Amaya: The largest insider trading investigation in Canadian history

Share

It was a routine day of logging stock trades and selling mutual funds. And then the police arrived.

Nearly a dozen officials from the Sûreté du Québec, Royal Canadian Mounted Police and the province's securities regulator pushed into the Montreal branch of Manulife Securities on the morning of Dec. 10, 2014.

Waving a search warrant, investigators identified more than a dozen startled employees and ordered them away from desks while police yanked power plugs and tagged, bagged and carried off computers and other equipment to waiting police vehicles in the west Montreal suburb of Dorval.

That same day, officers visited a squat stone building two kilometres away with a warrant seeking materials from the headquarters of Amaya Inc., owner of the world's largest online poker company. A third warrant was served at the Montreal branch of Amaya's investment banker, Canaccord Genuity Securities.

In the following weeks, a Globe and Mail investigation revealed that 20 people found themselves involved in what has become Canada's largest insider trading case. Quebec's securities regulator, the Autorité des marchés financiers (AMF), according to sources, is investigating two top executives and a mid-level manager at Amaya; a senior Canaccord executive and a top broker; and Manulife's most successful Dorval broker along with 14 other branch employees, whose names are unknown.

The AMF is the primary regulator in the case because Amaya, the publicly listed company whose stock is at the heart of the trading investigation, is based in Montreal. Amaya confirmed last week that its chief executive officer David Baazov and chief financial officer Daniel Sebag are under investigation by the AMF and the company said it has found no evidence of wrongdoing after an internal probe. At Canaccord, a spokesman said the firm has found no sign of misconduct after a review. A spokesman for Manulife said the company is co-operating with regulators and is obligated to notify authorities about unusual trading activities. Manulife provided the AMF with an internal report on the trading activities of its Montreal employees after the PokerStars deal was announced.

The AMF is the lead investigator in a sprawling international investigation that has so far involved the RCMP, the Ontario Securities Commission, and U.S. and British securities regulators. None of these authorities have made any allegations of wrongdoing. The core question in the case is why so many investors bet on a minnow-sized online gambling company months before news broke about its improbable $4.9-billion (U.S.) takeover last summer of online betting whale PokerStars.

Trading in Amaya's stock was so frenzied in the weeks before the deal was announced that a few industry bloggers and research analysts foretold its arrival. Some brokers were so certain the deal was imminent they sent e-mails to fund managers urging them to buy a stock destined to be transformed by a PokerStars acquisition.

Co-ordinating an investigation that involves so many targets, stock trades and investors in different jurisdictions will test the limits of a fragmented provincial securities regulatory system with a poor record of policing suspicious price runups in Canadian stocks ahead of deal news. The AMF, which has limited experience with insider trading cases, is as much under the spotlight to demonstrate its investigative skills as are its targets to provide their perspective on the PokerStars takeover.

"This will be a closely watched case," said Kelley McKinnon, a securities lawyer and former deputy director of enforcement with the OSC.

"Insider trading cases are so challenging to investigate and prosecute. Evidence of suspicious trading is not enough. You need compelling and credible evidence to prosecute a case."

Unidentified whistle-blowers

Amaya was financially stretched when it set its sights on PokerStars in December, 2013. The company reported a loss of $29-million (Canadian) on sales of $155-million for the 2013 year ended Dec. 31, its third consecutive year of losses. Cash was so tight that it reported negative operating working capital in 2013 and 2012.

After rising to $8.99 a share in early 2014, Amaya's stock slumped to $5.81 in mid-April, following a disappointing earnings report. Two weeks later, the stock was on a tear, nearly tripling in value in heavy trading to $14.08 a share in the next two months before the PokerStars takeover was revealed on June 12. During that period, trading volumes in Amaya's stock soared to an average 750,000 shares daily, more than double volume levels in the previous four months. A day after the acquisition was announced, the stock closed at $20 on the TSX and continued to rise until it peaked at a high of $38.74 in late November.

The AMF, aided by two unidentified whistle-blowers, alleges that tips about the company's confidential takeover talks helped stoke the buying frenzy in Amaya's stock.

"The investigation reveals that certain individuals in possession of privileged information transmitted that information to several people. These people then took advantage of that information and traded on Amaya shares," the AMF said in a December affidavit filed in a Quebec court.

In addition to Amaya's Mr. Baazov and Mr. Sebag, the AMF has targeted another unnamed employee at the company, according to a redacted copy of its search warrant. At Canaccord, sources said, regulators are investigating trading in Amaya's stock by two prominent officials, Stuart Raftus, CEO of the Bay Street firm's wealth management unit, and Peter Kirby, a top broker who has been bullish about the gambling company for years.

In response to questions from The Globe about Mr. Raftus and Mr. Kirby, Canaccord said in an e-mail: "We have conducted an internal investigation and remain confident that all of the employees of Canaccord Genuity have acted in good faith and with high integrity."

At Manulife, the AMF is examining a close-knit group in the Dorval branch of 15 employees, most of whom are brokers. According to one person familiar with the investigation, one of the targets is the branch's most successful broker Thierry Jabbour, who joined Manulife in 2007, when the Dorval branch was acquired from Berkshire-TWC Financial Group. After Mr. Jabbour's assistant was contacted by The Globe and Mail at Manulife's Dorval branch, a spokesman for the company responded by saying he is not available to comment.

Also under scrutiny are scores of Canadian and international investors who so actively traded Amaya's stock that alerts were triggered by market surveillance software at the Financial Industry Regulatory Authority (FINRA), Wall Street's self-regulator.

FINRA routinely produces lists of investors who trade in publicly listed company shares ahead of major news. The lists, which do not signal an investigation or imply any wrongdoing, are circulated to companies, bankers and advisers involved in transactions to ascertain whether those who traded Amaya's stock had connections to corporate insiders, bankers or advisers.

The regulator's algorithms identified more than 300 active Amaya investors ahead of the takeover, a number that greatly exceeds the few dozen shareholders typically identified by FINRA when tracking Canadian stocks.

According to sources familiar with FINRA's list, it includes a broad array of big and small investors who flocked to a stock regarded as so speculative that research analysts at Canada's top six bank-owned securities firms do not follow it to this day. Listed are more than a dozen Bay Street funds, including the manager of the country's biggest pension fund, the Canadian Pension Plan Investment Board, and a number of fund executives and portfolio managers. Outside Canada, the list cites such exotic investors as a trio of Lebanese banks and former top tennis pro Andy Roddick, whose San Diego-based financial adviser said he bought the shares on his behalf, without his knowledge.

Three investors identified by FINRA are friends and business associates of Amaya's CEO, Mr. Baazov. Also named are Canaccord's head of trading, Darren Hunter, and the father of Graham Saunders, its co-head of sales. Another investor on the list is the father of Mr. Kirby, the Canaccord broker under investigation by the AMF. Others include a former public relations adviser and director at Intertain Group, an online gambling company that was created early last year to hold some of Amaya's discarded online gambling assets.

Each of these investors or their spokespersons were contacted by The Globe. Of those contacted, four did not respond to requests for comment and two declined to comment. Spokespersons for the remainder, including Mr. Saunders and Mr. Hunter, said there is no evidence that the trades were based on confidential deal information.

A number of investors reached by The Globe said they bought Amaya stock in the months and weeks before the PokerStars deal because the stock was gaining momentum as an emerging player in the rapidly expanding online gambling business.

Harry Carmichael, who along with his business partner Roger Rowan and their Toronto investment management firm Watt Carmichael Inc., are among those cited by FINRA, said the firm traded in the stock, but not significantly.

"Amaya was a heavily traded stock all over the Street. It was a go, go stock," Mr. Carmichael said.

The Baazov family history

The road to Amaya begins in Gori, a tiny city in central Georgia made famous as the birthplace of Joseph Stalin. The mountainous city also is known for its bloody history of political and religious clashes. After the Second World War, it was Gori's tightly knit community of Orthodox Jews who were hounded by police and forced to shutter synagogues.

Thousands of Jewish families opted to leave Gori for a new life in Israel in the late 1960s and early 1970s. Joining the exodus were Joseph Baazov, Sara Elishakov and their young son Ofer. The family's first stop was Haifa, Israel, where a daughter Goulissa and three other sons, Amnon, Eli and David were born.

Shortly after their youngest son David was born in Haifa in 1980, the family was on the move again, this time to Canada. As David Baazov would later tell reporters and associates, his parents arrived in Montreal with so little money they depended on support from friends in the orthodox community for housing and food. By the early 1990s, Joseph, a construction worker and electrician, had enough money to buy a modest split-level home to accommodate a family that had grown to six children after the birth of Rina, a daughter.

The new home was located on Place des Fleurs, part of a small working-class enclave in Dollard-des-Ormeaux, just blocks from what was then called Montreal-Dorval International Airport. Joseph had enough confidence in his profession as an electrician to federally incorporate a company called Kazbek International Inc., which shares the same name as one of Georgia's highest mountains.

There are no mountains in Dorval. But for the Baazovs, life in the new country was rocky.

In 1993, Montreal police charged the family's oldest son Ofer, then 24, with seven counts of cocaine possession. He was convicted on four of the counts in 1995 and, according to Quebec court records, sentenced to 90 days in prison.

Ofer Baazov ran into more trouble with authorities when a telemarketing firm, registered in his name at the address of the family home on Place des Fleurs, attracted the attention of the Washington-based Federal Trade Commission (FTC). In 1996, the FTC announced it had taken enforcement actions against 80 defendants in an operation called "Project Jackpot" to thwart phony prize promotion telemarketing schemes. Included in the roundup was Ofer Baazov's company and a few other related ventures that the FTC said "deceptively" lured senior citizens in the American Midwest into buying hundreds of thousands of dollars worth of merchandise with the false promise of valuable prizes.

The FTC named Ofer Baazov and Joshua Baazov as the owners of the Montreal companies and in 1997 a judge with the United States District Court for the Northern District of Ohio ordered the two men to pay $777,000 (U.S.) in restitution payments through the court to victims of their scam. When contacted by The Globe, a spokeswoman for the court said there is no record of the restitution payments, which she said means "nothing was paid" to the court or the victims. It appears that the FTC was not aware that Ofer and Joshua are the same person. Business associates interviewed by The Globe said Ofer Baazov has referred to himself as Joshua or Josh for many years.

Ofer (Josh) Baazov, who lives outside Canada according to sources, did not respond to written questions from The Globe.

Another Baazov brother struggled in business. David Baazov is a college dropout who has told reporters that he was kicked out of the family home after he broke from his parents' orthodox faith. In an interview with Montreal's business weekly, Les Affaires, he said he survived at first by selling books of discount coupons with his childhood friend Benjamin Ahdoot.

Mr. Baazov and Mr. Ahdoot shifted their business interests to the technology sector in the late 1990s, selling computers, compact audio discs and other accessories to end users and retail outlets. Their business, Vortek Systems, attracted the attention of the Canadian Copyright Collective in early 2003. According to court documents, the collective notified Vortek in a letter that it was obligated by law to charge copying levies for every audio disc it sold to comply with a new copyright regime designed to compensate musicians for illegal music downloads.

Mr. Baazov and Mr. Ahdoot initially denied importing blank discs and later challenged the constitutionality of the levies, according to an agreed statement of facts cited in a court order. After three years of legal skirmishes, a lawsuit by the Copyright Collective against Mr. Baazov, Mr. Ahdoot and their company landed in a federal court trial before Justice Konrad von Finckenstein. The judge ruled in 2006 that Vortek's delayed levy payments were "inexcusable" and ordered the company to pay a $900,000 (Canadian) penalty in addition to unpaid copying levies of $1.7-million. He dismissed a move by the Copyright Collective to hold the two men personally liable for their company's debts on the grounds there was no evidence of bad faith.

Two months after the decision, Vortek filed for bankruptcy in May, 2006. Stéphane Lachance, a partner with the Montreal accounting firm Demers Beaulne, was appointed trustee of the bankrupt company. In an interview, Mr. Lachance said Vortek was liquidated with insufficient assets to pay the court-ordered penalty and levies.

After Vortek's collapse, Mr. Baazov diversified. The vehicle for his new enterprise was a numbered company, 9138-5666 Quebec Inc., which began as a spray tanning business called Celebrity Tan. The only shareholder named in the company's initial 2004 incorporation record is Craig Levett, a Montreal businessman who, according to corporate registration documents, has incorporated a number of Quebec and federal companies with David Baazov's older brother Josh.

David Baazov first appeared in Celebrity Tan registration documents in September, 2005, alongside Mr. Levett as one of only three shareholders in the business. The other shareholder was Albert Jann, who identifies himself on his LinkedIn page as a Montreal-based software and game developer. One of his LinkedIn posts said he worked at Amaya from 2004 to 2006 "with David and Josh Baazov founder of Amaya Gaming." Shortly after The Globe began questioning Amaya about Josh Baazov's history with Amaya, the older Baazov brother's name was removed from Mr. Jann's LinkedIn page.

In an e-mail response to questions from The Globe, Mr. Jann confirmed he worked with David Baazov at Amaya's predecessor company, Gametronix. He did not respond to questions about Josh Baazov's role at the company. Mr. Levett did not respond to requests for interviews.

By May, 2007, Mr. Levett was no longer cited as a shareholder in registration documents for Celebrity Tan, by then renamed Gametronix Systems. Six months later, the company pivoted again, this time to pursue the rapidly expanding world of gambling under the new name Amaya Gaming Inc.

According to two gambling industry veterans who agreed to speak on condition of anonymity, Josh Baazov presented himself during meetings and phone calls in the mid- and late-2000s as a foreign-based casino operator seeking advice and investments for a Canadian gambling venture.

In a meeting and subsequent discussions between 2005 and 2006, Josh Baazov met with a Canadian casino official to seek advice about how to supply electronic gambling equipment to licensed casinos. The product Mr. Baazov was promoting was an electronic poker table eventually called PokerMate, which Amaya later described in 2010 regulatory documents as the company's proprietary product.

Another businessman said he was invited by Josh Baazov to Montreal and had several subsequent phone calls in the late 2000s to review a possible investment in Amaya. At the meeting, Mr. Baazov described himself as someone with a difficult past who found strength in his family's orthodox faith. He told his visitor about plans to work with his younger brother David to make a big bet on online gambling by raising money through an initial public offering. The investor opted against financing Amaya.

In response to questions from The Globe, Amaya said "neither Josh Baazov or Craig Levett was involved in the launch or financing of Amaya." David Baazov, the company said, purchased an existing company from Mr. Levett "so that the corporation would have an operating history." Josh Baazov, the company said, "has never been an Amaya employee and to the best of the company's knowledge, is not, and never has been, an Amaya shareholder."

Josh Baazov was later linked with Amaya in March, 2011, when Chile's Superintendent of Casinos published a notice on its website that its senior officials met with two "representatives" from Amaya. Josh Baazov and Robert Dumitru are identified as the Amaya reps who, according to the website, gave a presentation about gambling products and services developed by the Montreal company.

Amaya said Josh Baazov and Mr. Dumitru "did not speak with anyone in Chile as Amaya representatives." The company said Josh Baazov was proposing a transaction as "a third-party company" seeking to supply the possible sale of a slot gambling system with Amaya machines.

The rise of Internet gambling

David Baazov was appointed Amaya's CEO in 2006 at the age of 25. He was then and is currently listed in regulatory filings as the company's largest shareholder.

Under Mr. Baazov, Amaya ventured into gambling at a time the business was exploding. Casinos, arcades and online gambling sites generated more than $500-billion (U.S.) in global revenues last year, up 40 per cent from $360-billion in 2007, according to Global Betting and Gaming Consultants. The fastest-growing segment is Internet gambling, with online revenues quadrupling in the past decade to $37-billion in 2014, according to consultants H2 Gambling Capital. Today, hundreds of millions of people turn to their computers, tablets and smartphones to place bets on poker, sports and other gambling websites. All of this at time when many big countries, including the United States, Japan and Canada, ban or heavily restrict online gambling.

Since 2006, the United States has banned anyone from accepting payments for illegal online gambling (three U.S. states, Nevada, New Jersey and Delaware, recently allowed online gambling sites under restricted conditions). The U.S. Department of Justice further cracked down on illegal Internet betting when it charged 11 online gambling executives in 2011 with fraudulently disguising billions of dollars of illegal online bets by U.S. residents. The Justice Department also seized the U.S. Internet addresses of three of the world's largest gambling websites, PokerStars, Full Tilt and Cereus.

Online gambling in Canada is restricted under the criminal code to agencies controlled by provincial governments. Although Internet betting sites cannot be controlled by non-government entities, companies can incorporate their business here provided online betting services are conducted in jurisdictions where the gambling is legal. Typically, companies meet this test by locating their computer servers and payments systems in gambling-friendly jurisdictions.

Initially, Amaya was too small to compete in the online market because it lacked the financial heft to buy expensive high-speed broadband links, servers and electronic payment systems needed to connect Internet gamblers. Amaya instead positioned itself as an online alternative by selling or leasing gambling software, electronic tables and mobile devices to resorts, casinos and cruise ships that connected guests to poker and other games on local networks.

The strategy saw the company grow from less than $1-million (Canadian) in revenue in 2007 to nearly $6-million by 2009 thanks to sales in a handful of gambling jurisdictions including Kenya, Romania and the Netherlands.

Amaya's fortunes changed in 2010 when Canaccord Genuity and Desjardins Securities agreed to underwrite a life-saving initial public stock offering for a company with only 28 employees and a small library of 19 proprietary betting games. The company's financial health was so precarious that, according to regulatory filings, it had fallen behind scheduled payments on one bank loan, while coping with a 14-per-cent interest rate on another debt.

Despite its frail condition, Amaya's bankers successfully raised $5-million by selling its stock at $1 a share to list on the TSX Venture Exchange. The new money, and a series of subsequent stock issues led by Canaccord, fed Amaya's ambitions. Within three years of the IPO, the start-up and its youthful CEO had shifted the company from a fringe player to an ambitious industry deal maker, acquiring software and gambling machine makers such as Chartwell Technology Inc., CryptoLogic Ltd. and Cadillac Jack.

While Mr. Baazov did not lack for ambition, his company sometimes ran short of cash to back his bets. Amaya's 2012 bid to purchase gambling software and service provider Cryptologic nearly unravelled because of insufficient financial backing. The deal was rescued by Toronto stock promoter and financier Yoel Altman, who stepped up with a $5-million bridge loan to help close the deal. Mr. Baazov relied on the financier for subsequent deals, but Amaya said he did not serve as an adviser on the PokerStars takeover.

In the eyes of some Bay Street firms, Mr. Baazov was a gifted deal maker.

"We believe that Amaya is on the cusp of a transformation after a flurry of acquisitions supporting strong growth in 2013 and 2014," a Canaccord analyst gushed in a glowing 2013 research report.

The enthusiasm partly reflected an emerging optimism in gambling circles that the United States might move to legalize online betting to tap into the rich vein of taxes generated by the booming business. The company poised to take the greatest advantage of the potential opening was PokerStars, the world's largest online poker site.

As Mr. Baazov would later tell reporters, it was his idea to make an audacious play for PokersStars. The Isle of Man poker giant had been seeking a New Jersey casino licence to take advantage of a 2013 state law allowing casinos to also offer online gambling. The problem with the PokerStars strategy was that the company's founder, Isai Scheinberg, was among those indicted by the U.S. Justice Department in 2011 for allegedly running an illegal gambling business via deceptive online payment sites. These charges have yet to be resolved.

In December, 2013, according to Amaya regulatory filings, David Baazov flew to the Isle of Man with a financially fanciful proposal. A company with only $155-million of annual revenue, three years of consecutive losses and scarce operating cash flow had a pitch to acquire a poker site powerhouse with more than $1-billion (U.S.) in revenue and $417-million in profit.

"I was quite persistent," Mr. Baazov would later tell Forbes Magazine. "This was a really, really big-stakes game."

Takeover rumours start to spread

The compliance team at Manulife's Dorval branch first noticed unusual trading in Amaya's stock in February, 2014. Securities firms regularly track stock bets by brokers and employees to track potentially improper trades in stocks that are restricted because the firm's advisers or bankers may have access to confidential, market-moving information. In February, the compliance team noticed a number of the branch's brokers were placing big bets on the Montreal gambling company.

According to sources, Manulife officials interviewed a handful of Dorval brokers who expressed enthusiasm for Amaya's rapidly growing business. Amaya was not a Manulife client, the sources said, so there was no initial concern about the activity.

At the time that Manulife's compliance team was asking questions, Amaya was two months into negotiations to acquire PokerStars and its parent Rational Group Ltd. from the Scheinberg family since early January. According to Amaya's regulatory filing, talks with the Scheinbergs were so advanced that some of the Montreal company's legal advisers had completed their due diligence, opening the way for serious deal negotiations in April.

Amaya was a wallflower stock in the early months of 2014. After disappointing quarterly results, the stock slipped to $5.81 (Canadian) a share on the TSX Venture Exchange in April.

By May, Amaya's stock was on fire. From a low of $6.95 in the first days of May, its stock price soared to more than $10.25 by May 25.

Behind the scenes, a proposed deal that Amaya officials would later say was so shaky it looked "dead" on numerous occasions began to look plausible. The turning point was financial backing from one of Wall Street's most respected financial players. According to Amaya regulatory filings, the credit division of one of Wall Street's biggest investment companies, Blackstone Group, had signalled in May its interest in financing a major portion of the planned PokerStars acquisition.

Shortly after Blackstone's credit division, GSO Capital, gave its nod to the financing, Amaya's bankers, led by Canaccord, according to numerous sources, began entering confidential discussions in mid-May with a number of fund managers to gauge their potential interest in buying securities and debt to finance a heavily levered $4.9-billion (U.S.) takeover that was financed almost entirely through the sale of new equity and debt.

Fund managers who "go over the wall" to discuss details of potential deal investments are required to sign documents confirming they will not disclose confidential details. Amaya's bid called for so many billions of dollars of debt and equity investments that the company's bankers, sources said, were forced to cast a wide net to find enough investors comfortable with higher-risk securities.

The more fund managers that were approached, the greater the risks of a potential leak. By mid-May, Amaya's stock price and trading volumes were climbing.

The only meaningful news from the company during that time was the announcement on May 15 that Amaya had landed a new credit line for $300-million (Canadian) that included the right for lenders to buy steeply priced company warrants. Near the end of the month, speculation was so rampant that analysts and industry blog writers were predicting that a significant acquisition was in the works at Amaya.

Blog writers and analysts were not the only people banging the takeover drums. A handful of fund managers contacted by The Globe said they were swamped with calls and e-mails from brokers and officials at small Toronto brokerage firms with news of the pending deal.

One Toronto hedge fund executive received an early morning e-mail on May 26 from an official at a small brokerage with the subject line: "PokerStars and Amaya Gaming Talking Acquisition." By the lunchtime, the hedge fund executive had received so many phone calls that he fired off an e-mail to his lawyer.

"I am getting inundated with calls today about the merger between Amaya and PokerStars. … This is getting ridiculous. How does one call the OSC and get them involved?"

Trading in Amaya's stock was so heavy that day that the company was prompted by market regulators to issue a statement. The company's said it regularly reviewed acquisitions, but there was "no assurance" a transaction was imminent.

Late on the evening of June 12, Amaya announced one of the worst-kept takeover secrets of the year. The small company from Montreal had landed a definitive agreement to acquire Rational Group, and its PokerStars and Full Tilt online poker brands for $4.9-billion (U.S.) to create the world's largest publicly traded online gambling business.

In the coming weeks and months, David Baazov, the 33-year-old college dropout from West Montreal, was celebrated by international media as the brash new "Prince" and "King" of online gambling.

Not everyone, however, cheered Amaya's big win.

Four days after the company announced the PokerStars deal, Bay Street's self-regulator, the Investment Industry Regulatory Organization of Canada (IIROC), received an anonymous letter. According to an AMF warrant, the letter alleged that insider trading had occurred in the company's stock. Three days later, an anonymous whistle-blower made a similar alert to IIROC's counterpart in Quebec.

By the end of June, the AMF quietly issued an investigation order targeting 10 unnamed individuals for possible improper stock trading. Within a few weeks, undercover investigators were following suspects from Manulife's Dorval branch and other unidentified individuals to local bars and homes.

On one surveillance trip, investigators followed an unnamed individual from a home in the West Montreal suburb of Pointe-Claire to the parking lot of Amaya's head office.

It has been almost a year since AMF investigators found themselves in Amaya's parking lot. The regulator has issued no allegations and each of the three companies targeted in the probe has completed internal investigations. Spokespersons for Canaccord and Amaya say their companies have found no evidence of improper conduct by employees whose actions or personal stock trades have drawn the attention of the AMF or FINRA. A spokesman for Manulife said the company provided the AMF with a comprehensive so-called gatekeeper's report on the trading activities of its targeted brokers and other staffers. All but two of the employees continue to work at the branch.

Amaya is a much-changed company since the PokerStars acquisition. It has sold or announced plans to spin off the major divisions, Cadillac Jack, Cryptologic and Chartwell, that David Baazov guided the company to acquire in recent years. The company has beefed up its small executive team with senior executives from PokerStars.

Throughout all these changes and regulatory challenges Amaya's stock has been as unflappable as a champion poker player. News of the AMF search warrants and the regulator's targeting of Mr. Baazov and Mr. Sebag sparked brief selloffs affecting the company's share price. After each blow, the stock recovered.

Today, the stock is co-listed in Canada and New York's Nasdaq market and, as of Friday's close, traded at more than $32 a share (Canadian) on the Toronto Stock Exchange. A company that launched on the public markets less than five years ago at $1 a share, today has a total market capitalization of $4.2-billion.

***

Investors and companies on the FINRA list

Wall Street's self-regulator, the Financial Industry Regulatory Authority, has identified more than 300 investors whose active trading in Amaya's stock ahead of its blockbuster $4.9-billion (U.S.) PokerStars takeover last summer tripped alerts on the U.S. regulator's surveillance algorithms. FINRA, which is not investigating the investors, has circulated the names of those listed to Amaya and its deal advisers, who are required to answer questions about any possible connections with the investors. Typically, FINRA passes the results of these surveys to the Washington-based Securities and Exchange Commission and, if relevant, foreign market regulators. Some FINRA-listed investors barely know the Montreal company, others have connections.

Andy Roddick: When The Globe and Mail called the former tennis champion's agent, his San Diego-based financial manager Phillip Meyers replied that it was his decision to invest in the Montreal company on behalf of his client. He said Mr. Roddick remarked, "What's Amaya" after The Globe's inquiry. Mr. Meyers said he "knew of no non-public information about Amaya" when he traded the company's shares between April and July, 2014. He said he was drawn to the stock because of "unusual high volume patterns with upside price momentum." He said Mr. Roddick's investment gain on Amaya was $24,587.

Intertain: Online gambling company Intertain was created in February, 2014, out of discarded assets from Amaya, which continues to own a minority stake in the company. One of Intertain's directors, Toronto businessman John Fielding, confirmed to The Globe that he invested about $2-million in shares in Amaya before the deal was announced. Mr. Fielding says he had no material information about a deal and very little direct knowledge of Amaya. James Walker, who resigned as a director in February, 2014, of Intertain's predecessor company, declined to discuss his trades in Amaya other than to say "nothing untoward has happened." Robert Chalmers a stock promoter and former Intertain spokesperson, who is cited on FINRA's list, declined to comment.

Aston Hill: Three senior executives and one director of the small Toronto fund are listed by FINRA as Amaya investors. One Aston Hill director is Mr. Fielding, the Intertain director. Another is Aston Hill president Ben Cheng. He told The Globe "I have never owned shares in Amaya. If anyone at Aston Hill purchased shares in Amaya following the signing of the NDA (non-disclosure agreement) they were not privy to any confidential information about Amaya." David Tawaststjerna, a senior vice-president, did not respond to a request for comment. Steve Vannatta, an Aston Hill portfolio manager who recently moved to Redwood Asset Management, did not respond.

JC Clark Adaly Trust Fund: The Toronto fund reported a 49-per-cent gain in 2014 thanks to a "substantial" investment in Amaya. Colin Stewart, CEO of JC Clark Ltd., said the firm had no knowledge that a deal was in the works at Amaya when it invested and was never in possession of undisclosed, non-public information. In a fund commentary published in December, 2014, the firm dismissed the notion that the Quebec securities regulator's insider investigation would amount to much. "How in the world something like this [insider trading] can even be proved, when in fact rumours of the PokerStars acquisition had been swirling around the Street for weeks, is beyond me."

David Baazov's friends and associates: The FINRA list cites three individuals who are close friends and associates of Amaya's CEO Mr. Baazov. One investor is Yoel Altman, who has been a lender and adviser to the company for years. Amaya said in a statement to The Globe that Mr. Altman was not an adviser in the PokerStars takeover. Mr. Altman has not responded to requests for comment. Another is Shan Ahdoot, who is related to Mr. Baazov's childhood friend Benjamin Ahdoot and once touted Mr. Baazov as a director of his publicly listed tech company EXO U Inc. Mr. Baazov later declined the offer. Mr. Ahdoot did not return a request for comment. Another investor is Craig Levett, the Montreal businessman who was an initial investor in Amaya's predecessor company and who has had many business dealings with Mr. Baazov's older brother Josh. He did not respond to a request for comment.

With research assistance from Stephanie Chambers

This story corrects an earlier version that incorrectly spelled the name of the JC Clark Adaly Trust Fund.