In their article “The Futility of Pretending to Certify Virtue,”  Liz Reisberg and Philip G. Altbach dangerously advocate for the abandonment of the very individuals they are so eager to protect. The growing number of students outside the U.S. seeking an American education must navigate a policy and protocol wilderness filled with obstacles and potentially treacherous paths. And yes, there are wolves lying in wait, intent on profiting from these students’ vulnerability.
However, the course of action being endorsed — the abandonment of commission-based compensation for third-party recruitment or any effort to bring ethical reform and accountability to the practice — is reckless. Neither the existence of recruitment agents nor students’ dependency on them outside the U.S. will end simply by having universities curtail what are legitimate activities. Rather, it will force recruitment underground, leaving students and their families even more vulnerable to exploitation.
As we all know, efforts at prohibition are usually exercises in futility.
But let’s step back a moment.
Over the last decade, the use of commission-based international student recruitment agencies by colleges and universities has become commonplace.  Agents are a fact of life, particularly in Asia, where most international students currently studying in the U.S. originate. Often struggling with limited knowledge of English (if any) and no familiarity with the American education system, these students and their families are confronted with a considerable financial investment with no road map to help guide their decision-making. Many are desperately in need of someone to help assist them with the many steps needed to successfully apply to and matriculate in a U.S. institution. U.S. government resources, such as EducationUSA, simply do not have the geographic reach, nor do they provide the range of services, that most students require.
Recognizing the need for professional standards, the American International Recruitment Council  (AIRC) stepped in to fill the breach. Conceived and created by U.S. accredited colleges and universities as a nonprofit Standard Development Organization, AIRC aims to address known deficiencies in the higher education marketplace through the adoption of ethical standards and enforceable certification of recruitment agencies.
AIRC member institutions (which total 135 as of June 2011) must be accredited by a U.S. Department of Education-recognized accrediting agency, and they range from community colleges to Ivy League institutions. What these institutions share is a deep commitment to the highest level of professional conduct on the part of the recruitment agencies with which they do business. AIRC has quickly established itself as a robust, internationally recognized NGO that has not only created consensus among practitioners on ethical practice and industry norms, but also made significant strides toward enforcing industry standards.
AIRC is to agents as regional accreditors are to colleges. Member agents pay a significant fee and expend considerable labor to qualify for certification. Afterward, agents must pay a membership fee and maintain ethical conduct to remain in good standing. A good number of agencies have initiated the AIRC process; not all will succeed. While it is rare, candidates have been rejected for certification. It is helpful to think of AIRC certification as akin to completion of a doctoral dissertation, where applicants must withstand several steps of review and external scrutiny. In most cases, the ones left standing at the conclusion of the process are certified as AIRC members.
Unfortunately, none of the AIRC’s efforts have stopped parties within the National Association for College Admission Counseling from proposing new language to its ethics standards  that would obligate member institutions to either abandon commission-based international student recruitment or else leave the association. Such an outright top-down prohibition attacks the cure rather than the disease, and is almost certain to result in disingenuous workarounds, rampant ethical violations, and disappointment for countless promising students.
Ironically, those most vociferous against using recruitment agencies — ostensibly out of concern over unethical practices — have been disengaged from regulatory processes already under way and have not offered any practical alternatives.
Enforceable professional standards — voluntarily developed from within an industry — have proven highly effective for improving consumer protection in a relatively short time across many industries, from manufacturing to securities to real estate. Americans invented and perfected these accreditation and certifications processes; this is an area where Americans have a global competitive advantage that should be leveraged.
Not coincidentally, Chancellor Nancy L. Zimpher of the State University of New York (SUNY) in June 2010 signed a letter of commitment to the United Nations Global Compact (UNGC). First announced by UN Secretary-General Kofi Annan at the World Economic Forum in 1999, and officially launched in 2000, the Global Compact is the world’s largest global corporate citizenship initiative and is designed to foster a new normative consensus around global business practice and ethics.
Since committing, SUNY has led the Global Compact Academic Working Group, which is composed of higher education institutions from six continents charged with developing a global framework for adopting the UNGC principles to higher education.
Why is SUNY doing this? Because we know that public universities have always played an important role in putting ethics into practice. In this same spirit, SUNY is committed to developing an international student recruitment network of ethical independent professional counseling agencies. We will do this in a transparent way, guided by professional standards developed by the AIRC.
Ultimately, it is SUNY’s responsibility to monitor our agents’ activities, seek feedback from recruited students, and correct problems as they occur. It is SUNY’s responsibility to discontinue working with agents that do not meet the standards of conduct to which we ourselves have committed. It is not NACAC’s responsibility to police SUNY’s relationships. NACAC may ultimately advocate walking away from corporate social responsibility, but SUNY takes its principles and responsibilities seriously.
Mitch Leventhal is vice chancellor for global affairs at the State University of New York, senior adviser on academic affairs to the United Nations Global Compact, and co-founder of the American International Recruitment Council.