Final Order — Money Services Business

Index: OFR 2026 - 275 ST ATE OF FLORIDA OFFICE OF FINANCIAL REGULATION 5/26/2026 LEGAL BH In Re: TRI-EAGLE ATM, INC., and MOHAMED NABULSI, Case N um her: 117072 Respondents. FINAL ORDER This cause came on for consideration and final agency action. Upon review of the record and being otherwise fully advised in the premises, the Office of Financial Regulation ("Office") hereby finds:

1. The Office has jurisdiction over the subject matter of this case and the parties hereto.
2. The entry of this Final Order concludes the above-referenced matter. ORDERED: A. The Stipulation and Consent Agreement (Exhibit A) is hereby approved and incorporated by reference as if fully stated herein and is adopted as the Office's Findings of Fact and Conclusions of Law. B. The parties shall comply with all terms of the Stipulation and Consent Agreement. DONE and ORDERED this 2b..p,,.. day of May, 2026, in Tallahassee, Leon County, Florida. Commissioner

CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Final Order has been furnished to Tri-Eagle ATM, Inc., and Mohamed Nabulsi, by electronic mail at -,/-flA trieagleatm@yahoo.com on this_ LL:>_ day of May, 2026. 14-8050 . lerk@flofr.gov Tel: (850) 410-9889 2

Exhibit A STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re: TRI-EAGLE ATM, INC., and MOHAMED NABULSI, Case Number: 117072 Respondents. STIPULATION AND CONSENT AGREEMENT The State of Florida, Office of Financial Regulation ("Office") and Respondents TRI EAGLE ATM, INC. ("Tri-Eagle") and MOHAMED NABULSI ("Nabulsi") (collectively, "Respondents"), in consideration of the mutual promises herein, recite, stipulate, and agree as follows:

1. Background. Tri-Eagle is a Florida company formed in 2017 by its sole owner and officer, Nabulsi. At all times material between May 2021 and September 2022 ("the relevant period"), Respondents placed three automated self-service machines (referred to herein as the "kiosks") inside third-party convenience stores in Tallahassee, Florida for the purpose of enabling consumers to cash checks on their own, purportedly eliminating the need for staff assistance. For a transaction fee, a consumer visiting one of these locations was able to receive cash in exchange for a check, money order, or similar payment instrument, upon its insertion into a kiosk and a successful identification verification. As the owner of these kiosks during the relevant period, Tri-Eagle acted as a "check casher" pursuant to section 560.103(6), Florida Statutes, and thereby operated a "money services business" pursuant to section 560.103(23), Florida Statutes (2023). At all times material, Nabulsi was and is the sole owner and president of Tri-Eagle. Accordingly, Nabulsi was and is both a "control person" of Tri-Eagle and a "person with a controlling interest" in Tri-Eagle, such that he was and is an "affiliated party" of Tri-Eagle who is therefore liable for any and all of Tri-Eagle's violations of

chapter 560, Florida Statutes. §§560.103(1), (lO)(a) and (I0)(t), 560.l 14(l)(a), and 560.127(1), Fla. Stat. (2023). Despite Respondents' use of these kiosks to regularly cash checks for consumers for compensation during the relevant period, including checks that equaled or exceeded $2,000, neither Tri-Eagle nor Nabulsi has ever applied for, or held, a money services business license in Florida pursuant to chapter 560, Florida Statutes. The Office first learned about Respondents' check cashing activities during an investigation to determine whether check cashing kiosks were being used by businesses in Florida in violation of any provision of chapter 560, Florida Statutes, or its corresponding rules. The Office's investigation began in 2021 by focusing on the kiosk supplier Simple Automated Money Inc. ("SAM") and its affiliate entity, Samco Financial Services Corp. ("Samco Financial"). SAM offered and sold the kiosks to vendors nationwide, and Samco Financial provided those vendors with ongoing kiosk support and remote check deposit services. The Office learned that SAM had leased or sold a number of kiosks to over a dozen vendors in Florida, including Respondents. In or around March 2021, Respondents entered into a contract to purchase three kiosks from SAM and, in exchange for a 25% cut of each transaction fee, to receive a variety of kiosk￾related services from Samco Financial that included remote customer verification, technical support, reporting, and banking services. Samco Financial received almost $2,500 of nearly $10,000 in total transaction fees collected by Respondents in exchange for cashing over $230,000 in checks through the three kiosk locations during the relevant period. Respondents maintain that SAM's sales agent orally represented to them at the initial point of purchase that Samco flnancial, not Respondents, would be responsible for handling all licensing and regulatory matters in Florida. Notwithstanding such representations, neither SAM nor Samco Financial ever submitted an application to the Office for a Florida money services business license. 2

Nonetheless, during the relevant period, SAM's website (www.samcodirect.com) advertised over a dozen Florida addresses where consumers could use a SAM kiosk to cash checks. SAM's website listed the three Tallahassee locations where Respondents' kiosks were located. The Office also learned that Respondents, consistent with their contractual obligations to SAM, had placed signage at these locations that informed the public about the availability of check cashing services using the kiosks. In December 2022, the Office issued letters to SAM and Samco Financial, as well as Respondents and the other Florida vendors, directing all parties to immediately cease and desist from engaging in unlawful check cashing activities in Florida. In April 2023, the Office initiated an administrative action against Samco Financial and its sole owner and officer, Charles Kintner ("Kintner"), who was also an officer of SAM. On April 25, 2024, the Office issued a Final Order (number OFR 2024-248) to Samco Financial and Kintner and which contained the Office's finding that between July 16, 2020 and December 2, 2022, they had unlawfully aided, assisted, procured, advised, and/or abetted in the cashing of checks by unlicensed third parties in the state of Florida through the use of kiosks purchased or leased from SAM, in violation of section 560. ll 4(1)(s), Florida Statutes. As a result of its investigation, the Office found grounds to initiate an administrative action against Tri-Eagle and Nabulsi. By this Stipulation and Consent Agreement, the parties are fully resolving all issues related to this matter in lieu of proceeding to litigation. 2. Jurisdiction. Pursuant to section 560.105, Florida Statutes, the Office is charged with the responsibility of administering and enforcing the provisions of chapter 560, Florida Statutes. The Office has jurisdiction to bring this administrative action against Respondents pursuant to chapter 560, Florida Statutes. 3. Findings. For purposes of this Stipulation and Consent Agreement, Respondents 3

neither admit nor deny, but consent to the Office's finding that for at least 499 days between May 2021 and September 2022, Tri-Eagle and Nabulsi engaged in check cashing, and advertised its check cashing service, without a license or exemption, in violation of sections 560.114(1 )(a) and (l)(w), 560.125(1), and 560.303(1), Florida Statutes. 4. Terms and Conditions. Respondents and the Office agree that the issues raised can be expeditiously resolved without a hearing and that further litigation can be avoided by the execution of this Stipulation and Consent Agreement. The parties acknowledge they have read this Stipulation and Consent Agreement and fully understand the rights, obligations, terms, duties, and responsibilities with respect to its contents. Therefore, in compromise and settlement of the foregoing findings and in consideration of the parties' forbearance from further litigation, Respondents agree to the following terms and conditions: a. FUTURE COMPLIANCE. Respondents Tri-Eagle and Nabulsi shall cease and desist from violations of chapter 560, Florida Statutes, and its corresponding rules, and comply with all provisions of chapter 560, Florida Statutes, and its corresponding rules. b. FUTURE APPLICATION. Respondents Tri-Eagle and Nabulsi shall not engage in any activity pursuant to chapter 560, Florida Statutes, which requires a license from the Office unless properly licensed. Respondents shall not apply for any license pursuant to chapter 560, Florida Statutes, for a period of THREE (3) YEARS from the date of entry of the Final Order adopting this Stipulation and Consent Agreement. Additionally, Respondents shall not act as an "affiliated party" of any company that is a "money services business" as defined by section 560.103(23), Florida Statutes (2025), and which is either licensed or required to be licensed by the Office, pursuant to chapter 560, Florida Statutes, for a period of THREE (3) YEARS from the date of entry of the 4

Final Order adopting this Stipulation and Consent Agreement. The fact that Respondents are not barred by the terms of this agreement from thereafter submitting any such application should not be construed as offering any opinion, suggestion, or insinuation concerning whether such license might be granted by the Office. Any application will be evaluated in the usual statutorily established manner. The facts surrounding this Stipulation may be fully considernd in any future licensing requests. c. ADMINISTRATIVE FINE. Respondents Tri-Eagle and Nabulsi shall pay the Office a total administrative fine of FOUR THOUSAND FIVE HUNDRED DOLLARS ($4,500.00), to be paid at the time of the execution and delivery of this Stipulation and Consent Agreement. The administrative fine shall be submitted in the form of a wire, cashier's check, or money order made payable to the "Office of Financial Regulation" and shall be sent to the attention of Agency Clerk- c/o Brandon Greenberg, Esq., Assistant General Counsel, Post Office Box 8050, Tallahassee, Florida 32314-8050. Respondents acknowledge and agree that in accordance with section 215.31, Florida Statutes, regarding the deposit of monies, (i) the tendered fine or settlement check proceeds may be deposited in advance of full execution or acceptance of the proposed Stipulation and Consent Agreement; and (ii) such deposit shall not be construed as a final acceptance of the Stipulation and Consent Agreement absent full execution thereof and entry of a Final Order adopting same. 5. Final Order. Respondents consent to the entry of a Final Order, which incorporates the terms of this Stipulation and Consent Agreement. Respondents understand and agree that this Stipulation and Consent Agreement is subject to the final approval of the Office and the entry of the Final Order adopting such Agreement. In the event that the Final Order is not entered, this Stipulation and Consent Agreement shall be null and void. The Final Order incorporating this 5

Stipulation and Consent Agreement constitutes final agency action by the Office, for which the Office may seek enforcement, pursuant to the provisions of chapters 120 and 560, Florida Statutes. 6. Waiver. By Respondents' consent to the entry of a Final Order with respect to this proceeding, Respondents waive: a. Any right to separately stated Findings of Fact and Conclusions of Law; b. Any right to receipt of a Notice of Rights pursuant to chapter 120, Florida Statutes; c. Any right to an administrative hearing or issuance of a Recommended Order pursuant to chapter 120, Florida Statutes; and d. Any right to contest in any administrative forum or judicial proceeding (including, but not limited to, an appeal pursuant to section 120.68, Florida Statutes) the validity of any term, condition, obligation, or duty expressly created in this Stipulation and Consent Agreement and the Final Order. 7. Releases. Upon full execution of this Stipulation and Consent Agreement, Respondents waive, release, and forever discharge the Office and its agents, representatives, and employees from any and all causes of action, in law or in equity, which Respondents may have arising from or relating to the subject matter hereof. The Office agrees to accept this release and waiver on behalf of itself and its agents, representatives, and employees without acknowledging, and expressly denying, that any such right or cause of action may exist. 8. Failure to Comply. Respondents acknowledge, concur, and stipulate that Respondents' failure to comply with any of the terms, obligations and conditions of this Stipulation and Consent Agreement, and the Final Order adopting it, is a violation of the written agreement and the Final Order entered pursuant to chapters 120 and 560, Florida Statutes. Such non￾compliance may result in the issuance of an emergency cease and desist order. However, nothing 6

herein shall be construed to limit Respondents' rights to contest any finding or determination of non-compliance. 9. Attorney's Fees. Each party herein shall be solely responsible for its separate costs and attorneys' fees incurred in the prosecution, defense, or negotiations in this matter up to and including entry of the Final Order adopting this Stipulation and Consent Agreement. 10. Severability. The parties agree that if any provision of this Stipulation and Consent Agreement (or the application thereof to any person or circumstance) is held invalid, the Stipulation and Consent Agreement will be given effect without the invalid provision, and to this end, the provisions of this Stipulation and Consent Agreement are declared severable. 11. Counterparts. This Stipulation and Consent Agreement may be executed in any number of counterparts, and by the parties in separate counterparts, each of which will be deemed to be an original but all of which together will constitute but one Stipulation and Consent Agreement. Copies of this Stipulation and Consent Agreement transmitted by facsimile or electronic mail shall have the same validity as if bearing an original signature. 12. Entire Agreement. This Stipulation and Consent Agreement represents the entire agreement by and between Respondents and the Office. Any alterations, variations, changes, modifications, or waivers of the provisions hereof shall be valid only when they have been reduced to writing, duly signed by the Office and Respondents hereto, attached to the original of this Stipulation and Consent Agreement, and subject to the approval of the Office. WHEREFORE, in consideration of the foregoing, the Office and Respondents execute this Stipulation and Consent Agreement for entry of a Final Ordcrr on the last date executed below. [this space intentionally blank with signatures appearing on the following page] 7

TRI-EAGLE ATM, INC. -,'--C ~ Q.!Ucl ~ ) \t \ S l Date: _ _ S .;.~ _~.:,....---=LJ=--=a:...c:: ~::,6,,,,,,,__ (Signature) Title: Mohamed Nabulsi sole owner and officer of Tri-Eagle A TM, Inc. State of Florida County of Leon Mohamed Nabulsi, as owner and officer of Tri-Eagle ATM, Inc., BEFORE ME by means of[") physical presence or [ ] online notarization, has sworn ( or affirmed) that he has read and understands the foregoing agreement and voluntarily signed the same. SWORN TO AND SUBSCRIBED before me this ~ ay of May 2026. Not.,;J.:rn{) Check the appropriate box: Personally known D OR Produced Identification E2(' Type of identification produced i Driver's License D Passport D Other _ (Do not include ID number) 8

MOHAMED NABULSI ~"'-D.uc~~ ~'c..\s. (Signature) State of Florida County of Leon Date: s-\ 4-- 2J) 2.G ------ - - - -- Mohamed Nabulsi, BEFORE ME by means of [ 4 1Ysical presence or [ ] online notarization, has sworn ( or affirmed) that he has read and understands the foregoing agreement and voluntarily signed the same. SWORN TO AND SUBSCRIBED before me this \l'°n day of May 2026. V Jvw\L Notary Public Check the appropriate box: Personally known D OR Produced Identification B Type of identification produced ~ Driver's License D Passport D Other _ (Do not include ID nwnber) OFFICE OF FINANCIAL REGULATION RACHEL SIMMONS MY COMMISSION# HH 713016 EXPIRES: August 21, 2029 Date: __ 5_12_2_12_0_2_6 _ Gregory C. Oaks, Director Division of Consumer Finance 9