Order: In the Matter of Polo Digital Assets, Ltd.

IN THE MATTER OF
POLO DIGITAL ASSETS, LTD.

File No. 2021-17

October 27, 2022

ORDER

(Subsection 127(1) and section 127.1 of the Securities Act, RSO 1990, c S.5)

WHEREAS the Capital Markets Tribunal held a combined merits and sanctions and costs hearing in writing to consider whether to make findings against, and impose sanctions and costs on, Polo Digital Assets, Ltd. (Polo Digital) pursuant to subsection 127(1) and section 127.1 of the Securities Act, RSO 1990, c S.5 (the Act);

AND WHEREAS the Tribunal made findings against Polo Digital in its Reasons and Decision issued on October 27, 2022;

ON READING the materials filed by Staff of the Ontario Securities Commission, no one appearing on behalf of Polo Digital;

IT IS ORDERED THAT:

1. pursuant to paragraph 2 of subsection 127(1) of the Act, trading in any securities or derivatives by Polo Digital shall cease permanently;
2. pursuant to paragraph 2.1 of subsection 127(1) of the Act, the acquisition of any securities by Polo Digital shall cease permanently;
3. pursuant to paragraph 3 of subsection 127(1) of the Act, any exemptions contained in Ontario securities law do not apply to Polo Digital permanently;
4. pursuant to paragraph 8.5 of subsection 127(1) of the Act, Polo Digital is prohibited permanently from becoming or acting as a registrant or as a promoter;
5. pursuant to paragraph 9 of subsection 127(1) of the Act, Polo Digital shall pay an administrative penalty in the amount of $1,500,000;
6. pursuant to paragraph 10 of subsection 127(1) of the Act, Polo Digital shall disgorge USD 1,825,417.89 to the Commission; and
7. pursuant to section 127.1 of the Act, Polo Digital shall pay $138,371.50 for the costs of the Commission’s investigation and hearing.