Caruso, The Placencia may have run afoul of Ontario securities laws

37. Caruso and the Caruso Companies traded in Canyon Securities with respect to projects in Belize during the Material Time either directly or through acts in furtherance of trading including the following:

1. attending information seminars regarding the Canyon Securities organized by the Canyon Entities in Ontario and elsewhere, as well as those organized by the HEIR Respondents;
2. engaging in meetings with potential investors in Ontario and elsewhere to promote the Canyon Securities;
3. using agents to solicit potential investors, including the HEIR Entities;
4. authorizing the Canyon Entities to highlight Caruso’s involvement as the projects’ developer in meetings, seminars and promotional materials and to provide investors with the investment contract documents; and/or
5. issuing Canyon Securities to investors.

38. During the Material Time, approximately 308 investors residing in Ontario invested at least $24.6 million in the Canyon Securities, of which $17.5 million concerned investment contracts with the Caruso Companies. The Canyon Respondents paid the HEIR Respondents approximately $875,500 in commissions or fees in regard to the purchases of the Canyon Securities.

39. In engaging in the conduct described above, and in circumstances where no exemptions from registration were available, the Canyon Respondents traded in securities and/or engaged in, or held themselves out as engaging in, the business of trading during the Material Time contrary to section 25(1) of the Act.

The above is related to developments on the northern end of the Placencia Peninsula – Copal Beach, The Placencia Hotel and Residences, Rendezvous Caye, the “international” airport, Panther Golf Course and the Placencia Marina.