A hearing panel of the Investment Dealers Association of Canada (IDA), has found Jean-Louis Trudeau, at the material time, an approved person at the Montreal head office of MacDougall, MacDougall & MacTier Inc., guilty of failing to act as a gatekeeper.

In a written decision dated Dec. 12, 2006, the panel ruled that during the period between February 2003 and May 2004, Trudeau failed to use due diligence to ensure that the acceptance of orders for the accounts of four clients were within the bounds of good business practice. Specifically, Trudeau failed in his role to protect the public interest by executing trades that were indicative of unlawful or suspicious behaviour without making any prior effort to determine whether insider trading or the use of privileged information was involved.

The panel has also found Trudeau guilty of failing to use due diligence to ensure that he learned the essential facts relative to four clients, and to every order or account accepted. During the period between June 2001 and May 2004, while an approved [erson at Thomson, Kernaghan & Co. Limited, and MacDougall, MacDougall & MacTier Inc., Trudeau neglected to identify the clients in accordance with IDA guidelines relative to the proceeds of crime (money laundering) legislation and failed to communicate with his clients to obtain the necessary information regarding their identity, their assets and the ties that connected them.

The [anel found Trudeau not guilty of failing to question his client or verify his status as an insider. In addition, at the request of the IDA, the panel accepted the withdrawal of the charge that Trudeau had neglected to report in writing to the IDA within the prescribed 10 day period, and on multiple occasions failed to report on various forms that he had been charged by the Montreal Exchange.

The penalties imposed against Trudeau will be determined at a penalty hearing to be set at a future date.

For a complete summary of facts, please see IDA Bulletin 3600.