Regulators in British Columbia found that a former notary committed fraud when she took in over $100 million in what amounted to a Ponzi scheme.

A hearing panel of the the B.C. Securities Commission (BCSC) found that between 2003 and January 2012, Rashida Samji ran a Ponzi scheme that took in over $100 million from at least 200 investors. The investors were told that the funds would be used to help secure financing for a winery, and that they would earn returns in exchange for the use of their funds.

However, the panel says that she has since admitted that none of the investors’ funds was ever used to invest in wineries or to help secure financing. Instead, it says that investors’ funds were used to pay interest to other investors.

“The evidence clearly establishes that Samji deceived the investors. The whole investment scheme was one big lie,” the panel said. “Instead, Samji used investors’ funds to pay other investors in order to keep the scheme going. She also used investors’ funds for her own purposes. It was a monumental deceit.”

The extent of investor losses from the scheme has not been determined at this point. The decision notes that an analysis by RBC in connection with civil proceedings in the case found that Samji took $110 million from over 200 investors and paid out $99 million. However, the respondents maintain that she took in $102 million, and paid out $98 million.

The panel concludes that the scheme took in at least $100 million, but it doesn’t attempt to determine how much was paid out, or retained for her own use. “All of the investors’ money Samji took she put at risk. The investment scheme was a sham. There were no fees from third parties to fund the promised returns,” it notes. “Moreover, as in all Ponzi schemes, it is certain that some investors will lose all of their investment. Many more may see some return of funds through the civil proceedings but the evidence shows that this group will also suffer significant losses. None will ever see the returns they were promised.”

The panel found that she perpetrated a fraud in connection with the Ponzi scheme, but it dismissed allegations that she also sold false mortgages to two investors. Penalties in the case have not been handed down yet. The BCSC will hold a further hearing to consider sanctions.