CIMM – Fraud – October 21, 2025

Key Messages

• IRCC has a multi-layered approach to prevent, detect and address fraud in immigration applications.
• When it comes to fraud, IRCC is primarily focused on two issues: (1) identifying organizers of coordinated fraud and (2) individuals who knowingly commit fraud or attempt to deceive IRCC.
• IRCC actively targets organized and coordinated fraud schemes through its administrative investigations and undertakes fraud disruption techniques in collaboration with the Canadian Border Services Agency (CBSA), who is responsible for pursuing enforcement action related to foreign nationals in Canada. This is critical to preventing systemic abuse within immigration and citizenship programs and to hold bad actors accountable.
• IRCC collaborates closely with domestic and international enforcement bodies, as well as provincial and territorial partners to identify cases of concern and program integrity issues, and to promote effective cross-jurisdictional information sharing. This integrated approach reinforces Canada’s overall fraud response capabilities.

Organized Crime and Other Public Investigations

• Canada maintains a zero-tolerance approach to fraud and organized crime. Under the Immigration and Refugee Protection Act, individuals convicted of serious crimes are inadmissible and may lose their immigration status, with CBSA empowered to enforce removal orders.
• IRCC collaborates with CBSA, the RCMP, and international partners to detect and disrupt organized crime while raising public awareness to encourage reporting of suspicious activity. Measures include enhanced document verification, expanded biometric checks, and improved international data-sharing.
• IRCC has been monitoring recent fraud concerns related to recent media coverage in Quebec, which include:
  • International criminal organizations, primarily from West Africa, exploiting Canada and Canadians through activities such as romance scams, vehicle theft, financial crime, and potential terrorism financing, posing risks to public safety, immigration integrity, and financial systems.
  • It is possible that study permits may be misused as one method for individuals to gain access to Canada. IRCC is working to decrease the ability to abuse its programs by implementing safeguards such as verifying all Letters of Acceptance (LOAs) with schools and regularly monitoring students’ engagement in their studies through the International Student Compliance Regime (ISCR).
  • IRCC is working with the Province of Quebec to have its Designated Learning Institutions (DLIs) join the ISCR and report to IRCC the enrollment status of their students. Once Quebec is on board, all provinces and territories will be part of the regime. International students destined to Quebec must also obtain approval from the province which adds a layer of rigour to the decision making process.
  • It was also identified recently in the media that criminals may conduct financial crimes using counterfeit passports, money transfer apps, victims’ bank accounts, and cryptocurrency channels to launder funds for their organizations.
  • IRCC takes a firm stance against abuses of our programs. When information is uncovered it is shared with our partners such as CBSA and RCMP to take enforcement action. Permanent and Temporary residents who are convicted of criminal offenses are inadmissible to Canada and subject to removal. Business owners participating in illegal activity may also be charged with criminal offences.
  • When IRCC uncovers or is informed of individuals abusing our programs, we are able to flag cases to our processing offices to prevent further abuse and disrupt the activities of these criminals.

Misuse of the Temporary Foreign Worker Program

• The Temporary Foreign Worker Program (TFWP) allows employers to fill short term, temporary labour market gaps when Canadians and permanent residents are not available. The Program is jointly administrated by Employment and Social Development Canada (ESDC) and IRCC with the support of CBSA. Questions related to misuse or fraud under the TFWP program should be directed to ESDC.
• Canadian employers who want to hire a temporary foreign worker under the TFWP must submit and obtain a positive Labour Market Impact Assessment (LMIA) through ESDC. ESDC assesses LMIA requests received and makes an assessment on the genuineness of the employer and on the impact these temporary foreign workers would have on the Canadian labour market. IRCC reviews and processes the work application submitted by the temporary foreign workers by assessing whether applicants meet admissibility (health, criminality, and security), eligibility and regulatory requirements necessary for work permit issuance, including the genuineness of the job offer.
• LMIA misuse is a principal concern for the Temporary Foreign Worker Program (TFWP) and refers to the buying and selling of LMIA applications, as well as the unethical recruitment and exploitation of vulnerable foreign nationals for personal and financial gain. LMIA misuse can be carried out by employers, third parties and/or temporary foreign workers including stakeholders overseas.
• ESDC has a number of tools already in place to mitigate risks linked to program misuse, including:
  • an enhanced LMIA assessment employers and/or sectors identified as high-risk for LMIA fraud to ensure their business operations and employment needs are genuine
  • tightening documentation requirements to prove their business legitimacy
  • increased administrative monetary penalties (AMP) for non-responsive employers when it is determined through an inspection that the business does not exist or if they appear to be engaging in LMIA misuse, from $15,000 to up to $45,000 with a 5-year program ban, and applied to every position on the LMIA instead of one single penalty
  • Increased use of Ministerial Instructions to suspend positive LMIAs (e.g., in cases of suspected program misuse, and/or when there is serious risk to the worker’s health and safety). Work permit applications associated with suspended LMIAs are also suspended until ESDC has either lifted the suspension or revoked the LMIA
  • Suspending and/or revoking previously approved LMIA positions where there is reason to suspect program misuse, at an earlier stage in the inspection process. This prevents employers from hiring additional workers until the situation is resolved or until the inspection is completed
• While LMIA misuse is primarily addressed by ESDC, IRCC also addresses this issue by:
  • training officers to detect misuse when assessing the genuineness of a job offer prior to issuing a work permit;
  • participating in domestic and international outreach with a focus on advancing ethical recruitment practices; and
  • maintaining dedicated web pages on LMIA Fraud on IRCC websites
  • implementing a new temporary measure making it that Express Entry candidates no longer receive additional points for having a job offer. This temporary measure, instituted in Spring 2025, will reduce fraud by removing the incentive to illegally buy or sell labour market impact assessments to improve a candidate’s chances of being selected to come to Canada as a permanent resident.
• Canadian employers hiring foreign workers on employer-specific work permits under both the IMP and the TFWP are subject to an employer compliance regime to promote safe and fair working conditions for foreign workers, to help prevent program misuse, and to ensure that they comply with the conditions imposed under the Immigration and Refugee Protection Regulations (IRPR).
• Employer compliance inspections under the IMP are conducted by IRCC, whereas inspections under the TFWP are conducted by ESDC.
• Under both programs, should an employer be found non-compliant following an inspection, they may be subject to a warning, an Administrative Monetary Penalty (AMP), or a ban from the Program. The AMP amount and the length of the ban are determined based on several factors, including the type or classification of the condition, any past history of non-compliance, and the severity of the violation. All employers found non-compliant who have received an AMP and/or a ban under either program are listed on a public website.
• To support workers, Service Canada offers a confidential tip line, available 24/7. Live agents are available in 200 languages. Concerns can also be reported anonymously through an online reporting tool. Workers are encouraged to report any concerns about unsafe conditions and protections are in place to help ensure workers can speak up without fear of reprisal.
• Instances of suspected criminal activity, including fraud, are referred to the appropriate authorities including the CBSA, RCMP or local police force.

Updated Regulations to Address Misconduct by People who are Paid for Representation or Advice

College of Immigration and Citizenship Consultants Regulations

• The Government established the College of Immigration and Citizenship Consultants in 2021 to regulate immigration and citizenship consultants and protect the public from fraud.
• The College is an important part of the government’s efforts to fight fraud in Canada’s immigration system. IRCC maintains oversight to ensure the College fulfills its mandate to protect the public and strengthen the integrity of the immigration and citizenship consultants’ industry.
• IRCC is introducing regulations to further define the structure and operations of the College. These new regulations aim to improve the regulation of immigration and citizenship consultants.
• The regulations will
  • elaborate on the College’s authorities under the College of Immigration and Citizenship Consultants Act (College Act) in such areas as the public register, the complaints and discipline processes, and investigations conducted by the College;
  • prescribe the management of the College’s compensation fund for victims of unethical immigration and citizenship consultants; and
  • clarify the Minister’s power to appoint someone to take over the board of directors’ duties if it fails to meet its responsibilities under the College Act.
• The draft regulations were published in the Canada Gazette, on December 21, 2024, followed by a 45-day public consultation period during which stakeholder feedback was received and considered. The regulations are anticipated to take effect in spring 2026.

Administrative Penalties and Consequences (APC) Regime

• The Government of Canada is introducing a new system called the Administrative Penalties and Consequences (APC) regime. This system is being added to immigration and citizenship system to help protect people from fraud and unauthorized advice.
• The new regime allows IRCC to issue monetary penalties to people who give immigration or citizenship advice or representation without proper authorization, or who encourage others to lie or misrepresent information. In addition to monetary penalties, IRCC will be able to publish the names of those who break these rules.
• To enforce this, IRCC will be able to inspect records and request documents from those offering paid services. The new system will apply to Anyone who is paid to give immigration or citizenship advice or represent someone during the application process. This includes authorized professionals like licensed consultants and lawyers, as well as unauthorized individuals in Canada or abroad.
• Monetary penalties are issued per application, so someone can be fined multiple times if they break the rules on several applications. Anyone who receives a penalty can ask for a review by an independent reviewer.
• Fines vary based on the violation ranging from $5,000 for each case of unauthorized practice to $15,000 for each case of encouraging misrepresentation. Total penalty amounts can go up to $1.5 million.
• The proposed changes were published in the Canada Gazette on December 21, 2024, with a 45-day public consultation with the final rules expected to come into effect later in 2025 or early 2026.