9. The shares were received into the Nominee Accounts from Sulja Nevada’s treasury either directly or through Kore. In both circumstances, the trading constituted a distribution which requires in each instance the issuance of a prospectus receipt by the Commission for the securities of Sulja Nevada or a proper exemption under Ontario securities law. No such receipt has been issued nor have the Respondents demonstrated the existence of a proper exemption from the requirement, contrary to section 53 of the Act.
We KNOW no prospectus was ever filed in the US or Canada.
We KNOW the shares are now being publicly traded, so we KNOW there was a violation.
We might not know exactly who is responsible.
I have been posting about Rule 144 violations (US law) for some time now.