Final Order (Default) — Money Services Business

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STATE OF FLORIDA
OFFICE OF FINANCIAL REGULATION
In Re:
SKRILL USA, INC., Case Number: 133550
Respondent.
FINAL ORDER
The State of Florida, Office of Financial Regulation ("Office"), being authorized and directed to administer and enforce chapter 560, Florida Statutes, hereby enters this Final Order with Notice of Rights ("Final Order") as authorized by the provisions of chapters 120 and 560, Florida Statutes, against SKRILL USA, INC. ("Respondent"). FINDINGS OF FACT 1 . On March 6, 2026, the Office issued an Administrative Complaint ("Complaint") against Respondent, alleging violations of chapter 560, Florida Statutes. (Exhibit A)
2. The Office served Respondent with the Complaint via U.S. certified Mail at its
address of record with the Office.
3. Respondent timely filed a response indicating that it did not dispute any of the
Office's factual allegations, was not requesting a hearing and consented to the entry of a final order adopting the findings of fact and conclusions of law contained in the Complaint. (Exhibit B)
4. The Statement of Facts as alleged in the Complaint is incorporated herein by
reference as if fully set forth herein, and being uncontested by Respondent, is accepted as true and correct and is adopted by the Office as Findings of Fact for purposes of this Final Order.

CONCLUSIONS OF LAW
5. The Office is responsible for the administration and enforcement of chapter 560,
Florida Statutes, and has jurisdiction over the subject matter and of Respondent pursuant to chapter 560, Florida Statutes.
6. The Findings of Fact that have been adopted herein serve as the basis of the entry
of this Final Order against Respondent.
7. Based on the Findings of Fact adopted herein, Respondent's agreement with the
conclusions of law contained in the Complaint, and Respondent's waiver of a hearing, the Office concludes that Respondent violated the specific statutes and rules charged in the Complaint and, as such, the specific charges in the Complaint are adopted in this Final Order as Conclusions of Law.
8. The waiver of a hearing by Respondent, taken together with the Findings of Fact
and Conclusions of Law adopted herein, constitute sufficient grounds for the Office to take administrative action against Respondent, including the imposition of an administrative fine. Based on the foregoing Findings of Fact and Conclusions of Law, it is hereby ORDERED:
A. Within thirty (30) days of the docketing of this Final Order, Respondent shall pay an ADMINISTRATIVE FINE of Six Thousand Five Hundred Dollars ($6,500.00). B. Respondent shall submit the administrative fine in the form of a wire, money order or cashier's check made payable to the "Office of Financial Regulation." Such payment shall reference Case Number 133550 and shall be sent to the attention of Agency Clerk, c/o Maria A. Guitian, Assistant General Counsel, P.O. Box 8050, Tallahassee, FL 32314-8050. 2

DONE and ORDERED this 17-lt- day of April, 2026, in Tallahassee, Leon County, Florida. Commissioner NOTICE OF RIGHTS A PARTY WHO IS ADVERSELY AFFECTED BY THIS FINAL ORDER IS ENTITLED TO JUDICIAL REVIEW PURSUANT TO SECTION 120.68, FLORIDA STATUTES. REVIEW PROCEEDINGS ARE GOVERNED BY THE FLORIDA RULES OF APPELLATE PROCEDURE. SUCH PROCEEDINGS ARE COMMENCED BY FILING THE ORIGINAL NOTICE OF APPEAL WITH THE AGENCY CLERK FOR THE OFFICE OF FINANCIAL REGULATION AS FOLLOWS:
Bv Mail or Email
Agency Clerk
Office of Financial Regulation
P.O. Box 8050
Tallahassee, Florida 32314-8050
Phone: (850) 410-9889
Email: Agency.Clerk@flofr.gov
OR By Hand Delivery
Agency Clerk
Office of Financial Regulation
General Counsel's Office
The Fletcher Building
101 East Gaines Street, Suite 504
Tallahassee, Florida 32399
Phone: (850) 410-9889
A COPY OF THE NOTICE OF APPEAL, ACCOMPANIED BY THE FILING FEES AS REQUIRED BY LAW, MUST ALSO BE FILED WITH THE DISTRICT COURT OF APPEAL, FIRST DISTRICT, 2000 DRAYTON DRIVE, TALLAHASSEE, FLORIDA 32399-0950, OR WITH THE DISTRICT COURT OF APPEAL IN THE APPELLATE DISTRICT WHERE THE PARTY RESIDES. THE NOTICE OF APPEAL MUST BE FILED WITH BOTH THE AGENCY CLERK FOR THE OFFICE OF FINANCIAL REGULATION AND THE DISTRICT COURT OF APPEAL WITIDN 30 DAYS OF THE RENDITION OF THE ORDER TO BE REVIEWED. 3

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing Final Order was furnished by electronic mail to Skrill USA, Inc. c/o Zakary Cutler, CEO and COO at Zakary.cutler@paysafe.com and Lori Wilson, Senior Compliance Coordinator at lori.wilson@paysafe.com on this~ day of April, 2026. 4 A~ ~ [ Office of Financial Regulation Post Office Box 8050 Tallahassee, FL 32314-8050 Email: Agency.Clerk@flofr.gov Tel: (850) 410-9889

EXHIBIT A
STATE OF FLORIDA
OFFICE OF FINANCIAL REGULATION
In Re:
SKRILL USA, INC., Case N um her: 133550
Respondent.
ADMINISTRATIVE COMPLAINT
The State of Florida, Office of Financial Regulation ("Office"), files this Administrative Complaint against SKRILL USA, INC. (''Respondent"), alleging:
GENERAL ALLEGATIONS
I. Pursuant to sections 560.105 and 560.109, Florida Statutes, the Office is charged
with administering and enforcing the provisions of chapter 560, Florida Statutes, and conducting examinations and investigations to determine whether any provision of chapter 560, Florida Statutes, has been violated.
2. Pursuant to section 560.l 14(1)(a), Florida Statutes, failure to comply with any
provision of chapter 560, Florida Statutes, or related rule, constitutes grounds for disciplinary action.
3. Parts II, Ill, and IV of chapter 560, Florida Statutes, set forth the specific
requirements of money services businesses and licensees.
4. Section 560.103(23), Florida Statutes, defines a "money services business" as any
person located in or doing business in this state, from this state, or into this state from locations outside this state or country who acts as a payment instrument seller, foreign currency exchanger, check casher, or money transmitter.
5. Section 560.103(24), Florida Statues, defines a "money transmitter'' as a corporate
entity qualified to do business in this state which receives currency, monetary value, a payment

instrument, or virtual currency for the purpose of acting as an intermediary to transmit currency, monetary value, a payment instrument, or virtual currency from one person to another location or person by any means, including transmission by wire, facsimile, electronic transfer, courier, the Internet, or through bill payment services or other businesses that facilitate such transfer within this country, or to or from this country. The tenn includes only an intermediary that has the ability to unilaterally execute or indefinitely prevent a transaction.
6. Skrill USA, Inc. is licensed under Part II, Chapter 560, Florida Statutes, as a money
transmitter, having been issued license number FT230000379.
7. Skrill USA, Inc. is a wholly owned subsidiary of Paysafe Group Holdings II
Limited. Zakary Robert Cutler is the Chief Executive Officer and Chief Operating Officer of Skrill USA, Inc.
8. The Office conducted an examination (Examination No. 129622) of Skrill USA,
Inc., to ascertain its compliance with Florida law for the period of June 30, 2023 through December 31, 2024 ("examination period").
9. When the examination was concluded, the Office sent Respondent a letter
attaching a "report of examination." The letter specifically requested that Respondent the report and provide the Office with a written response. A response was received by the Office on October 31, 2025.
10. Respondent met with the examiner for an entrance conference or meeting on May
19, 2025, and an exit conference or meeting on June 17, 2025.
11. Rule 69V-560.1000(1 ), Florida Administratrive Code, provides that the penalties
that are applicable to each ground for disciplinary action that may be imposed by the Office against a person for a violation of chapter 560, Florida Statutes, are set forth in the "Office of Financial Regulation, Division of Consumer Finance, Form OFR-560-09, Disciplinary 2

Guidelines for Money Services Businesses .. . "
12. Pursuant to Rule 69V-560.1000(5), Florida Administrative Code, the range for an
"A" level administrative fine is between $1,000.00 and $3,500.00.
COUNT!
13. The above general allegations are hereby re-alleged and incorporated by reference
as if fully stated herein.
14. Pursuant to section 560.126(2), Florida Statutes, a licensed money services
business must report on a form adopted by rule, any change in the information contained in an initial license application fonn or in any amendment to such application, within 30 days after the change is effective.
15. Pursuant to Rule 69V-560 .102( 5), Florida Administrative Code, a completed Form
OFR-560-01, incorporated by reference into Rule 69V-560.1012, Florida Administrative Code, must be submitted within thirty (30) days of any change in information which is required to be reported on the fonn.
16. During the examination, the Office reviewed Respondent's bank records and
compared them to the information contained in Respondent's submissions of Form OFR-560-01.
17. The Office found that Respondent failed to timely report to the Office the removal
of seven (7) bank accounts under which it conducted money services business held at Metropolitan Commercial Bank, and failed to report the addition of four (4) bank accounts held at Community Federal Savings, under which it conducted money seTVices business.
18. Respondent failed to timely report changes to its banking information under which
it conducted money services business, in violation of section 560.126(2), Florida Statutes. I 9. Pursuant to the Disciplinary Guidelines for Money Services Businesses Form OFR-560-09, incorporated by reference in Rule 69V-560.1000, Florida Administrative Code 3

(2024 ), violation number 4 7, a licensee cited for violating section 560.126(2), Florida Statutes, is subject to an "A" level administrative fine.
20. Therefore, the Office is seeking an administrative fine of $3,500.00.
COUNT II
21. The above general allegations are hereby re-alleged and incorporated by reference
as if fuJJy stated herein.
22. Pursuant to section 560.126(3), Florida Statutes, a licensed money services
business must report on a form adopted by rule, any change in the control persons of the licensee or changes in the form of business organization by written amendment in such form and at such time specified by rule.
23. Pursuant to Rule 69V-560.201(3), Florida Administrative Code, requires that
every licensed money services business that proposes to change any personnel listed in question 5G of Fonn OFR-560-01 that does not result in a change of controlling interest in the licensee, shall file an amendment on or before the effective date of the change or within two (2) business days after the licensee first received notice of the change.
24. At the onset of the examination, the Office provided Respondent with a business
questionnaire to be completed.
25. As part of its examination, the Office reviewed Respondent's initial application for
licensure and all subsequent amendments to said application, as well as the business questionnaire responses.
26. The Office found that Respondent failed to timely notify the Office of the addition
of new officers.
27. Specifically, the Office found the following:
a) The addition of the Chief Compliance Officer, A.C.P.S., was not reported; 4

b) The addition of the Interim Chief Compliance Officer, J.G. was not reported; and, c) The addition of Chief Compliance Officer, M.M., was reported 66 days late.
28. Respondent failed to report the addition of a control person(s) of the licensee, in
violation of section 560.126(3), Florida Statutes.
29. Pursuant to the Disciplinary Guidelines for Money Services Businesses Form
OFR-560-09, Incorporated by Reference in Rule 69V-560.1000, Florida Administrative Code (2024), violation number 48, a licensee cited for violating section 560.126(3), Florida Statutes, is subject to an "A" level administrative fine.
30. Therefore, the Office is seeking an administrative fine of $3,000.00.
WHEREFORE, Respondent, SKRILL USA, INC. is hereby notified that the Office intends to enter an Order imposing an administrative fine in the amount of Six Thousand Five Hundred Dollars ($6,500.00). NOTICE OF RIGHTS The licensee is entitled to be represented by counsel or another qualified representative. The licensee also has the right to request a hearing pursuant to sections 120.569 and 120.57, Florida Statutes. Such request must comply with Rules 28-106.2015 and 28-106.104, Florida Administrative Code. An Election of Proceeding form is attached for your convenience. Any such request must be filed as fol1ows:
By Mail, Facsimile or Email
Agency Clerk
Office of Financial Regulation
Office of General Counsel
P.O. Box 8050
Tallahassee, FL 32314-8050
Phone: (850) 410-9889
Fax: (850) 410-9663
Email: Agency.Clerk@flofr.gov
OR
5
Bv Hand Deliven ·
Agency Clerk
Office of Financial Regulation
Office of General Counsel
The Fletcher Building
101 East Gaines Street, Suite 504
Tallahassee, FL 32399
Phone: (850) 410-9889

TO PRESERVE THE RIGHT TO A HEARING, A WRITTEN RESPONSE MUST BE FILED WITH THE OFFICE OF FINANCIAL REGULATION WITIDN TWENTY￾ONE (21) DAYS AFTER THE RECEIPT OF THE ADMINISTRATIVE COMPLAINT. SAID RESPONSE MUST BE RECEIVED BY THE OFFICE NO LATER THAN 5:00 P.M. ON THE TWENTY-FIRST DAY AFTER THE RECEIPT OF THE ADMINISTRATIVE COMPLAINT. A FAILURE TO TIMELY RESPOND IN WRITING WILL CONSTITUTE A WAIVER OF THE LICENSEE'S RIGHT TO REQUEST A HEARING AND A FINAL ORDER MAY BE ENTERED WITHOUT FURTHER NOTICE. You may not make an oral request for an administrative hearing. With regard to a written request, if you fail to follow the outlined procedure, your request may be dismissed. Any request for an administrative proceeding received prior to the date of this notice is deemed abandoned and to be considered must be timely renewed in compliance with the procedure set forth above. Mediation of this matter pursuant to section 120.573, Florida Statutes, is not available. NOTICE TO RESPONDENT In accordance with the Americans with Disabilities Act, persons with disabilities needing special accommodation to participate in this proceeding should contact the Agency Clerk no later than seven (7) days prior to the filing deadline or proceeding, at the Office of Financial Regulation, The Fletcher Building, 200 East Gaines Street, Tallahassee, Florida 32399, Phone:
(850) 410-9889, or by Email: Agency.Clerk@flofr.gov.
Maria
By: ~
A. Guitian a. ~
Assistant General Counsel
Office of Financial Regulation
Office of General Counsel
Fla. Bar No. 813966
200 E Gaines Street
Tallahassee, FL 32399
Tel: (305) 536-0341
Email:Maria.Guitian@flofr.gov
6

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing Administrative Complaint has been sent for service via US Certified Mail to Skrill USA, Inc. 5335 Gate Parkway, 4 th Floor, Jacksonville, Florida 32256 and Corporation Service Company 1201 Hays Street, Tallahassee, Florida 32301 on this 6th day of March, 2026. :tnm.w (l. ~i-/1~ Maria A. Guitian 9489 □□ □ □□ 27 662 □ 8139 96 7

Docusign Envelope ID: 1 DF98FB9-06D2-4332-B164-EADECE8D547D Case No: 133550 Skrill USA, Inc. 5335 Gate Parkway, 4th Floor Jacksonville, Florida 32256 STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION ELECTION OF PROCEEDING EXHIBIT B I have received and read the Administrative Complaint, including the Notice of Rights, filed by the Office of Financial Regulation ("Office") regarding the above-referenced Respondent, and I am requesting disposition as indicated below. PLEASE SELECT ONLY ONE OF THE OPTIONS:
OPTION #1: ~ l do not request a hearing in this matter. I do not dispute any of the Office's factual allegations and conclusions of law as stated in the Administrative Complaint. I understand that upon my waiving the right to a hearing, the Office may enter a final order adopting the findings of fact and conclusions of law In the Administrative Complaint. and imposing the penalties sought in the Administrative Complaint. OPTION #2: D I do not dispute any of the Office's factual allegations but dispute the Office's conclusions of law to those factual allegations, and request disposition of this matter by informal hearing pursuant to section 120.57(2), Florida Statutes. I request to (CHECK ONLY ONE OF THE FOLLOWING 2 OPTIONS):
a. D Attend a hearing by video teleconference before a Hearing Officer appointed by the Office; OR b. D Submit a written statement with supporting documentation to a Hearing Officer appointed by the Office. OPTION #3: D I do dispute one or more of the Office's factual allegations. I request a formal hearing before the Division of Administrative Hearings (DOAH) pursuant to section 120.57(1), Florida Statutes. In accordance with Rule 28-106.2015(5)(c), FAC, I am attaching a copy of the material facts that I dispute. If you selected Option #2 or #3, above, and wish to engage in settlement negotiation. please check the box below:
D I am interested in settlement negotiation. I request the Office to NOT refer my case for a hearing at this time. TO PRESERVE YOUR RIGHT TO A HEARING, A RESPONSE MUST BE FILED WITH THE OFFICE OF FINANCIAL REGULATION AGENCY CLERK NO LATER THAN 5:00 P.M. ON OR BEFORE THE TWENTY-FIRST DAV AFTER RECEIPT OF THE ADMINISTRATIVE COMPLAINT, BY ANY OF THE FOLLOWING METHODS:

1. By email: Agency.Clerk@flofr.gov; or
2. By U.S. Mail: P.O. Box 8050, Tallahassee, Florida 32314-8050; or
3. By hand delivery: Office of General Counsel, Fletcher Bldg., 101 E. Gaines Street, Tallahassee, FL 32399.
   ~s~ 57 ADFF43C525464 ...
   Signature of Respondent or
   Authorized Representative of Respondent
   Zakary Cutler. CEO & COO
   Printed Name & Title
   Apri 1 1, 2026zakary.cutler@paysafe.com
   Date E-mail Address
   Form: OFR-GC-13 (rev. 11.19.2024)
   5335 Gate Parkway, 4th FL.
   Mailing Address
   Jacksonville FL
   City State
   +1-617-962-2223
   Telephone Number
   STATE OF FLORIDA
   Page 1 of 2
   32256
   Zip