CASL compliance not built into AI outbound sequences
Canadian businesses running Apollo.io or Lemlist outbound sequences without documented consent records for each recipient are carrying a CASL enforcement risk. CASL requires either express consent or a valid implied consent basis — prior business relationship within 2 years, or published contact details with relevance — for every commercial electronic message. AI outbound sequences that pull contacts from purchased lists or web-scraped databases and send without consent verification are in breach. The CASL Spam Reporting Centre receives complaints and the CRTC has issued enforcement notices and fines to businesses running non-compliant mass email campaigns. The fix is not difficult: it requires a consent status field in your outbound tool, a consent basis documentation template, and a process for verifying consent before contacts enter the sequence.