Bill C35 has been sold as the Cracking Down on Crooked Consultants Act. In fact, the most appropriate label would be the Protecting Crooked Consultants Act.
Bill C35 grants the Minister the authority to designate and revoke the regulator of immigration consultants. Kenney has already proposed to revoke the designation of the Canadian Society of Immigration Consultants (CSIC) and designate the ICCRC as regulator. ICCRC is not a regulator, ICCRC is in fact CAPIC, the Canadian Association of Professional Immigration Consultants, a trade association that protects the interests of immigration consultants. CAPIC President Hemlin has been revoked by CSIC's independent discipline council for serious professional misconduct, and ordered to pay costs of $50,000. His case in fact gives a clue as to the future of immigration consulting under ICCRC.
Bill C35 also criminalizes ghost consulting; that is it imposes criminal sanctions on those who provide immigration assistance for a fee if you are not a lawyer or member of the designated body, proposed to be ICCRC. In fact, the reality is that Canada has no jurisidiction over ghost consultants operating overseas. Also, ghost consultants in Canada can simply become Agents of ICCRC members and continue to operate, making a massive profit for the crooked ICCRC member that sells their membership to the ghost consultants.
That is exactly what one can see taking place in the Hemlin decision, available at He signed and sold blank Use of representative forms to a Chinese ghost agent related to an investor program scheme; this conduct was deemed acceptable by the CAPIC Members who re-elected Hemlin President despite the disciplinary decision. CAPIC is ICCRC; all ICCRC Board members (self-appointed, none have been elected) are from CAPIC.
Welcome to immigration consulting under ICCRC; ghost consultants simply work as Agents of ICCRC members ensuring that the profits of ghost consultants are shared with the ICCRC cartel. While honest, hard-working immigration consultants struggle to make ends meet, CAPIC Members through ICCRC can make huge profits as a direct result of Bill C35.
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