What is the test for complicity in crimes against humanity?

From these principles, it follows that where there is no evidence of direct involvement in the commission of crimes against humanity, the characterization of the nature of the organization is a critical factor in a finding of complicity. Where an organization is characterized as being principally directed to a limited brutal purpose, a presumption operates which may result in a finding of complicity in the absence of any further evidence other than membership. The fact that the organization exists for a single purpose leads to the assumption that, as stated by McKeown J. in Saridag v. Canada (Minister of Employment and Immigration), [1994] F.C.J. No. 1516 at paragraph 10 “... its members intentionally and voluntarily joined and remained in the group for the common purpose of actively adding their personal efforts to the group's cause. This assumption gives rise to a presumption of complicity on the part of any refugee claimant who was found to be a member of such a group ...”. A shared common purpose is presumed unless the applicant is able to rebut the presumption.