July 31, 2023

Open Letter to Office of the Superintendent of Financial Institutes pdf

CC:         CSIS  Facsimile: 613-231-0612

FinTrac  communications3@fintrac-canafe.gc.ca

Dear Superintendent Routledge,

RE: Follow-up to our letter to Bank of Canada and Regulatory Capture Issues of Concern

On July 19, 2023, we faxed and emailed to your organization a copy of our Open Letter to the Bank of Canada.

We are deeply concerned that foreign funded Environmental Non-governmental Organizations (ENGO) have skewed and are skewing Canadian banking policies.

In our recent Open Letter to the Bank of Canada, we referred to the US Senate Testimony of Prof. Jessica Weinkle on the many serious conflicts of interest in the world of climate finance and risk analysis.  More recently, Prof. Weinkle has questioned the level of ‘regulatory capture’ of financial oversight institutions like yours. As our letter to the Bank of Canada revealed that “The Science” behind catastrophic/climate emergency claims is deeply flawed, Prof. Weinkle’s recent comments on regulatory capture and scientific integrity are relevant:

Regulation that deviates from the public interest

Regulation in and of itself is not problematic. And regulation is desirable.

The problem comes when regulation favors the special interest in sacrifice of the public interest.

Whatever the merits on climate related financial risk disclosure, popular methods and much of media reporting on climate change utilizes information resulting from lapses in scientific integrity.

Scientific integrity is in the public interest because reliable empirical knowledge provides a sound basis from which to develop and assess policy options, and hold policymakers accountable for their choices.  

Science that lacks integrity is little more than political ideology expressed in technocratic terms. It undermines democracy by obscuring the locus of accountability for decision outcomes. And it is dangerous for society because it injects unnecessary ignorance into the decision making process- in this case, the global financial system. (bold emphasis added)

Indeed, it appears that the climate finance regulatory capture is so deep that even the IMF cannot stand to hear the works of  John Clauser, recipient of the 2022 Nobel Prize in physics, who states there is no climate crisis (a view confirmed by the IPCC AR6 WGI Physical Sciences report, as noted in our previous open letter).  But the IMF will cite Greta Thunberg.

Likewise, despite those who have lobbied you on climate risk and mandatory reporting[1] claiming that missing the 1.5 °C target would cause an existential threat, the new Chair of the Intergovernmental Panel on Climate Change (IPCC), James Skea, a scientist, not a climate activist, has stated that it is wrong to present surpassing that temperature mark as an existential threat.[2] Indeed, in March of 2019 he said that the IPCC SR1.5 report “The panel “did not say we have 12 years left to save the world”, but no one seemed to be listening,[3] or rather they were only listening to Greta Thunberg.

A sample list of foreign funding to some of the larger Canadian ENGO charities from Robert Lyman’s “Big Green Money” report. https://blog.friendsofscience.org/wp-content/uploads/2019/02/Big-Green-Money-NO-vs-PRO-FINAL-RevB-FEB-12-2019-2.pdf

Whether you approve or despise the Freedom Convoy, the fact is that allegations were made by former Bank of England and Bank of Canada Governor, Mark Carney, that foreign funding was behind the movement and that this threatened Canada’s economy and security, stating “Foreign funders of an insurrection interfered in our affairs from the start.”  As reported by CSIS, this was later proven to be untrue by FinTrac.

The same can be said about the power of the influence of foreign-funded Environmental Non-governmental Organizations (ENGOs), most of them are federally registered charities whose obligations under Canada Revenue Agency policy are supposed to provide a net public benefit to Canadians. Instead, we have endured job loss and economic decline due to climate change and environmental policies promoted by these foreign funded groups.

As you may or may not be aware, many of these ENGOs have been foreign-funded for the express purpose of blocking the Alberta oil sands, pipelines for oil or natural gas, creating nature reserve exclusion zones where resource development or shipping routes are no longer permitted, and engaging in nuisance lawsuits to delay, block and rewrite legislation to make it more difficult for energy and resource companies to do business in Canada. (See Appendix for grant examples)

This has been extremely damaging to Canada’s economy. Robert Lyman, former public servant of 27 years, 10 years a diplomat, has summarized some of the losses in revenues and employment in “Prosperity Foregone.”

Thus, it is alarming to see that the OSFI has been consulting with some of these foreign-funded ENGOs – Environmental Defence, Ecojustice and Shift Pensions (an offshoot of TIDES/MakeWay) to set policy. These groups ironically claim in their submission to you on climate risk,[4] that it appears Canadian oil and gas assets will be stranded, when these are the parties that have been actively participating in the Tar Sands Campaign, the goal of which was stated as:

Above – excerpt of the Tar Sands Campaign strategy paper by Corporate Ethics. See examples in Appendix.

It seems clear that this is a ‘green trade war’ against Canada, disguised as saving the planet, while benefitting competitor nations and decimating our own economy.

In 2012, Michelle Stirling, our Communications Manager, wrote to your organization as a private individual expressing concerns that the ENGOs were going to be taking on the banking sector. Your organization directed her to the Environment Ministry.  In the interim, what she was concerned about has come to pass.

Ms. Stirling was formerly employed at Alberta Environment in 2005 when the Sierra Club issued a scathing review of Alberta’s climate and environment policies, which were then outstanding examples of climate and environmental leadership in North America.

Canada’s economically destructive carbon tax has its roots in foreign-funded lobbying of the Sierra Club, then under Elizabeth May, with this grant from the Oak Foundation out of Switzerland. These and other grants can be seen in the Oak Foundation grant documents, publicly available and downloaded here.

The International Funders for Indigenous Peoples reported in 2010 that ENGOs and Indigenous groups partnered in Canada and the US to block Keystone XL with the ultimate objective (as shown in the screenshot on page 2) of completely shutting down the Alberta oil sands.

Returning to the notion of the influence of foreign-funding on Canadian climate and environmental policy, none other than Anders Fogh Rasmussen, former chief of NATO has said that there is evidence that Russia is behind the funding of many environmental, non-governmental groups.  Belgian author of “The Green Reich,” Drieu Godefridi confirms this.  Interesting that Russia saw the Kyoto Protocol as a threat to human civilization. Why would they (or other competitor nations) not capitalize on the gullible West to ensure that Canadian oil, gas, coal, and critical minerals are blocked from market by a web of evermore burdensome regulations and blockades, driven by foreign-funded ENGO lobbying, destroying finance and insurance options to the resource industry driven by perhaps naïve but passionate ENGOs?

Indeed, it is curious that when Germany and Japan came shopping for natural gas supply from Canada, the influential Canadian charity ENGO International Institute for Sustainable Development (IISD) strongly opposed any efforts to supply either with Liquified Natural Gas (LNG).

Source: CRA 2021-03-31 IISD return

It appears that most of their funding, some $18 million of $25 million, comes from foreign sources, which are not identified by the CRA reporting system. The point being, Canadian energy and resource policies, which drive our economy and jobs, are being skewed by foreign funded agents in a manner that threatens our fiscal and energy security and many of these groups are directly engaging with your organization. As Weinkle suggests, this appears to be a case of regulatory capture that is detrimental to the public interest.

If the Freedom Convoy was deemed a threat to national security, allegedly due to foreign funding which was shown to not be true, why are these many foreign-funded ENGOs not seen in a similar light, particularly when there are many questions about the ultimate sources of their foreign-funds. The intent is clear, as laid out in “Design to Win” – to fund local ENGOs to agitate for a change in policy desired by ClimateWorks and other major foreign ‘green’ promoters, making it appear as if local grassroots citizens desired these policies.

The Alberta Inquiry/Allan Inquiry along with the Deloitte Forensic Audit show that tremendous sums of foreign money have funded organizations with stated intentions to change government policy or to affect economic drivers of Alberta and Canada.

We have published two reports showing the impacts of the Tar Sands Campaign: “Fear and Loathing” and “Protest or Green Trade War,” the latter challenging claims of Environmental Defence that the Tar Sands Campaign was ‘just a protest.’ Our four reports by Robert Lyman reviewing the funding and influence of foreign and domestic funded ENGOs are here.[5]

As per our recent Open Letter to the Bank of Canada, the climate world is fraught with conflicts of interests and claims of a climate emergency are not supported by the scientific evidence, no matter what the ENGO front men say. Foreign competitors, whether directly or indirectly funding these groups, or simply capitalizing on their efforts, are winning while Canada is losing. And it appears that your organization is engaging with foreign-funded actors on policies that are destructive to our economy and resource sector and not in the public interest.

Ironically, while all regulated securities offerings and operations under your supervision must put disclaimers and cautionary notices about forward-looking statements on their documents, there is no such requirement for your climate risk reporting, which is surely less likely to be accurate a decade or a hundred years from now.

As noted in our Open Letter to the Bank of Canada, China’s policy of #MadeInChina2025 and plans to dominate the world by 2049 are clearly benefitting from the climate risk reporting policies that you are setting.  Note that 2049 is just one year shy of #NetZero2050 – the climate policy target that is deindustrializing the entire West. This puts our country at risk in terms of energy and economic security. Yet there is no mention of either Chinese foreign policy in your recent webinar, nor is there in the Bank of Canada’s climate risk assessment. Why? Certainly with the recent revelations of PRC China meddling in Canadian affairs, this should be of significant concern to the banking and finance sector.

We are pleased to know, as per your June 5, 2023, webinar,[6] that:

So, as I hope is clear, OSFI will remain vigilant. We will take swift and decisive action where necessary. We’ll prioritize transparency with all of you and with the general public. And we believe by doing these things well we will contribute to public confidence in the Canadian financial system. We aim to provide clear insights into the risks we see and we aim to listen to feedback when folks don’t agree with our insight into those risks or our view of them.

We would like to hear your views on this important discussion about public policy and finance. We would like to know how you will handle climate change issues going forward now that you are aware of the conflicts of interests and lack of scientific integrity in mainstream climate change dogma.


Ron Davison, P. Eng.


Friends of Science Society

Excerpt of Oak Foundation grant database circa 2013.

Excerpts of Oak Foundation grant database circa 2014.

Oak Foundation funded the above-described efforts to block access to shoreline for Alberta oil sands and to cancel Enbridge Northern Gateway pipeline. The information suggests political influence/interference as well.

Ecojustice states the many laws in which it has had some influence in the above note.

This excerpt from a Financial Post article showing that Ecojustice was foreign-funded at that this funding was reported to the US IRS by Living Oceans to stop the Trans Mountain pipeline.

[1] https://environmentaldefence.ca/report/climate-finance-risks/

[2] https://www.dw.com/en/dont-overstate-15-degrees-c-threat-new-ipcc-head-says/a-66386523

[3] https://apnews.com/article/fe7c9d4a9f8f458c827677d31230f594

[4] https://environmentaldefence.ca/wp-content/uploads/2021/05/Shift-Environmental-Defence-Ecojustice-OSFI-climate-related-risk-consultation-submissions-2021-04-12.pdf

[5] https://blog.friendsofscience.org/2019/05/07/environmental-charities-a-compilation-of-reports-on-their-finances-power-and-implications-for-canada/

[6] https://www.osfi-bsif.gc.ca/eng/osfi-bsif/med/sp-ds/Pages/pr20230605.aspx