Final Order — Money Services Business

Index: OFR 2026 - 365
STATE OF FLORIDA
OFFICE OF FINANCIAL REGULATION
In Re:
J&J COMPASSION WEALTH
MANAGEMENT LLC, D/B/A
MET PASTORO & MET FOUNO, and
JOHANE ETIENNE,
Respondents.
FINAL ORDER
Case Number: 134374
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 { l,J).. day of July, 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 by email to Respondents at j.compassionwealthmanagement@gmail.com on this _L__b_1::;, of July, 2026. . flofr.gov Tel: (850) 410-9889 2

STATE OF FLORIDA
OFFICE OF FINANCIAL REGULATION
In Re:
J&J COMPASSION WEALTH MANAGEMENT LLC, d/b/a MET PASTORO & MET FOUNO, and JOHANE ETIENNE, Respondents. Exhibit A Case Number: 134374 STIPULATION AND CONSENT AGREEMENT The State of Florida, Office of Financial Regulation ("Office"), and J&J COMPASSION WEALTH MANAGEMENT LLC, d/b/a MET PASTORO & MET FOUNO, and JOHANE ETIENNE ("Respondents"), in consideration of the mutual promises herein, recite, stipulate, and agree as follows:

1. Background. At all times material hereto, J&J COMPASSION WEALTH
   MANAGEMENT LLC, d/b/a MET PASTORO & MET FOUNO, and JOHANE ETIENNE, is and has been a Part III Money Services Business in the State of Florida, having been issued license number FT340001314, and having been authorized to conduct business as a check casher. At all times material, JOHANE ETIENNE is and has been the President, CEO, Director, Comptroller, Sole Owner, and Registered Agent of J&J COMPASSION WEALTH MANAGEMENT LLC, d/b/a MET PASTORO & MET FOUNO. The Office conducted an examination (No. I 3 I 865) to ascertain Respondents' compliance with chapter 560, Florida Statutes. In lieu of initiating a formal proceeding, the parties are herein resolving the matters at issue.
2. Jurisdiction. The Office is the state agency charged with the administration and
   enforcement of chapter 560, Florida Statutes, and the rules promulgated thereunder. 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
consent to the Office making the following findings:
a) Respondents failed to implement their AML program. An independent review was not done in two of three years as required by the AML program and Respondents failed to provide annual training to one of three employees, in violation of 31 C.F.R
1022.210 and thereby section 560.114(1 )(y), Florida Statutes.
b) Respondents failed to maintain daily cash reconciliation, in violation of Rule 69V-560.704(3)(b), Florida Administrative Code, and section 560.114(l)(a), Florida Statutes. c) Respondents failed to maintain returned payment instrument records, in violation of Rule 69V-560.704(3)(a), Florida Administrative Code, and section 560.l 14(1)(a), Florida Statutes. d) Respondents failed to notify the Office in a timely manner of the addition of a new bank account within 30 days of the change, in violation of Rule 69V-560.201 (2), Florida Administrative Code, and section 560.126(2), Florida Statutes. e) Respondents failed to maintain records for five years pertaining to bank statements and bank signature cards. which were inaccurate, in violation of section 560.109(3)(a), Florida Statutes. f) Respondents failed to maintain a copy of each payment instrument cashed in violation of section 560.310(1 ), Florida Statutes. 2

4. Terms and Conditions. The parties agree that the issues raised can be
   expeditiously resolved without further litigation by the execution of this Stipulation and Consent Agreement. The parties acknowledge that 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 Office's forbearance from further litigation, Respondents agree to the following terms and conditions:
   a) FUTURE COMPLIANCE. Respondents agree that they shall cease and desist from violations of chapter 560, Florida Statutes, and the rules promulgated thereunder, and comply with all provisions of chapter 560, Florida Statutes, and the rules promulgated thereunder. b) LICENSE SURRENDER. Respondents shall voluntarily surrender their money services business license (number FT340001314 ). The license termination shall be effectuated by the Office on the date that the Final Order adopting and incorporating this Stipulation and Consent Agreement is entered. At that time, any and all rights and privileges pertaining to those holding such license shall terminate. c) FUTURE APPLICATION. Respondents shall not act as an affiliated party of any money services business licensed or required to be licensed by the Office, nor shall Respondents apply for any license pursuant to chapter 560, Florida Statutes, for a period of 3 years from the date of entry of the 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 3

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 and Consent Agreement may be fully considered in any future licensing requests.
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 of Financial Regulation 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 Stipulation and Consent Agreement constitutes final action by the Office for which the Office may seek enforcement pursuant to the provisions of chapters 560 and 120, Florida Statutes.
6. Waiver. By Respondents' consent to the entry of a Final Order with respect to this
proceeding, Respondents waive:
7. 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. Releases. Upon full execution of this Stipulation and Consent Agreement, Respondents waive, release, and forever discharge the Office and its agents, representatives, and 4

employees from any and all causes of action, in law or in equity, which Respondents may have arising out of this matter. The Office accepts this release and waiver by Respondents on behalf of itself, its agents, representatives, and employees without acknowledging, and expressly denying, that any such right or cause of action may exist.
8. Failure to Complv. 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 herein shall be construed to limit Respondents' right 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 attorney's fees incurred in the prosecution, defense, or negotiations in this matter up to and including the entry of the Final Order adopting this Stipulation and Consent Agreement.
10. Severabilitv. 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. 5

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 Order on the last date executed below. [this space intentionally left blank with signatures appearing on the following page] 6

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J&J COMPASSION WEALTH MANAGEMENT LLC. d/b/a MET PASTORO & MET FOUNO:
Name: JOHANE ETIENNE
State of FLl)L I Z>A
County of fA.c.rn ~ U
Date:() 1 -o::1- Qo:J&
Title: President, CEO. Director. Sole Owner, and Comptroller ..
JOHANE ETIENNE, as President, CEO, Director, Sole Owner, and Comptroller of J&J Compassion Wealth Management LLC, d/b/a Met Pastoro & Met Founo, BEFORE ME by means of)(physical presence or □ online notarization, has sworn (or affirmed) that (s)he has read and understands the foregoing agreement and voluntarily signed the same. SWORN TO AND SUBSCRIBED before me this--2e_ day of :[u ~ y , 2026. Check the appropriate box:
Personally known D
OR Produced Identification ~
Type of identification produced r:ll
□
□
~~ :;:,~ otar}'Public
Driver's License
Passport
Other _ ___
(Do not include ID number)
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LISA MARIE FABRO
Notary Publlc, Stale ot Florida
Commission# HH 310984
My comm. expires Sept. 12. 2026
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JOHANE ETIENNE:
Name: JOHAN£ ETIENNE
State of F u~i I l)A
CoW1ty of '?At.m ~
Date: O/- OJ- Jo:Jt_
JOHANE EITENNE, BEFORE ME by means of !m physical presence or O online notarization, has sworn (or affinned) that (s)he has read and understands the foregoing agreement and voluntarily signed the same . SWORN TO AND SUBSCRIBED before me this_L day of JYL..'( , 2026 . ~~ otPublic Check the appropriate box:
Personalty known D
OR Produced Identification ~
Type of identification produced ~ Driver's License 0 Passport USA MMUE FABRO Notary Public, State ol Flollda Commission# HH 310984 My oomm. expres Sep!. 12, 2026 0 Other ______ _ (Do not include ID number) OFFICE OF FINANCIAL REGULATION ~;;1.2,, ~;,.~:,4- Date: ---- - ----- 7/15/2026 Divisiop of Consumer Finance 8