thomasmoreai/arckit-ca-fitaa

> ⚠️ 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

text
$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

1. 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

1. Use scripts/bash/generate-document-id.sh <PROJECT_ID> FITAA --filename for the artefact filename.
2. Resolve the <!-- DOC-CONTROL-HEADER --> marker per RENDERING.md. Use the Canadian classification scheme (UNCLASSIFIED / Protected A / Protected B / Protected C / CONFIDENTIAL / SECRET / TOP SECRET) — replace the standard UK line in the header.
3. 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.

1. 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.
2. Write the artefact via the Write tool to projects/<project-id>/<filename>.
3. 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.