The British Columbia Securities Commission (BCSC) issued allegations that Shimshon Refoel (Shimmy) Posen, an Ontario-based securities lawyer, directed a wash trade in January 2024 to artificially lower the share price of a B.C.-based company listed on the Canadian Securities Exchange (CSE). The company sought to sell 10 million shares in a private placement at CAD 0.03 per share, but CSE rules require placements priced below CAD 0.05 to be no lower than the issuer’s 20-day volume-weighted adjusted price (VWAP), which was CAD 0.078 at the time. The BCSC alleges Posen placed an order to buy 50,000 shares at CAD 0.005 in an online account in his name, then directed a matching sell order at the same price through a registered representative in an account held by a holding company owned by his wife, over which he had trading authority. A few days later, his law firm informed the CSE that the company’s 20-day VWAP was below CAD 0.03, after which the CSE approved the private placement at CAD 0.03. The BCSC alleges this conduct breached British Columbia’s Securities Act by creating a misleading appearance of trading activity and an artificial share price. The allegations have not been proven. Posen or his counsel must appear at the BCSC’s offices on May 6, 2025 if he wants to be heard before a hearing is scheduled.

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