Cambria Capital, Llc

Allegations: SECTION 5 OF THE SECURITIES ACT OF 1933, NASD RULES 2110, 3010(A), 3010(B), 3011 - CAMBRIA CAPITAL LLC CONDUCTED SALES OF UNREGISTERED SECURITIES THAT WERE NOT EXEMPT FROM REGISTRATION. THE FIRM FAILED TO ESTABLISH A SUPERVISORY SYSTEM OR ESTABLISHED, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH SECTION 5 OF THE SECURITIES ACT OF 1933 TO DETECT OR PREVENT THE SALE OF SECURITIES THAT WERE NEITHER REGISTERED, EXEMPT FROM REGISTRATION OR TO DETERMINE THAT SECURITIES RECEIVED INTO CUSTOMER ACCOUNTS COULD BE SOLD WITHOU RESTRICTION. THE FIRM FAILED TO FULLY IMPLEMENT ITS CUSTOMER IDENTIFICATION PROGRAM IN CONNECTION WITH NEW NON-INDIVIDUAL CUSTOMER ACCOUNTS BY FAILING TO OBTAIN COMPLETE INFORMATION TO VERIFY THE IDENTITY OF THE ACCOUNTS. THE FIRM'S INDEPENDENT TESTING OF ITS AML PROGRAM FOR COMPLIANCE DID NOT COMPLY WITH NASD RULE 3011 BECAUSE THE TESTER DID NOT QUALIFY AS INDEPENDENT AT THE TIME IT WAS CONDUCTED. THE FIRM FAILED TO PROPERLY INVESTIGATE INFORMATION RECEIVED FROM ITS CLEARING FIRM IDENTIFYING CUSTOMERS OPENING NEW ACCOUNTS THAT HAD SECURITIES DISCIPLINARY HISTORIES AND/OR OTHER CHARACTERISTICS WARRANTING REVIEW. THE FIRM FAILED TO ENFORCE ITS SUSPICIOUS ACTIVITY REPORT (SAR) PROCEDURES IN THAT IT FAILED TO FILE SARS IN CONNECTION WITH QUESTIONABLE ACTIVITIES IN CUSTOMER ACCOUNTS INVOLVING $5,000 OR MORE. SUCH ACTIVITIES APPEARED TO LACK A LAWFUL PURPOSE AND THE FIRM WAS NOT AWARE OF ANY REASONABLE EXPLANATION FOR THE TRANSACTIONS. Status: Final Sanction Detail: $40,000 FINE Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED AND FINED $40,000.