Veronica Moye was the only licensed immigration consultant in a commercial operation that spanned Dubai, India, and Vancouver. She signed the retainer agreements. She was the authorized representative on every file. And she did essentially none of the work. When five clients complained to the CICC, her explanation was that she had too many files to supervise personally. The Panel's response was permanent revocation. Delegation is not a defence. It never was.
The Ontario Court of Appeal has clarified what the good character requirement actually demands of licensing panels. Working through the standard Armstrong factors: remorse, rehabilitation, passage of time is not enough. Panels must step back and ask the harder question: would granting this licence be consistent with public trust in the legal profession? In Law Society of Ontario v AA, the Tribunal failed to ask that question. The Court of Appeal set the decision aside.
Regulators across professions say that members are expected to maintain professional standards in both their professional and personal lives. What matters is not where you posted or whether you were acting in your professional capacity at the time, but whether the conduct would reasonably be regarded as reflecting on your fitness to hold a licence. A personal account on a public platform is still public, and in the age of real names, profile bios, and professional identifiers, the connection to your profession is easy to make.
Years of practice management failures did not ultimately determine the outcome. Instead, the decisive issue was licensing dishonesty. After commencing and continuing articling without having received a required Certificate of Qualification, the Tribunal found willful blindness despite the respondent’s assertion that he had no intention to deceive. The case underscores a critical regulatory principle: uncertainty about eligibility is not a defence, and integrity in the licensing process can become a determining factor.
Many RCICs believe that giving a client portal access fulfills their duty to keep them informed. In reality, this "Portal Trap" often leads to CICC complaints. Under Section 38(2) of the Code, you are strictly liable for staff oversight, and under Section 22(3), you must provide proactive written updates regardless of portal access. Whether through outsourced neglect or assuming the client is monitoring their own file, systemic failures are not a legal defense. Learn the 3 SOPs every licensee needs to protect their license