It does seem low, but my sense is that the real problem is not going to be how significant the punishment is but how easy is it going to be to secure convictions. I think it is highly unlikely that most immigrants and refugee claimants who suffer mistreatment by immigration consultants are actually going to report that mistreatment. So I think there are other more serious challenges with this strategy.
On October 20th, 2010. See this statement in context.