The authority for any level of government to do anything is by enacting laws. Under the Constitution, the federal government has exclusive jurisdiction to enact criminal law so, by definition, all federal law is 'criminal law'. But not every piece of legislation creates offences and those that do must clearly state so (i.e. 'everyone who does x if guilty of an offence'). I haven't looked at it in a while, but I doubt the Conflict of Interest Act creates offences. It empowers the Commissioner to conduct an investigation and table a report of findings. Period.