I do see it as fraudulent.
The license is being purchased under the guise that the land will be used for commercial hunting (that's what the license is for), but in fact the full intent is precisely the opposite - it is to prevent commercial hunting.
Perhaps not "fraud" in the legal sense because perhaps there are no rules about land use in the regulations of these licenses. Nevertheless it is certainly fraudulent. It seems that some rules need to be created/modified to prevent this from happening.
How about: If you aren't a legitimate guide outfitter then you don't get to buy the license for a guide territory. Hard to believe this isn't already in the books.
Furthermore, any guide outfitter should be required to submit a yearly report of the land use, just like people with mining claims do.
If you aren't using the land for the purpose of the license then you lose your license. No money back.
That would dampen down illegitimate license applications a bit.