CICC v Moye, 2026 CICC 13
Veronica Moye was a registered Canadian immigration consultant for almost fifteen years. She was a director of CanApprove Immigration Services Limited, a company owned by someone else, operated primarily out of Dubai, and staffed almost entirely by people who held no licence at all. She was the only RCIC in the entire operation.
When five clients complained to the College of Immigration and Citizenship Consultants, Moye’s position was straightforward: she had delegated the file work to trained staff. She had too many files to manage personally. The people doing the work knew what they were doing.
The Panel was not persuaded. On April 21, 2026, it permanently revoked her licence, fined her $50,000, ordered restitution to four clients, and awarded the College $41,850 in costs.
The lesson is not complicated. You can delegate the work. You cannot delegate the responsibility.
What CanApprove Actually Was
CanApprove’s business model was built around a promise: pay us, and we will find you a job in Canada and get you permanent residency. Staff in Dubai and India would tell prospective immigrants that they were eligible for Provincial Nominee Programs or employer sponsorship programs, collect retainers of approximately $25,000 per client, and promise results within months.
The retainer agreements named Moye as the authorized representative and consultant. She signed them. She was the only person in the organization authorized under the IRPA to provide immigration services. What she did not do was provide them.
Files were handled entirely by unlicensed staff. Moye had no day to day involvement with any of the five complainants. She communicated directly with only one of them, and when that client began pressing her for answers, she blocked him on WhatsApp. No Provincial Nominee Program applications were ever submitted for any of the clients. When clients asked for refunds, CanApprove pressured them to sign settlement agreements releasing their right to full repayment, in exchange for partial refunds paid in post dated cheques spread over months.
One client received a full refund. He got it only after threatening to report Moye to the authorities.
The Supervision Obligation Is Not Optional
The Code permits RCICs to delegate tasks to staff. It does not permit RCICs to walk away from the files those staff are handling.
The distinction between delegation and abdication is central to this decision. Delegation means assigning tasks while maintaining oversight, reviewing work, staying informed about file progress, and remaining accessible to clients. Abdication means signing the retainer agreement and then disappearing from the file entirely. Moye did the latter across five complaints spanning multiple years.
The Panel found that unlicensed CanApprove staff were conducting initial consultations, assessing client eligibility for permanent residency programs, advising on documentation requirements, and communicating with clients throughout the life of the retainers. Every one of those activities constitutes the provision of immigration services under the IRPA. All of it was happening without a licence and without any meaningful oversight from the one person in the organization who held one.
Moye’s explanation was that she had too many files to supervise personally. The Panel rejected this without hesitation. Accepting more clients than you can properly supervise does not discharge your supervisory obligation. It is itself a breach of your professional obligations.
Your Signature on the Retainer Agreement Is Not a Formality
One of the most important aspects of this decision is what the Panel said about Moye’s role in the organization. Her licensure, the Panel found, gave the CanApprove enterprise an air of legitimacy. That framing should be uncomfortable for any RCIC who has ever signed a retainer agreement for files they did not intend to actively supervise.
When you sign a retainer agreement, you are not performing an administrative function. You are assuming full professional responsibility for everything that happens on that file from that moment forward. It does not matter that the business is owned by someone else. It does not matter that other people are doing the day to day work. It does not matter that those people are experienced or well trained. The retainer agreement creates the professional relationship, and you are the professional in it.
The Job Selling Problem
Beneath the supervision failures was a more fundamental issue: the business model itself was illegal. British Columbia’s Employment Standards Act prohibits charging a person seeking employment for the service of finding them a job. The Temporary Foreign Worker Protection Act contains equivalent prohibitions. CanApprove’s retainer agreements charged clients precisely for that service, and Moye signed those agreements.
The Panel found that Moye knew or ought to have known that LMIA costs were required to be borne by employers, not workers. She collected them from workers anyway. That was job selling, and it rendered the entire scheme improper regardless of any other consideration.
The Panel also noted that the clients in this matter were vulnerable. They were foreign nationals navigating an unfamiliar immigration system in a language and legal framework they did not fully understand. They paid large sums of money for a new life in Canada and received nothing. When they asked for their money back, they were pressured into signing away their rights to full repayment. The Panel found this pattern to be reprehensible.
What This Means for RCICs in Practice
The structure that Moye participated in is not unusual. There are immigration consultancies operating across Canada where the RCIC is one person and the operational reality is a larger commercial enterprise: offshore offices, unlicensed staff handling client files, business owners who are not licensees, third party recruiters managing placement.
If you are the RCIC in that kind of structure, this decision is directed at you.
It does not matter how the business is organized. It does not matter what the internal division of responsibilities looks like. What matters is whose name is on the retainer agreement. If it is yours, the professional obligations that flow from that agreement are yours. The work being done on those files is being done in your name. The advice being given to those clients is being given under your licence. And if something goes wrong, the College will hold you accountable for all of it.
Supervision is not a box to check. It is an ongoing, active professional obligation that requires you to know what is happening on your files, to review the work being done by your staff, to be available to your clients, and to intervene when things go wrong. The fact that you have many files does not reduce that obligation. It increases the care you need to take in how you structure your practice.
If you are an RCIC with concerns about your supervision obligations, your business structure, or a complaint that has been filed against you, contact Tamir Litigation Law Firm. We defend RCICs before the CICC and understand what the College expects.
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This commentary is for informational purposes only and does not constitute legal advice.
FAQ
1. I run a busy immigration consultancy and I delegate most file work to my staff. Am I personally responsible if something goes wrong on a file I did not personally handle?
Yes, entirely. The CICC’s decision in Moye makes clear that delegating file work to staff does not transfer your professional responsibility for that work. You remain the authorized representative on every file you sign. That means you are responsible for reviewing the work your staff performs, remaining accessible to clients, and ensuring that everything being done on those files meets the standards the College requires. If your staff makes errors, provides incorrect advice, or fails to deliver promised services, that is your professional failure, not theirs.
2. I have too many files to supervise every one personally. Is that a defence if the College investigates me?
No. The Panel in Moye expressly rejected this argument. Accepting more clients than you can properly supervise is itself a breach of your professional obligations, not an excuse for the supervision failures that follow. If your practice has grown to the point where meaningful supervision is not possible, that is a signal to restructure your practice, not a justification for operating without oversight.
3. My firm is owned by someone who is not an RCIC. I am the only licensee. What are my obligations in that structure?
Your professional obligations to every client whose retainer agreement you sign are unchanged by the ownership structure of the business. The College does not regulate the business owner. It regulates you. Everything that happens on files bearing your name as authorized representative happens under your licence and within your professional responsibility. If unlicensed staff are providing immigration advice or services to clients in that business, you are responsible for supervising that work and ensuring it complies with the IRPA and the Code. If the business model itself involves prohibited conduct, such as job selling, your signature on the retainer agreements makes that your professional problem.
4. What is job selling and why does it matter to RCICs?
Job selling refers to charging a person seeking employment for the service of finding them a job. In British Columbia, this is prohibited under the Employment Standards Act and the Temporary Foreign Worker Protection Act. Federally, employers who obtain an LMIA are prohibited from recovering recruitment costs from the worker. RCICs who charge clients fees for securing employment or employer sponsorship as part of an immigration pathway are engaging in job selling, regardless of how those fees are described in the retainer agreement. The CICC has treated job selling as serious professional misconduct in multiple decisions, and in Moye it was one of the central grounds for permanent revocation.
5. What should I do if the CICC has received a complaint about my supervision of staff or the structure of my practice?
Engage legal counsel immediately and before responding to the College. How you respond to an investigation, what you say, what documents you produce, and how you characterize your role in the files under review can all significantly affect the outcome. The College’s investigators are experienced and the complaints process moves quickly once a referral to the Discipline Committee is made. Early and properly advised engagement gives you the best opportunity to present your position effectively and protect your licence.
This commentary is for informational purposes only and does not constitute legal advice.