Is membership of an international terrorist organisation sufficient to establish complicity?

Mere membership in an organization which from time to time commits international offences is not normally sufficient to bring one into the category of an accomplice. At the same time, where the organization’s primary objective is achieved by means of crimes against humanity, or it is directed to a limited, brutal purpose, membership will generally be sufficient to establish complicity (Zazai, FC, above, at para. 28; Thomas v. Canada (Minister of Citizenship and Immigration), 2007 FC 838, 317 F.T.R. 6, at para. 23).