[2019] NZIACDT 3, LL v Sun (Jianya Sun)

“Rubber stamping / allowing unlicensed people to manage visa application process / adviser had no direct contact with client in accordance with Chinese law / all communications made via local migration company / complaint client asked to sign blank application form, information supplied without her knowledge and signature forged / whether the company’s unlicensed staff performed immigration services / whether Chinese law qualifies adviser’s professional obligations / Code of Conduct 2014, cl1, cl2, cl3c / Immigration Advisers Licensing Act 2007, s442 / Chinese law restrictions irrelevant & obligations not qualified by them / unlikely staff did not provide immigration advice / staff’s work did not amount to clerical work / bulk of complainant’s instructions carried out by company / adviser did not know falsity of documents / mere filing of false documents does not, of itself, amount to lack of due care or diligence / adviser had no knowledge of staff’s conduct / complaint upheld.”