The Immigration and Refugee Protection Act prohibits anyone who isn't licensed from providing paid legal services in the immigration context. The law already has in place provisions that would ensure that people who are acting as ghost consultants could be brought to prosecution, so it's really a question of enforcement.
The enforcement can be done. The ICCRC has no power to enforce, so it has to be done either by the RCMP or by the CBSA. I believe the CBSA now has a unit that engages in prosecutions. My experience is that the types of issues that arise for those consultants, unless they are on a massive scale, are not the type that would generally be of interest to the RCMP.
If we're going to try to have more effective enforcement regarding ghost consultants, it's going to have to be done by the CBSA and I think the government is going to have to dedicate funds to that specific problem to ensure that sufficient attention is paid to prosecute those who act as ghost consultants.