In September 17, 2008, an IIROC Hearing Panel found that Dax Sukhraj, owner and sole board member of Argosy Securities Inc., engaged in business conduct or practice unbecoming and detrimental to the public interest. The conduct in question was his failure, contrary to Association By-laws 29.1 and 38, to ensure that Argosy fulfilled representations to the IDA that it would develop and implement policies and procedures to ensure compliance with regulatory requirements.

Although the Panel found that his conduct had been neither unethical nor in bad faith, his failure to cure numerous deficiencies was described as grossly negligent warranting significant sanctions.

On December 31, 2008, the Hearing Panel imposed a fine of $150,000 inclusive of costs on Dax Sukhraj. In addition, the Panel demanded that Dax Sukhraj complete the Chief Compliance Officers Qualifying Examination no later than April 1, 2009 and that a compliance consultant approved by IIROC be put in place to remain at Argosy Securities Inc. for a period of one year to conduct regular evaluations of Argosy’s compliance systems.