views.
• $arckit-ca-aia -- Triggered when registration triage uses any automated decision-making, scoring, or risk classification.