Insider Trading at Score Media: OSC Settlement Highlights Market Integrity Risks

By Sharon Henderson, *Capital Currents*

The Ontario Securities Commission (OSC) has secured a settlement with Jessica Tam, the final participant in an insider trading scheme linked to the 2021 acquisition of Score Media & Gaming Inc. by Penn Entertainment. While the settlement – a two-year market ban and disgorgement of $120,000 in ill-gotten gains – appears straightforward, a deeper look reveals troubling questions about internal controls at Score and the persistent threat to market integrity posed by those who exploit confidential information.

Tam’s involvement, orchestrated by Score VP Alvin Huynh and facilitated by Huynh’s friend Nancy Pham, underscores the vulnerability of even established companies to insider trading. The scheme involved Huynh tipping Tam with non-public information about the impending acquisition, providing funds and trading instructions in exchange for 80% of the profits. Tam, in turn, received a 20% cut.

“Insider trading erodes public trust in our capital markets and undermines the integrity of our financial system,” stated Bonnie Lysyk, Executive Vice President, Enforcement at the OSC, in a press release. This case serves as a potent reminder of that principle, though the penalties levied raise questions about whether they sufficiently deter future misconduct.

A Breakdown of the Scheme

The timeline is crucial. According to the OSC, the scheme unfolded in the weeks leading up to the announcement of Penn Entertainment’s acquisition of Score Media in August 2021. Huynh, leveraging his position as a VP, accessed material non-public information and shared it with Tam, a friend of Pham. Pham's role, acting as a conduit, highlights how personal relationships can facilitate illicit activity.

“It's often not a sophisticated operation,” explains a former OSC investigator, speaking on condition of anonymity. “Often, it's about exploiting existing relationships and a lapse in judgment. The real challenge is uncovering these schemes before they generate significant profits.”

The OSC’s investigation, which benefited from Tam’s cooperation under its Credit for Cooperation Program, revealed that Huynh and Pham were previously settled with the OSC in September 2025, suggesting a coordinated effort to conceal the activity. The program, while offering incentives for cooperation, doesn’t eliminate the need for robust internal controls within companies.

Internal Controls Under Scrutiny

Score Media, a digital sports media company, had built a reputation for innovation and rapid growth. However, this case raises concerns about the effectiveness of its compliance program. While the company has not publicly commented on the specifics of the case beyond acknowledging the OSC’s actions, the fact that a VP was able to engage in such activity without detection is troubling.

“A strong compliance program isn’t just about having a policy manual; it’s about fostering a culture of compliance,” explains a corporate governance expert. “That means regular training, robust monitoring, and a clear process for reporting suspicious activity. It also requires a ‘tone at the top’ that emphasizes ethical behavior.”

The investigation suggests a potential breakdown in Score’s insider trading prevention policies. Did the company have clear restrictions on who had access to acquisition information? Were there robust monitoring systems in place to detect unusual trading activity? These are critical questions that Score must address to prevent future incidents.

Beyond Score: The Broader Threat

The Score Media case is not an isolated incident. Insider trading remains a persistent threat to the integrity of Canada’s capital markets. The OSC has been actively pursuing insider trading cases in recent years, but proving these cases can be challenging.

“The biggest obstacle is often uncovering the scheme in the first place,” says the former OSC investigator. “These schemes are often carefully concealed, and the perpetrators are adept at covering their tracks. We rely heavily on whistleblowers and data analysis to identify suspicious activity.”

Advances in technology, such as artificial intelligence and machine learning, are helping regulators to detect insider trading patterns more effectively. However, perpetrators are also becoming more sophisticated, using encrypted communication channels and offshore accounts to conceal their activities.

The penalties imposed on Tam, Huynh, and Pham, while significant, may not be enough to deter future misconduct. Some experts argue that tougher penalties, including jail time, are needed to send a stronger message to those who would exploit confidential information for personal gain.

“The goal isn’t just to punish the perpetrators; it’s to deter others from engaging in similar behavior,” says the corporate governance expert. “That requires sending a clear message that insider trading will not be tolerated.”

The Path Forward

The Score Media case serves as a cautionary tale for companies and regulators alike. Strengthening internal controls, enhancing surveillance capabilities, and imposing tougher penalties are all essential steps in combating insider trading. But ultimately, the most effective defense against insider trading is a culture of ethics and compliance, where integrity is valued above all else.

For Score Media, this incident is a reputational blow. The company must demonstrate a commitment to transparency and accountability to restore investor confidence. The OSC, meanwhile, must continue to aggressively pursue insider trading cases and work with other regulators to strengthen the integrity of Canada’s capital markets. The protection of these markets depends on it.