RIA profile

Maceratio LLC

MIAMI, FLCRD 304078Registration Status: ApprovedEffective since August 16, 2024SEC # 801-130936Latest Form ADV October 13, 2026
Assets Under Management
$1.2B
Employees
7
Offices
1 office
Total Clients
248

Maceratio LLC's Form ADV filing dated 2026-10-13 reports $1,191,853,071 in regulatory assets under management, $0 discretionary and $1,191,853,071 non-discretionary, 278 accounts, and 7 employees.

Associated firm names

2 names listed
  • LS ADVISORS
  • MACERATIO LLC

Leadership

5 roles identified
CEONicholas P. Salas
CCONicholas P. Salas
CFOMarcus V. Ayres

Advisory services offered

4 types reported
Other advisory services
Portfolio management for businesses
Portfolio management for individuals and small businesses

Fee models offered

2 types reported
Asset based fees
Fixed fees

Offices & Contact

Primary office

MIAMI, Florida, United States

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Primary office regionOther reported regions
Florida

MIAMIPrimary office

Shading shows states and countries with reported offices. Cities are listed below; shading does not indicate service coverage.

1 office records listed · 1 total offices reported. Counts can use different reporting dates. SEC filers may list only their largest 25 additional offices.

Contact and digital presence

ADV profile links

Regulatory Assets Under Management Breakdown

Total regulatory assets under management$1.2Bas of October 13, 2026
Discretionary0.0%
$0
0% of total RAUM0.0%
Non-discretionary100.0%
$1.2B
100% of total RAUM100.0%
All regulatory assets under management are non-discretionary.

Client Coverage Demographics

Top client segmentHNWI represent 98.0% of total clients.
Top client categories% of clientsClients
1
HNWI
98.0%
243
2
Investment Cos.
1.6%
4
3
Other Advisers
0.4%
1
Categories with <5 clients
Other investment advisers<5 clients

Assets Under Management

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total AUM$1.2B
Total Accounts278
10Y AUM Change+$1.1B (+821.2%)

Employee Growth by Quarter

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total Employees7
Clients per Employee35:1
10Y Employee Change+4 (+133.3%)

Historical AUM and employee figures reflect available SEC Form ADV filings under this CRD. Filing gaps may reflect registration status changes, dormant periods, state registration periods, firm restructuring, or other reporting changes. Rialytix does not interpolate missing periods.

Private Funds

Private funds reported by Maceratio LLC

Loading private fund disclosures…

Custodians

Reported custodian relationships by Maceratio LLC

  • INSIGNEO SECURITIES, LLC

    $0

  • ACP SECURITIES, LLC

    $59,057,230

  • LATIN SECURITIES INC.

    $1,071,277,314

  • PERSHING LLC

    $0

These custodians are disclosed for separately managed accounts under Form ADV’s 10% reporting threshold. This is not a complete list of custodians for all client assets.


Ownership

Reported direct and indirect relationships by Maceratio LLC

Each range applies to a separate reported relationship and should not be added together.

Reported ownership ranges

Highlighted bands show the percentage range reported in Form ADV.

0%25%50%75%100%
MACERATIO HOLDINGS LLCDirect owner · Schedule AInterest in MACERATIO LLC
75%+
Marcus Vinicius AyresIndirect owner · Schedule BInterest in MACERATIO HOLDINGS LLC
50% to < 75%
NICHOLAS PATRICK SALASIndirect owner · Schedule BInterest in MACERATIO HOLDINGS LLC
50% to < 75%

Bars represent the reported range at that individual ownership step, not an estimated percentage of the advisory firm. Indirect relationships may refer to intermediate entities rather than directly to Maceratio LLC.

Reported ownership and control details

5 entries

Compliance & Disclosures

Responses were selected by the RIA in its filing. Questions are shortened for readability; “you” refers to the reporting firm, and some questions also cover advisory affiliates.

RIA or supervised-person involvementThe RIA reported that one or more events below involve the firm or its supervised persons.RIA responseYes
AFelonies2 No

In the past ten years, have you or any advisory affiliate:

  • A1Been convicted of or pleaded guilty or no contest to a felony?No
  • A2Been charged with a felony?No
BMisdemeanors2 No

In the past ten years, have you or any advisory affiliate:

  • B1Been convicted of or pleaded guilty or no contest to a misdemeanor involving investments, an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion?No
  • B2Been charged with a misdemeanor of the kind listed above?No
CSEC or CFTC actions3 Yes2 No

Has the SEC or CFTC ever:

  • C1Found you or an advisory affiliate made a false statement or omission?No
  • C2Found you or an advisory affiliate violated SEC or CFTC regulations or statutes?Yes
  • C3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • C4Entered an order against you or an advisory affiliate in connection with investment-related activity?Yes
  • C5Imposed a civil money penalty on you or an advisory affiliate, or ordered you or an advisory affiliate to cease and desist from any activity?Yes
DOther regulatory actions1 Yes4 No

Has any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority ever:

  • D1Found you or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?No
  • D2Found you or an advisory affiliate violated investment-related regulations or statutes?Yes
  • D3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • D4In the past ten years, entered an order against you or an advisory affiliate in connection with investment-related activity?No
  • D5Denied, suspended, or revoked your or an advisory affiliate’s registration or license, or otherwise prevented association with an investment-related business or restricted activities?No
ESelf-regulatory organization actions1 Yes3 No

Has a self-regulatory organization or commodities exchange ever:

  • E1Found you or an advisory affiliate made a false statement or omission?No
  • E2Found you or an advisory affiliate violated its rules, other than a violation designated as a minor rule violation under an SEC-approved plan?No
  • E3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • E4Disciplined you or an advisory affiliate by expulsion, suspension, barring association with other members, or otherwise restricting activities?Yes
FProfessional authorizations1 No
  • FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
GPending regulatory proceedings1 No
  • GAre you or any advisory affiliate now the subject of a regulatory proceeding that could result in a “Yes” answer to any part of C, D, or E?No
HCivil judicial actions and proceedings2 Yes2 No

(1) Court actions

Has a domestic or foreign court:

  • H(1)(a)In the past ten years, enjoined you or an advisory affiliate in connection with investment-related activity?Yes
  • H(1)(b)Found that you or an advisory affiliate violated investment-related statutes or regulations?Yes
  • H(1)(c)Dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or an advisory affiliate by a state or foreign financial regulatory authority?No

(2) Pending civil proceedings

  • H(2)Are you or any advisory affiliate now the subject of a civil proceeding that could result in a “Yes” answer to any part of H(1)?No
Additional DRP filings 5 source blocks

Verbatim excerpts from supporting DRP filings, which may concern the firm or advisory affiliates. Amounts retain their filed labels; no total or attribution is inferred.

regulatory · block 1GARCIA, LINA, MARIAPDF pages 20–22
Advisory affiliate name — filed text
GARCIA, LINA, MARIA
Regulator name — filed text
MINNEAPOLIS, MN
How was matter resolved — filed text
Settled

Action status / disposition — filed text

CASE WAS SETTLED BY BROKER-DEALER FOR $217,500.00
Other filed details

Description of allegations — filed text

ALLEGED UNSUITABLE INVESTMENTS/CHERRYPICKING

Sanction detail — filed text

BROKER-DEALER RESTITUTED CUSTOMER $217,500.00 ON 06/10/2024.
Full extracted filing text

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the

same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
4447599
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
GARCIA, LINA, MARIA
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
MINNEAPOLIS, MN
2.
Principal Sanction:
Other
Other Sanctions: 
CASE WAS SETTLED. NO SANCTION INSTITUTED.
3.
Date Initiated (MM/DD/YYYY): 
04/06/2023
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
23-00832
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
UCB FINANCIAL SERVICES
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ALLEGED UNSUITABLE INVESTMENTS/CHERRYPICKING

8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
06/10/2024
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
BROKER-DEALER RESTITUTED CUSTOMER $217,500.00 ON 06/10/2024.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
CASE WAS SETTLED BY BROKER-DEALER FOR $217,500.00
regulatory · block 2GARCIA, LINA, MARIAPDF pages 22–24
Advisory affiliate name — filed text
GARCIA, LINA, MARIA
Regulator name — filed text
SEC
How was matter resolved — filed text
Settled

Action status / disposition — filed text

CASE SETTLED ON OCT 2022. ALL FUNCTIONS SUSPENSION ENDED ON OCT 2023.
Other filed details

Description of allegations — filed text

CHERRY-PICKING THROUGH UCB ADVISERS WHERE RESPONDENT HAD OVERSIGHT RESPONSIBILITIES.

Sanction detail — filed text

SUSPENDED FOR 12 MONTHS (OCT 2022 - OCT 2023) FROM ALL FUNCTIONS, AND 36 MONTHS FOR ANY SUPERVISORY ROLE. ENJOINING FROM FUTURE VIOLATIONS OF 17(A)3 OF THE SECURITIES ACT OF 1933.
Full extracted filing text

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE

CRD
Number:
4447599
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
GARCIA, LINA, MARIA
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
SEC
2.
Principal Sanction:
Suspension
Other Sanctions: 
SUSPENSION FOR 12 MONTHS (OCT 2022 TO OCT 2023)
3.
Date Initiated (MM/DD/YYYY): 
10/02/2022
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-21218
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
UCB FINANCIAL ADVISERS INC.
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
CHERRY-PICKING THROUGH UCB ADVISERS WHERE RESPONDENT HAD OVERSIGHT RESPONSIBILITIES.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):

10/02/2022
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
SUSPENDED FOR 12 MONTHS (OCT 2022 - OCT 2023) FROM ALL FUNCTIONS, AND 36 MONTHS FOR ANY SUPERVISORY ROLE. ENJOINING FROM
FUTURE VIOLATIONS OF 17(A)3 OF THE SECURITIES ACT OF 1933.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
CASE SETTLED ON OCT 2022. ALL FUNCTIONS SUSPENSION ENDED ON OCT 2023.
regulatory · block 3POLIAK, MARCELO, JAVIERPDF pages 24–26
Advisory affiliate name — filed text
POLIAK, MARCELO, JAVIER
Regulator name — filed text
FINANCIAL INDUSTRY REGULATORY AUTHORITY
How was matter resolved — filed text
Acceptance, Waiver & Consent(AWC)

Action status / disposition — filed text

INDIVIDUAL DENIES THE FIRM'S ALLEGATIONS PERTAINING TO MONEY-TRANSFERS AS THE THOSE WERE RECEIVED, CONDUCTED AND REVIEWED BY THE FIRM AND ACCORDING TO HIS UNDERSTANDING OF EXISTING FIRM'S PROCEDURES.
Other filed details

Description of allegations — filed text

WITHOUT ADMITTING OR DENYING THE FINDINGS, CONSENTED TO THE SANCTION AND THE ENTRY OF FINDINGS THAT HE REFUSED TO APPEAR FOR ON- THE-RECORD TESTIMONY REQUESTED BY FINRA IN CONNECTION WITH ITS INVESTIGATION INTO THE REGULATORY TIP AND ALLEGATIONS CONTAINED IN FORM U5 FILLED BY MEMBER FIRM. TERMINATION WAS RELATED TO ALLEGEDLY FACILITATING IMPERMISSIBLE MONEY-TRANSFERS AND DELETING OFF-CHANNEL BUSINESS COMMUNICATIONS.

Sanction detail — filed text

PERMANENT
Full extracted filing text

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
2465622
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
POLIAK, MARCELO, JAVIER
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.

If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
FINANCIAL INDUSTRY REGULATORY AUTHORITY
2.
Principal Sanction:
Bar
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
05/19/2026
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2024084295503
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
JEFFERIES LLC
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, CONSENTED TO THE SANCTION AND THE ENTRY OF FINDINGS THAT HE REFUSED TO APPEAR FOR ON-
THE-RECORD TESTIMONY REQUESTED BY FINRA IN CONNECTION WITH ITS INVESTIGATION INTO THE REGULATORY TIP AND ALLEGATIONS CONTAINED
IN FORM U5 FILLED BY MEMBER FIRM. TERMINATION WAS RELATED TO ALLEGEDLY FACILITATING IMPERMISSIBLE MONEY-TRANSFERS AND DELETING
OFF-CHANNEL BUSINESS COMMUNICATIONS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
05/19/2026
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension

B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
PERMANENT
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
INDIVIDUAL DENIES THE FIRM'S ALLEGATIONS PERTAINING TO MONEY-TRANSFERS AS THE THOSE WERE RECEIVED, CONDUCTED AND REVIEWED BY
THE FIRM AND ACCORDING TO HIS UNDERSTANDING OF EXISTING FIRM'S PROCEDURES.
regulatory · block 4GHERARDI, PABLO, LEONELPDF pages 26–28
Advisory affiliate name — filed text
GHERARDI, PABLO, LEONEL
Regulator name — filed text
FINANCIAL INDUSTRY REGULATORY AUTHORITY
How was matter resolved — filed text
Acceptance, Waiver & Consent(AWC)

Action status / disposition — filed text

INDIVIDUAL DENIES THE FIRM'S ALLEGATIONS PERTAINING TO MONEY-TRANSFERS AS THE THOSE WERE RECEIVED, CONDUCTED AND REVIEWED BY THE FIRM AND ACCORDING TO HIS UNDERSTANDING OF EXISTING FIRM'S PROCEDURES.
Other filed details

Description of allegations — filed text

WITHOUT ADMITTING OR DENYING THE FINDINGS, CONSENTED TO THE SANCTION AND THE ENTRY OF FINDINGS THAT HE REFUSED TO APPEAR FOR ON- THE-RECORD TESTIMONY REQUESTED BY FINRA IN CONNECTION WITH ITS INVESTIGATION INTO THE REGULATORY TIP AND ALLEGATIONS CONTAINED IN FORM U5 FILLED BY MEMBER FIRM. TERMINATION WAS RELATED TO ALLEGEDLY FACILITATING IMPERMISSIBLE MONEY-TRANSFERS AND DELETING OFF-CHANNEL BUSINESS COMMUNICATIONS.

Sanction detail — filed text

PERMANENT
Full extracted filing text

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
4602689
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
GHERARDI, PABLO, LEONEL
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
FINANCIAL INDUSTRY REGULATORY AUTHORITY
2.
Principal Sanction:
Bar
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
05/18/2026
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2024084295502
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
JEFFERIES LLC
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, CONSENTED TO THE SANCTION AND THE ENTRY OF FINDINGS THAT HE REFUSED TO APPEAR FOR ON-
THE-RECORD TESTIMONY REQUESTED BY FINRA IN CONNECTION WITH ITS INVESTIGATION INTO THE REGULATORY TIP AND ALLEGATIONS CONTAINED
IN FORM U5 FILLED BY MEMBER FIRM. TERMINATION WAS RELATED TO ALLEGEDLY FACILITATING IMPERMISSIBLE MONEY-TRANSFERS AND DELETING
OFF-CHANNEL BUSINESS COMMUNICATIONS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
05/18/2026
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
PERMANENT
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).

INDIVIDUAL DENIES THE FIRM'S ALLEGATIONS PERTAINING TO MONEY-TRANSFERS AS THE THOSE WERE RECEIVED, CONDUCTED AND REVIEWED BY
THE FIRM AND ACCORDING TO HIS UNDERSTANDING OF EXISTING FIRM'S PROCEDURES.
civil judicial · block 1PDF pages 28–29
Full extracted filing text

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Item 11.H. of Part
1A or Item 2.F. of Part 1B of Form ADV.
Civil Judicial
Check Part 1A item(s) being responded to:
11.H(1)(a)
11.H(1)(b)
11.H(1)(c)
11.H(2)
Check Part 1B item(s) being responded to:
2.F(1)
2.F(2)
2.F(3)
2.F(4)
2.F(5)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the
same event. Unrelated civil judicial actions must be reported on separate DRPs.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
4447599
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
GARCIA, LINA, MARIA
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.H.
(1)(a), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) 
SEC
2.
Principal Relief Sought:

Civil Penalty(ies)/Fine(s)
Other Relief Sought: 
3.
Filing Date of Court Action (MM/DD/YYYY):
10/02/2022
 Exact
 Explanation
If not exact, provide explanation:
4.
Principal Product Type:
No Product
Other Product Types: 
5.
Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case
Number): 
DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA - CASE NO. 21-22152-CIV
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 
UCB FINANCIAL SERVICES LIMITED
7.
Describe the allegations related to this civil action (your response must fit within the space provided): 
CHERRY-PICKING THROUGH UCB ADVISERS WHERE RESPONDENT HAD OVERSIGHT RESPONSIBILITIES.
8.
Current Status? 
 Pending
 On Appeal
 Final
9.
If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 
10. If pending, date notice/process was served (MM/DD/YYYY):
10/02/2022
 Exact
 Explanation
If not exact, provide explanation:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only.
11. How was matter resolved:
Settled
12. Resolution Date (MM/DD/YYYY): 
10/02/2022
 Exact
 Explanation
If not exact, provide explanation:
13. Resolution Detail:
A.  Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $ 100,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:
DISGORGEMENT OF $264,000
C.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement, or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
FINE (100,000) AND DISGORGEMENT (264,000) PAID WITHIN 14 DAYS OF CASE SETTLEMENT OCT 02 2022.
14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must
fit within the space provided). 
TO AVOID THE COST OF ADDITIONAL LITIGATION, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, MS. GARCIA ELECTED TO ENTER INTO A
SETTLEMENT AGREEMENT WITH THE SEC.

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