when refusing the request for an adjournment, and what the
Panel did in this case. In particular, in this case, the Panel
treated the issue seriously; it weighed the pros and cons of the
request; and it did not act arbitrarily.
 I see no merit in the suggestion by Azeff and Bobrow that
they were denied procedural fairness and natural justice arising
from the manner in which the Panel dealt with this issue.
 I turn now to the submissions of the appellants that the
sanctions imposed by the Panel were unprecedented and exces-
sive. I will deal with each of the appellants in turn, although it is
unnecessary to deal with Cheng on this issue. Since the decision
on the merits respecting Cheng has been set aside, the sanctions
decision falls with it.
 Before dealing with each of the appellants, however, it
will be helpful to set out the general principles that underlie the
imposition of sanctions regarding conduct that violates the Act.
In that regard, the purpose of the Act bears repeating. It is set
out in s. 1.1, that reads:
1.1 The purposes of this Act are,
(a) to provide protection to investors from unfair, improper or fraudu-
lent practices; and
(b) to foster fair and efficient capital markets and confidence in capi-
 In pursuing that purpose, the respondent must “consider
the protection of investors and the efficiency of, and public confidence in, capital markets generally”: Committee for the Equal
Treatment of Asbestos Minority Shareholders v. Ontario (
Securities Commission),  2 S.C.R. 132,  S.C.J. No. 38,
at para. 45.
( i) Finkelstein
 Finkelstein was found to have contravened s. 76 of the
Act by tipping on three occasions. The Panel levied an administrative penalty of $450,000 (or $150,000 per violation) and
ordered Finkelstein to pay $125,000 in costs.
 Finkelstein says that the sanctions are excessive. He
points to the fact that he did not personally profit from any of
the tipping. He also says that a penalty of $150,000 per violation
greatly exceeds the penalties in other cases. On this latter point,
Finkelstein points to the decision in Agueci (Re) (2015), 38 OSCB
5995, where a penalty of $25,000 per violation was imposed.