the position that the violator held and other like factors are
much more important considerations.
 Azeff and Bobrow also complain about the ten-year
registration ban that was imposed upon them. While they
acknowledge that such bans “are generally found to be appropriate in insider trading/tipping cases”, they submit that they were
not appropriate in this case. The principal reason advanced for
this submission is that, in the years since the allegations arose,
Azeff and Bobrow had continued to participate in the market,
albeit under strict supervision, without any further violations.
 The Panel considered that submission and rejected it.
The Panel found that permitting Azeff and Bobrow to continue
working in the market would fail to provide sufficient protection
to all other market participants. Specifically, the Panel said, at
Continued registration for Azeff and Bobrow, even under strict supervi-
sion, does not provide a sufficient shield to the market. It would leave Azeff
and Bobrow, as registrants, in the milieu where financings and takeover
bids are regularly discussed. We have no confidence that Azeff and Bobrow
would resist temptation any more in the future than they did in the
past. Supervision, while laudable, does not cover the whole day. Tipping can
occur by various, difficult-to-detect, means and may not always occur at the
 That was an entirely reasonable conclusion for the Panel
to reach in the circumstances. It is not for this court to second
guess that conclusion, or to substitute our opinion for that of
 Azeff and Bobrow do not directly challenge the costs
awards made against them. However, insofar as they may indirectly challenge those costs awards, my observations and conclusion, regarding the issue of costs as they relate to Finkelstein,
apply equally to Azeff and Bobrow.
( iii) Miller
 Miller was found to have violated the Act on three occasions. He was ordered to pay an administrative penalty of
$450,000 and costs of $50,000. He was also ordered to disgorge
the profits that he made.
 Miller’s sole submission regarding the sanctions imposed
on him is to repeat the arguments made by Azeff and Bobrow
regarding the multiplier of profits approach to setting administrative penalties. I will not repeat what I have just said in
rejecting that approach as being determinative of the appropriate penalty.