CIMM – Responses to MP Letter– June 14, 2023

Prepared by: IRM

Issue

• Letter from MP Tom Kmiec, M.P. and Brad Redekopp, M.P
  • How were these fraudulent admissions letters approved by IRCC during the study visa application process and why were there no proper safeguards in place to protect these prospective students?
  • Why did it take years to discover these college admissions letters were fraudulent and why was an inspection not conducted during the application process?
  • What measures need to be implemented to bring an end to this practice?

Questions and Answers

How were These Fraudulent Admissions Letters Approved by IRCC During the Study Visa Application Process and why were there no Proper Safeguards in Place to Protect These Prospective Students?

• Letters of Acceptance (LoA) verification requests are sent for verification during the processing of an application if an officer has concerns regarding the submitted LoA.  [Redacted]
• IRCC works with its local and international partners to detect and deter fraud, and is continuously improving its systems to detect evidence of fraud. Where fraud tips are involved, IRCC will look into each tip.
• Canada has taken decisive measures to combat organizers of coordinated fraud. This includes holding immigration and citizenship consultants to account by investing $48.3 million over four years and $9.8 million ongoing to improve oversight, strengthen enforcement, and increase accountability to protect the public from dishonest consultants and other bad actors who take advantage of vulnerable people.

Why Did it Take Years to Discover these College Admissions Letters were Fraudulent and why was an Inspection not Conducted During the Application Process?

• A Letter of Acceptance Verification Project (LoAVP) was launched in 2018; the project is a centralized office within IRCC to communicate with designated learning institutions (DLIs) to verify the authenticity and validity of letters of acceptance (LoA).
  • A processing officer refers LOAs for verification with the DLI to confirm its authenticity if the officer has reason to believe the document is fraudulent.
  • When there are multiple cases of fraud that suggest a pattern, trends may emerge that suggest an unscrupulous consultant or bad actor operating in the background. We have resources in place to conduct an administrative investigation. Investigations take time to gather facts and evidence.
• Once the initial SP is approved, the student would typically not be examined again until a future application is submitted, which may be several years later in some cases.
• Officers may consider previous temporary resident applications when assessing subsequent immigration applications. This may lead to the discovery of fraud on previous applications.
• If there are any suspected organizers located in Canada, the information will be referred to CBSA Criminal Investigations to pursue criminal charges. CBSA Criminal Investigators do not have authority to investigate crimes committed outside of Canada.

What Measures Need to be Implemented to Bring an End to this Practice?

• IRCC has taken a multi-pronged approach to combatting fraud in the student movement in recognition of the complexity of the issue. The approach includes the mobilization of resources, regulatory changes, and the overlay of technology and client outreach efforts all coordinated with the aim of combatting fraud in key markets. (Risk Assessment Officer, streamlined verification Letters of Acceptance (LOA) and using analytics to identify high risk cases).
• IRCC maintains a post-issuance compliance regime for the international student program. Twice a year, Designated Learning Institutions (DLIs) across Canada are expected to report on the enrollment status of study permit holders who are associated to their DLI in IRCC records. Based on the information provided by the DLIs it can inform subsequent application processing and post arrival student compliance verifications. These activities also help the department to identify fraud trends.
• To increase the integrity of the program and to help protect vulnerable students from nefarious actors, IRCC will begin to implement an in-house solution in the fall of 2023 to verify letters of acceptance with designated learning institutions. This is a stepping stone towards a modernized international student program, including future trusted institution model, and complements program integrity measures already in place.
• A review of the International Student Program is underway with a key pillar to strengthen program integrity and enhance protection to address student vulnerability, unethical recruitment and non-genuine actors.