There are only two conditions for entrapment - government inducement of the crime, and the defendant's lack of predisposition to engage in the criminal conduct. [1] And I think this qualifies on both counts. The students were looking to get into the US, but the government pushed this visa mill on them indirectly, via the brokers (who wouldn't have had a dual-accredited fake university to pitch without the government's aid). Had these brokers not reached out to these students, it's unlikely that they would have sought out the same illegal method to enter the country. (This is assuming the brokers reached out the students, and not the other way round).
[1] https://www.justice.gov/usam/criminal-resource-manual-645-en...