On March 30, the Québec Financial Markets Tribunal (the QFMT) delivered its ruling on the merits of Autorité des marchés financiers c. Solo international inc.,[1] a case involving a pump-and-dump scheme whose proceedings date back to 2017. The QFMT granted the AMF’s application and issued various orders in response to violations of sections 195.2 and 199.1 of the Québec Securities Act (the Act).
Although the QFMT found that there was compelling and preponderant evidence to establish that the alleged violations had been committed, and dozens of paragraphs meticulously detailed the various phases of the scheme, the QFMT provided no explanation of the distinctions between the offences outlined in sections 195.2 and 199.1 of the Act, leaving readers uncertain as to whether the constituent elements of these offences differ. Furthermore, the QFMT did not specify which particular acts contravened sections 195.2 and 199.1 of the Act, instead taking the position that the entire sequence of events, taken together, amounted to the violations in question.
Moreover, while the QFMT set out the facts relating to the pump-and-dump scheme in detail, the decision contains relatively little analysis justifying the administrative penalties imposed. It simply stated that the AMF’s requested penalties were “reasonable” given the seriousness of the violations and the harmful nature of the transnational pump-and-dump scheme, without offering precedent or a comparative basis.
For an in-depth analysis of the tribunal’s decision, read the full Update by Osler’s Fabrice Benoît and Alexandra Romcea.
[1] Autorité des marchés financiers c. Solo international inc., 2026 QCTMF 24.
