- PLEASE SUMARISE THIS CASE

Particulars of the allegations:

i. At all material times, Mr. Artem Djukic (the "Member") was a registered member of the Immigration Consultants of Canada Regulatory Council (the "ICCRC").

ii. On or about June 11, 2017, M.T. retained the Member to obtain and process a Labour Market Impact Assessment ("LMIA"), Work Permit and Canadian Experience Class applications.

iii. M.T. entered into a retainer agreement with the Member and executed a Use of Representation form.

iv. M.T.'s uncle, B.A. paid the Member $15,000 in professional fees on behalf of M.T.

v. The Member promised M.T. and B.A. that 80% of the profession fees would be returned if the result of the application was not favourable.

vi. The Member also advised that the chances of an unfavourable outcome were "slim".

vii. Over the subsequent weeks, the Member failed to communicate with B.A. or M.T. When B.A. and/or M.T. followed up on the status of the application, the Member would make excuses and fabricate reasons for the delay. Eventually, the Member threatened them by saying, "if you call me one more time, you won't get a penny back".

viii. On or about May 22, 2018, the Member agreed to a refund, and informed B.A. that he had mailed a refund cheque; however, no refund was ever received.

ix. The Member received $15,000 in professional fees and failed to provide any immigration services.

x. The Member has failed or refused to return the funds even though he claims to have mailed a refund cheque.

xi. The Member has not provided a refund as agreed.

("BA"), filed a complaint against Djukic with ICCRC. DA executed a Witness Evidence Form.

41. Around April 2017, DA and BA met with Djukic about obtaining immigration status for their nephew Mr. MT ("MT"), who had come to Canada to visit them. Djukic told DA and BA that he could obtain a job for MT at a company called "L. Construction", and then apply for and obtain permanent residence status for him. Djukic advised DA and BA that the cost for these services would be $15,000.00 Canadian Dollars ("CAD").

42. Based on Djukic's representations, DA, BA and MT decided to retain Djukic.

43. On June 11, 2017, BA and MT attended Djukic's office where they paid him $15,000.00 CAD and were issued a receipt. Djukic and MT also signed a Retainer Agreement, which outlined that Djukic was retained to prepare, file and process an application for a Labour Market Impact Assessment ("LMIA"); obtain valid Work permits in Canada once the LMIA was obtained; and prepare and file an application for immigration to Canada under the Canadian Experience Class. Djukic and MT signed a Use of Representative Form, or an IMM 5476. MT never received confirmation from Immigration, Refugees and Citizenship Canada ("IRCC") that such form was filed.

44. Eight months passed by and there was no sign that Djukic was making progress on the application. On February 22, 2018, still not having received a work permit, MT and DA attended Djukic's office. MT and DA recorded the conversation with Djukic and a certified translated transcript was obtained by the ICCRC. During the conversation, Djukic made assurances that he was working on a temporary work permit for MT. Djukic promised them that he would refund them $12,457.50 CAD if he could not obtain a work permit for MT by April 1, 2018. Djukic also advised MT that he should work under the table for cash, contrary to the terms of MT's visitor visa.

45. Djukic confirmed that he was arranging a job for MT and that the chances of a successful application were good.

46. Djukic told DA that he would contact her at the end of March 2018 to let her know whether he was able to obtain a work permit for MT.

47. Between March 30 and May 9, 2018, DA and Djukic exchanged several text messages to attempt to schedule a meeting. Djukic repeatedly put off meeting, cancelling and rescheduling three times.

48. On May 22, 2018, Djukic wrote to DA that he could not meet with her but informed her that a "refund cheque has been mailed to your home address".

49. Contrary to Djukic's representation that he had sent a cheque by mail to DA, she never received a refund cheque from Djukic.

50. Djukic never provided DA with a refund of any fees paid, contrary to Djukic's promise that he would provide a refund of $12,457.50 CAD.

51. DA, BA and M never received any documentation from Djukic that confirmed that he submitted any application on M's behalf. There is no indication that Djukic did any work he agreed to do pursuant to the retainer agreement and the representations he made to DA. Yet he kept the $15,000.00 fees that were paid.