Final Order — Money Services Business

Index: OFR 2026 - 245 STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re: CFL CONSUL TING GROUP LLC, D/B/A MONEY AGENCY, SOCORRO PIRES MOURA MENDES, and ANTONIO MONTEIRO MENDES FILHO, Respondents. FINAL ORDER I 5/14/2026 LEG~. Case Number: 120520 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 CFL CONSULTING GROUP LLC. D/B/A MONEY AGENCY, SOCORRO PIRES MOURA MENDES, AND ANTONIO MONTEIRO MENDES FILHO ("Respondents"). FINDINGS OF FACT

1. The Office has jurisdiction over the subject matter of this case and the parties hereto.
2. At all times material, CFL Consulting Group LLC. d/b/a Money Agency is and has been licensed in Florida as a Part III Money Services Business, having been issued license number FT340001231, pursuant to chapter 560, Florida Statutes.
3. The Office conducted an examination (No. 115186) to ascertain Respondents' compliance with chapter 560, Florida Statutes, and found that grounds existed to initiate a legal action against Respondents. As such, on November I 8, 2025, the Office issued an Administrative Complaint ("Complaint") (Exhibit A) alleging violations of chapter 560, Florida Statutes, and

seeking an administrative fine of $26,475, and revocation of the Money Services Business license number FT340001231. 4. Respondents' license has since expired as of December 31, 2025 and revocation is no longer necessary. 5. The Complaint contained a Notice of Rights, which fully advised Respondents that they had twenty-one (21) days after the receipt of the Complaint within which to petition the Office for an administrative hearing to contest the allegation set forth in the Complaint, in accordance with sections 120.59 and 120.57, Florida Statutes, including the following information: B). TO PRESERVE THE RIGHT TO A HEARING, A WRITTEN RESPONSE MUST BE FILED WITH THE OFFICE OF FINANCIAL REGULATION WITHIN 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 W AIYER OF THE LICENSEE'S RIGHT TO REQUEST A HEARING AND A FINAL ORDER MAY BE ENTERED WITHOUT FURTHER NOTICE. 6. The Complaint was served by U.S. Certified Mail on November 24, 2025 (Exhibit 7. Respondents' written response to the Complaint was due on or before December 15, 2025. To date, the Office has neither received a written response to the Complaint nor have Respondents made a claim of equitable tolling. 8. The Findings of Fact alleged in the Complaint are hereby incorporated by reference and adopted as Findings of Fact in this Final Order. 2

CONCLUSIONS OF LAW 9. The Office is responsible for the administration and enforcement of chapter 560, Florida Statutes, and has jurisdiction over the subject matter and of Respondents pursuant to chapter 560, Florida Statutes. 10. The Findings of Fact that have been adopted herein serve as the basis of the entry of this Final Order against Respondents. 11. Section 120.569(2)(a), Florida Statutes, and Rule 28-106.111(2), Florida Administrative Code, require, among other things, that a response or a petition to an action which affects the substantial interests of a party be filed with the agency within 21 days of receipt of written notice of the action. 12. Section 120.569(2)(c), Florida Statutes, provides that a petition for hearing shall be dismissed if it has been untimely filed (not within 21 days). 13. Pursuant to Rule 28-106.111(4), Florida Administrative Code, the failure of Respondents to timely respond to the Complaint constitutes a waiver of Respondents' right to an administrative proceeding. 14. The doctrine of equitable tolling can be applied in administrative cases when a party has been misled or lulled into inaction, i.e., has in some extraordinary way, been prevented from asserting his rights, or has timely asserted his rights in the wrong forum. Machules v. Department olAdmin., 523 So. 2d 1132 (Florida 1988). 15. Without any evidence of equitable tolling, it is appropriate for the Office to conclude there was none. Patz v. Dept. of Health, 864 So.2d 79, 80 (Fla. 3d DCA 2003). 16. When Respondents failed to submit a response to the Office on or before December 15, 2025, Respondents did not timely file a petition or any other document in response to the Complaint. Respondents also presented no claim or evidence of equitable tolling. Therefore, it is appropriate for the Office to conclude there was no equitable tolling and Respondents waived their 3

right to an administrative proceeding. 17. Based on the Findings of Fact adopted herein, the Office concludes that Respondents 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. 18. The Findings of Fact and Conclusions of Law that fonn the basis for the Complaint, together with the waiver of a hearing by Respondents, constitute grounds for the Office to impose an administrative fine against CFL CONSULTING GROUP LLC. D/B/A MONEY AGENCY, SOCORRO PIRES MOURA MENDES, AND ANTONIO MONTEIRO MENDES FILHO. Based on the foregoing Findings of Fact and Conclusions of Law, it is hereby ORDERED: A. Within thirty (30) days of the date of this Final Order, CFL CONSULTING GROUP LLC. D/B/A MONEY AGENCY, SOCORRO PIRES MOURA MENDES, AND ANTONIO MONTEIRO MENDES FILHO shall pay an ADMINISTRATIVE FINE of Twenty-Six Thousand Four Hundred Seventy-Five Dollars ($26,475). B. Respondents 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 120520 and shall be sent to the attention of Agency Clerk, c/o David Tarbert, P.O. Box 8050, Tallahassee, FL 32314-8050. C. DONE and ORDERED this !~"#- day of May, 2026, in Tallahassee, Leon County, Florida. Commissioner 4

NOTICE OF RIGHTS A PARTY WHO IS ADVERSELY AFFECTED BY THIS FINAL ORDER IS ENTITLED TO WDICIAL 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: 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 By Hand Delivery Agency Clerk Office of Financial Regulation Office of General Counsel The Fletcher Building 101 East Gaines Street Tallahassee, FL 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 WITHIN 30 DAYS OF THE RENDITION OF THE ORDER TO BE REVIEWED. 5

CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Final Order was furnished by U.S. Certified Mail to CFL Consulting Group LLC. d/b/a Money Agency, Socorro Pires Moura Mendes, and Antonio Monteiro Mendes Filho at 7061 Grand National Dr., Suite 115, Orlando, FL 32819 on this ~ day of April, 2026.

• • ~489 □□ □ 0027 6620 8137 81 ·- - - - ------~---- 6 l Regulation 050 32314-8050 cy.Clerk@flofr.gov Tel: (850) 410-9889

Florida Office of Financial Regulation 200 East Gaines Street I Tallahassee, Florida 32399-0370 RETURN SERVICE REQUESTED .-,,., uiwrEc s,,:rcs CfRTff/£D M',, / • ......., f'()•:i,'!rsi:.,~Vl("i I j /1 Im I II11 9489 09 □ 0027 bb20 8157 47 ,,; .. a.~ ~i i"' -a;~ !f CFL Consulting Group LLC. d/b/a Money Agency Attn: Socorro Pires Moura Mendes 7061 Grand Nationa1 Dr., Suite 115 Orlando, FL 32819 ~

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STA TE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re: CFL CONSULTING GROUP LLC. D/B/A MONEY AGENCY, SOCORRO PIRES MOURA MENDES, and ANTONIO MONTEIRO MENDES FJLHO, Respondents. ADMINISTRA TJVE COMPLAINT Case Number: l20520 The State of Florida, Offa:e of Financial Regulation ("Office"), files this Administrative Complaint against CFL CONSULTING GROUP LLC. d/b/a MONEY AGENCY, and SOCORRO PIRES MOURA MENDES, and ANTONIO MONTEIRO MENDES FILHO (together "Respondents"), alleging: GENERAL ALLEGATIONS

1. 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 hcen violated. ') .... Pursuant to section 560.114( l )(a), Florida Statutes, failure lo comply with any provision of chapter 560, Florida Statutes, or related rule, constitutes grounds for disciplinary action.

2. Parts Tl, lll, and IV of chapter 560, Florida Statutes, set forth the specific rcqu iremcnts of money services businesses and liccns~s.

3. Section 560.114( I )(a), Florida Statutes, among other things, holds an "affiliated party" responsible for complying with any and all provisions of chapter 560, Florida Statutes, or its related rules.

4. Section 560.103(1 ), Florida Statutes, defines an "affiliated patty" as, among other things, an oflicer, responsible person, or a person who has a controlling interest in a money services business.

5. Section 560.103(1 0)(a) Florida Statutes defines a "control person'' as, among other thing~, an owner, president, or compliance otTicer of a money services business.

6. Section 560.103(6), Florida Statutes, defines a "check casher" as a person who sells currency in exchange for payment instruments received, except travelers' checks.

7. Pursuant to section 560.103(29), Florida Statutes, a "payment instrument" means a check, draft, warrant, money order, travckrs du:ck, electronic instrument, or other instrument used for the transmission, exchange, or payment of currency or monetary value.

8. At all times material. CFL Consulting Group, LLC. (''CFL Consulting") is and has hccn licensed as a Part lI1 Money Services Business (License No. FT30800193) pursuant to chapter 560, Florida Statutes. l 0. At all times material, CFL Consulting is and has been operating as a check casher, as defined in section 560.103(6), Florida Statutes. 11 . At all times material, Socorro Pires Moura Mendes ("Mendes") is and has been the President and 50% owner of CFL Consulting, and by operation of law, pursuant to section 560.103(1 ), Florida Statutes, Mendes is an "affiliated party" who is liable for any and all violations of CFL Consulting. Pae,e 2 of H

] 2. At all times material, Antonio Monteiro Mendes Filho ("Filho") is and has heen the Compliance Officer and 50% owner of CFJ, Consulting: and by operation of law, pursuant to section 560.103(1), Florida Statutes, Filho is an "affiliated party'' who is liable for any and all violations of CFL Consulting. 13. The omce conducted an examination (Exam Number 115186) of CFL Consulting's business records and operations for the period of April 1, 2021 to March 31 , 2023 ("examination period"). 14. Respondents produced, or attempted to produce, specified documents in response to the Otnce's various records requests throughout the examination. Pursuant to section 560.1105, Florida Statutes, Respondents are required to maintain all information necessary for detem,ining compliance with chapter 560 and related rules for 5 years. Therefore, all the payment instruments and business records referenced here \Yerc not only in Respondents' possession and control during the examination period, but Respondents are under a legal obligation to possess and continue to maintain the subject records pursuant tu section 560.1105, Florida Statutes. 15. During the examination period, Respondents cashed 4,177 payment instruments with a total face value of $5,040,738.68 and collected $103,673.32 in check cashing fees. 16. There were 572 payment instruments selected to review for compliance, 218 of ,vhich were for over $1,000. The Office found that 67 payment instruments produced by Respondents were duplicate check cashing database ("CCDB") entries. The payment instruments reviewed for compliance arc identified below.

Transaction Transaction Number Date 8519785 Pl?0/20~ 1 8635_5_7_6~1/_27/3_023 Check Order 1 1 Actual Total - r Actual Total N b f I Transaction um ero Ch~c;ks Amount 1 1 $1,432 .57 I -i $1,398.83 Payment Instrument Amount $1,432.57 $1,398.83 --------- Page 3 of2J I -l

8782569 7552747 8908970 ~ 8841911 8782684 ~~-"'· 2/24/2023 1 -- ~/24/2023 5/6/2022 ~ 1 _ 3/10/2023 1 2/24/2023 1 $1,375.81 $1,375.81 - -- - I $1,310.12 $1,310.12 $1,317.67 $1,314.36 $1,314.36 $1,256.~- J~,256,70 8106323 i_!!l_23/29_22 t 1 1 $1,197.90 I $1,197.90 8101488 9/23/2022 1 1 $1,197.90 $1,197.90 8026985 ( 9/2/2-02-2 -+· 1 ___ 1___ $_1-,2-00- .0- 0 - $1~-200.00 J 7973975 1 8/19/2022 .,I 1 1 ,,· _ $1,2_0_0.00~$1,2_0_0._o_o 7918000 8/6/2022 1 $1,200.00 I $1,200.00 --+---~--- -1- ·-·· - 8459681 I 12/16/2022 $26,326.25 I s1, 119.41 f-------i-'- -----------, 8457422 12/16/2022 1 2 $26,326.25 $7,119.41 ·-~-------+---- 7797069 7/7/2022 10 45 $6,825.00 $145.00 8642650 J.:.!E!.2023 _ 1 ____ 1 _~ $5,337.75 8106233 9/23/2022 , 1 1 $4,855.68 8sGs260 111112023 T 1 1 $4,000.00 $5,337.75 ! $4,855.68 $4,000.00 -- .. 7068896 1/3/2022 1 1 - , $2,161.55 • $2,161.55 --·- -- - . --- ·---· 7004596 12/16/2021 $2,079.35 $2,079.35 8476095 12/20/2022 1 1 $2,818.75 - -~-,. 8475461 12/20/2022 1 1 $2,818.75 >-------+--- --➔ 8675733 2/4/2023 1 2 $8,547.06 8675347 2/4/2023 1 2 $8,547.06 --- 8018236 9/1/2022 19 58 $9,395.00 I -- 8243762 10/28/2022 1 1 $5,718.52 -+------ 6358660 6/5/2021 $38,940.00 8910370 3/24/2023 I 2 2 $35,307.50 ---- ---~'------------- 8459681 8457422 6656183 6605279 8910591 8494823 12/16/2022 1 2 $26,326.25 12/16/2022 $26,326.25 - -+ ----- 8/24/2021 $13,288.00 - -- 8/17/2021 I $13,2ss.oo 3/24/2023 1 1 $15,000.00 12/B/2022 I 1 1 $12,820.20 $2,818.75 $2,818.75 $2,741.98 --- ~-- $2,741.98 - -- $510.00 $5,718.52 $38,940.00 $25,000.00 $19,206.84 $19,206.84 $13,288.00 $13,288.00 $15,000.00 $12,820.20 8491538 I !2/23/2022 .• 7694853 6/10/2022 7693112 6/10/2022 I 1 s12,s20.20 I s12,s20.20 $12,374.00 lsii~374.00 $12,374.00 ., $12,374.00 6685620 9/11/2021 -- c---~+- r 6685468 9/11/2021 - , .. ~ 6605277 8/7/2021 I 12/24/2021 ~~;~ I 12/24/2021 I 1008044 • 12111;20211

1 1 $9,587.00 $9,587.00 2 2 $15,944.00 $9,587.00 1 _ _ 1 . $9,144.10 $9,144.10 I 11 7 ' - 1 - .... $10,482.?S ~$l_OA82.~?. 1

• -1-- 1 $10,482.25 $10,482.25 1 1 $10,325.00 _ $10,325.00 Page 4 of23

l 7007809 8910370 6622792 8933190 - 8665713 8665472 8510667 8510565 7612855 7608490 8422150 8422094 1 12/17/2021 ! _ 1_ 3/24/2023 I 1 - ·1-- 8/24/2021 I 1 1 3/29/2_023 I 1 2/3/2023 1 2/3/2023 1 - - -- - I 1212s;2022 3 - , -- I 1212s;2022 3 •"t+- - - ·-- i 5/20/2022 1 5/20/2022 1 12/9/2022 1 12/9/2022 1 -, 1 2 1 1 -- 1 1 $10,325 .00 $10,325.00 --- __ $35,3_07.5.£_~ $10,307.50 $13,288.oo I $B,2ss.oo $1D,OOO.OO I $10,000.00 s10,ooo.oo r s10,ooo.oo $JO , 000 00 $10 , 000 00 - I - - 3 $23,342.00 $9,990.00 3 $23,342.00 $9,990.00 . 1 $9,950.00 $9,950.00 1 $9,950.00 $9,950.00 1 $9,900.00 $9,900.00 1 $9,900.00 $9,900.00 , __ ----- . - I 7960526 8/17/2022 1 1 $9,900.00 $9,900.00 - 7959903 7645838 7645288

8/17/2022 1 1 5/28/2022 1 .f----' I 5/28/2022 1 $9,900.00 $9,900.00 ~ ' - 1 j_ $9,900.00 $9,900.00 1 _ $9,900.00 $9,900.00 r - - 7698469 6/11/2022 1 $9,872.00 $9,872.00 -- - ·- 7694306 6/10/2022 1 $9,872.00 $9,872.00 - - - ----+-- 7431810 4/6/2022 1 $6,580.00 $6,580.00 - ··· - 7429904 4/6/2022 1 1 __ l $6,sso.oo $6,s8o.oo , - - ---r----- 8565020 1/11/2023 1 2 I $19,618.oo $9,809.oo _8S6~~9__J1/l 1/2023 2 --r-

• ·t-- - -- 2 I $19,618.00 $9,809.oo 8564810 l 111112023 1 I 2 $19,618.00 $9,809.00 .,. 8564810 -- 7585126 7583974 8642635 8841949 8841072

---

8917551 8783095

8780503 7975021 7974770 - 7974998

• • 7974821 8449127 8448852 8632285 8631285 8553562 I 1/11/2023 5/13/2.022 2 I 1 t￾2 $19,618.00 $9,809.00 --'--------'----, 1 $9,804.00 $9,804.00 5/13/2022 1/28/2023 ~ _ 1_-+--__ 1_-_i $8,715.83 1 $9,804.00 - -- - + 4 $30,881.99 $9,804.00 $9,800.00 $8,715.83 $8,715.83 $7,827.07 3/10/2.023 3/10/2023 3/25/2023 l 2/25/2023 1 1 j $8,715.83 1 1 $7,827.07 1 $6,120.00 i $6,120.00 2/25/2023 1 1 $6,120.00 $6,120.00 J 8/20/2022 1 1 $6,100.00 $6,100.00 8/20/2022 8/20/2022 1 1 $6,100.00 $6,100.00 1 1 $6,000.00 $6,000.00 _J 8/20/2022 1 1 $6,000.00 $6,000.00 ---'----+------+--- 12/15/2022 1 1 $5,943.01 $5,943.01 12/15/2022 J _]1~12023 I 1 1 $5,943.01 $5,943.01 1 -+---1~ ~~--$~4,-99_7 __ 7-6--.-- $4,997 :76 -1 1/26/2023 1 1 $4,997.76 $4,997.76 1/7/2023 l 1 1 __ $4,63_7J?O s~,6_37.oo Page 5 of23

8553137 7973915 7969090 8548569 8548259 8659912 8657582 8864799 8864319 8737370 8736887 8459283 8456216 8753721 8753671 8917788 8841038

8838539 8836703 8599853 - 8580349 8282498 8280452 8211063 8210744

8541811 8541661

7442001 7438800 8519909 8517464 8728787 - 8728709 8917788 8656844 8655697 8608464 8608166 8662122 8661467 8548405 111120~3 J 1 1 + $4,637.oo I $4,637 .oo s,119!2_02_2 1 1 I $3,292.8~ 1~ ,292.s8 s/1912022 1 1 $~,292.8_s l $3,292.s8 1/6/2023 1 1 $2,755.00 ! $2,755.00 1/6/2~2~) 1 1 $2,755.00 i $2,755.00 i l . y31;2023 I 1 1 s2,410.oo 1/31/2023 i 1 1 i, $2 470 00 l 3/1412023 T 1 1 -~ 13/14/2023 -1 $2,470.00 -- ~ , $2 , 470 00 - $1,852.00 $1,852.00 ,..__ .. ,,, __ $1,852.00 $1,852.00 I 2/11 ;2023 -1· -_i 2 2/17/2023 1 2 -1· - • 12/16/2022 1 r 1 _ I 12/16/2022 r-1 --6-1 r· 2/21/2023 1 1 2;2112023 . 1 1 l • 3/2s12023 -;-- - 1 - I 2 - ·r

• $2,517.50 $1,615.00 $2,517.50 $1,615.00 $1,337.25 $1,337.25 - - $1,337.25 $1,337.25 $1,330.00 ~,330.00 $2,425.50 I $1,270.35 --l ~ .-¼ ---• 3/10/2023 I 1 1 ----•- $1,260.4~ J $1,260.45 - - 3/9/2023 ]j '}./?023 1/14/2023 --- 1/14/2023 I 11;s;2022 I 11/s/2022 10/21/2022 1 . --~-- $1,240.43 $1,240.43 1 I 1 $1,240.43 $1,240.43 ---t - • -~-~ 1 1 $1,227.31 $1,227.31 1 __ -----1 ___ s1,2_27.3! I s1,221.31 __ 1 ____ 1 _ _ $1!214.18 j $1,214.18 1$1,214.18 I $1,214.18 - -----,--- 1 1 $1,207.65 $1,207.65

------- I 1012112022 1/5/2023 I 1/5/2023 4/8/2022 4/8/2022 12/30/2022 12/30/2022 2/16/2023 2/16/2023 3/25/2023 1/31/2023 1/31/2023 1/20/2023 1/20/2023 2/2/2023 I t -2;i;2023 .. 1/6/2023 1

-·· 1 $1,207.65 $1,207.65 1 $1,227.58 $1,227.58 1 $1,227.58 $1,227.58 - 1 $1,185.36 $1,185.36 1 1 $1,185.3_~ 1 $1,185.36 1 1 $1,200.00 I $1,200.00 ----+--------+-- 1 ___ 1__ $1,200.00 j $1,200.00 1 1 $1,141.35 $1,141.35 1 1 $1,141.35 $1,141.35 2 2 $2,425.50 $1,155.15 r--:--:-:- 1 1 $1,124.62 $1,124.62 1 - i - l s1,124.62 s1,124.62 --~----••--« 1 1 $1,097.55 $1,097.55 1 1 $1,097.55 l $1,097.55 1 I $1,075.35 $1,075.35 1 $1,075 .35 1 I $1,075.35 1 - -- $1,051 .65 $1,051.65 t Page(, of23

. 8545401 1/6/2023 1 1 $1,os1.65 I s1,os1.6s 8844219 ~/10/20~ 1 ____ H $1,023.33 1 $1,023.33 8842652 3/10/2023 1 $1,023.33 $1,023.33 8337493 J 1!/18/2022 1 • $1,049.30 .. - $1,049.30 I 8335799 ' 11/18/2022 l 1 1 $1,049.30 $1,049.30 8418509 ; 121312022 1 ~-1I,01s.04 • Slms.04 ~ • 8418437-] 12/8/2022 I 1 1 I $1,015.04 s1,01s.04 7425050 4/4/2022 --- 8459551 12/16/2022 - 8459506 12/16/2022 8457276 12/16/2Q?2 8394731 12/2/2022 8392151 12/2/2022 ~ 1 $1,050.00 1 l $1,040.00 ---- 1 1 $1,040.00 __ 1 ____ 1 _ l $1,040.00 1 1 . $1,040.00 $1,050.00 ~-- - ·- $1,040.00 j _ $1,040.00 I $1,040.00 r- · $1,040.00 -- 1 1 ~ $1,040.00 I $1,040.00 T s1,04o.oo $1,040.00 8337540 11/18/2022 1 1 $1,040.00 - - ~--- · - 8335773 11/18/2022 . 1 1 $1,040.00 ·•-· ---- 1 j $1,020.00 -----·--- 8273304 - - 8272654 8281902

8281078 8790908 11/4/2022 11/4/2022 .2.!f.~/2022 I 11/5/2022 I 212112023 1 - ---- I 1 r 1 I i I 1 8790768 212112023 I 1 8737370 2/17/2023 1 ----- 8736887 2/17/2023 2 ___ 8275201 11/4/2022 1 __. $1,020.00 -- -- 1 J $1,020.00 1 ~$!!002.00 $1,020.00 $1,002.00 1 ___ $1,002.00 _, $1,002.00 $1,031.94 2 s2,s11.so I $902.so 1~,031.94 j , 2 $2,517.50 $902.50 _1 ___ 1 $-1-,2-14-.1-8---,.-$-1,-21-4-.1-8- 17. The Office also reviewed these 5 of the 22 corporate customer files that Respondents were required to maintain during the examination period. Corporate Files Pagr 7 of"23

18. As part of the examination, Respondents met with the Office for an exit conference on May 30, 2023.

19. After the examination was concluded, Respondents \Vere sent a letter dated September 28, 2023, attaching the Report of Examination. The letter specifically requested that Respondents "review the report and provide a written response to the [Office] within fifteen (15) business days." The letter further informed Respondents that their wrinen response ';may include advising the Oftice of any exceptions or disagreements with the report, any actions taken to correct the possible violations, and any mitigating circumstances you would like us to consider that might reflect the need for a lesser sanction in the event a violation has occurred."

20. The Report of Examination identified potential violations of the specific statutory provisions of chapter 560, Florida Statutes, and the accompanying rules of the Florida Admini!ilrative Code. For each finding, the Report of Examination also hrictly stated how Respondents violated the applicable statute and/or rule. 21 Pursuant to Ruic 69V-560. I 000(5), Florida Administrative Code, the range for an "A" level fine is between SI ,000 and $3,500.

21. Pursuant to Rule 69V-560. l 000(5), Florida Administrative Code, the range for a af3" level fine is between $3,500 and $7,500.

22. Pursuant to section 560.114(1 )( a), Florida Statutes, each money services business and its affiliated parties must comply with all provisions of chapter 560, Florida Statutes, the Office may revoke a money services business license for such failure to comply. COUNTI

23. The above general ailcgations arc hereby re-alleged and incorporated by reference as if fully stated herein. Pa!!C N of23

24. Pursuant to section 560.310(2)(d), Florida Statutes, when payment instruments ("checks") over $1,000 arc cashed, licensees are required to submit certain information into the check cashing database ("CCDB") before providing currency to the person cashing the check.

25. Pursuant to section 560.310(2)(d), Florida Statutes, and Rule 69V-560.704(5), Florida Administrative Code, among the infonnation required to be submitted into the CCDB are the following: • Transaction date; • Payor name; • Payee name; • Conductor's name; • Payment instrument amount; • Amount of currency provided; • Payment instrument type; • Check cashing fee; • Branch or location where the check was accepted; • Personal identification type and number presented hy payee or conductor; • Payee's workers' compensation policy number or exemption certificate number; • Payee's Corporate Document Number issued hy the Secretary of State; and, • Payee's federal Employee Identification Number.

26. As part of its examination, and as detailed in the general allegations, the Office reviewed a sample Respondents' records for a sample of 572 of Respondents' check cashing transactions that were required to be submitted into the CCDB.

27. The Office found that 67 of the 572 ( l I%) entries were duplicate entries of the same transaction.

28. During the examination period, Respondents entered inaccurate information into the CCDB, in violation of section 560.3 l0(2)(d), Florida Statutes, and Rule 69V-560.704(5), Florida Administrative Code,

29. Pursuant to the Disciplinary Guidelines for Money Services Businesses Form OFR￾560-09, incorporated by reference in Ru le 69V-560. I 000, Florida Administrative Code (2019), Page 9 of23

violation number 96, a licensee cited for violating section 560.3 J0(2)(d), Florida Statutes, rs subject to an ''A" level administrative fine and revocation of license. 31. Therefore, the Office is seeking an administrative fine of $1,300 an<l revocation of license. COU~TII 32. The above general al legations are hereby re-alleged and incorporated by reference as if fully stated herein. 33. Pursuant to section 560.103( 11 ), Florida Statutes, a "corporate payment instrument" is a payment instrument (check) on which the payee named on the check's face is other than a natural person. 34. Pursuant to section 560.3 l 0(2)(a), Florida Statutes, licensees are required to create and maintain a customer file for each entity listed as the payee on corporate checks accepted by the licensee that exceed $1,000. 35. Pursuant to Rules 69V-560.704(4)(d), Florida Administrative Code, each customer file must include the following information: • Documentation from the Secretary of State (so-called "SlJNBIZ") verifying registration as a corporation showing the listed officers and FElD registration number; • Articles of Incorporalion or other such documentation which establishes a legal entity in whatever form authorized by law. For purposes of this rule a sole proprietor operating under a fictitious name registered with the Secretary of State shall not have to present such documentation; • Documentation of the business I icense/occupational license, business tax receipt, or its equivalent from the county where the entity is located; • A copy of the search results .screen page from Compliance Proof of Coverage Query Page wcbpage from the Florida Department of Financial Services - Division of Workers' Compensation website Page 10 of23

fhtt )s://dwcdata )Ortal.fldfs.com/ProofOfCovcraue.as 1x ,: • lfthe entity has an active workers' compensation policy, the licensee must also maintain a copy of the policy declaration page or other document provided by the insurer indicating the amount of coverage; • Documentation of individuals authorized to negotiate payment instruments on the corporation or fictitious entity's behalf including corporate resolutions; and, • A written corporate customer profile which includes; the full legal name of each beneficial ovv11er, as defined in 31 C.F.R. s. 10 l 0.230( d), effective July 1, 20 l 8, is hereby incorporated by reference and available al http:/ /www.flrules.or!!/ Gatewa,-Jrefcrence.a_sp ?~Q:"":Re(: l I 4(i4, of the corporate customer; an explanation of the customer's business model; typc(s) of services offered; projected annual volume of check cashing; and annual check cashing limits as lhey relate to the corporate customer's workers' compensation policy coverage limits. 36. As part of its examination. and as detailed in the general allegations above, the Office reviewed a sample of 5 of Respondents' corporate customer files and found the following: • Regarding the SUNBIZ document. 3 of the 5 files reviewed did nut contain this document; • Regarding the business tax receipt: in 5 of the 5 files this document was missing; • Regarding the proof of worker's compensation coverage, 5 of the 5 files Cailcd to include this document; • Where an active workers' compensation policy existed, none of those customer files contained a copy of the policy declaration page or other document provided by the insurer indicating the amount of coverage; • Regarding the required written corporate customer profiles, Respondents failed to include an explanation of the customer's business model in all 5 files. 37. Respondents failed to maintain complete corporate customer files, in violation of section 560.310(2)(a), Florida Statutes: and Rules 69V-560.704(4)(d), Florida Administrative Code. 38. Pursuant to the Disciplinary Guidelines for Money Services Businesses Form OFR￾560-09, im:orporatcd by reference in Rule 69V-560. I 000, Florida Administrative Code (2019), violation number 93, a licensee cited for violating section 560.310(2)(a), flori<la Statutes, is subject to an "A" level administrative fine: and revocation of license. Pagel 1 of23

39. Therefore, the Office is seeking an administrative fine of 53~500 and revocation of license. COUNTIII

40. The above gcrn:ral allegations are hereby re-alleged and incorporated by reference as if fully stated herein.

41. Pursuant lo section 560.310(2)(a), Florida Statutes, a I icensee must maintain customer files if the licensee is cashing payment instruments from the corporate customer that exceed $1,000. Pursuant to Rule 69V-560.704(4)(d)7., Florida Administrative Code, each customer file must contain a written corporate customer profile which sets an annual check cashing limit.

42. Pursuant to Ruic 69Y-560.609(4), Florida Administrative Code, check cashing transactions involving corporate payment instruments that exceed the annual check cashing limits set by the licensee are deemed suspicious and require the check casher to file a suspicious activity report (''SARH) for each transaction.

43. Pursuant to section 560.309(5), Florida Statutes, a licensee must report all suspicious activity to the Office, in accordance with the criteria in 31 C.f.R. I 022.320. Pursuant to Rule 69V-560.609(2), Florida Administrative Code, the Oflice has designated FinCEN as the appropriale regulator to receive the reports.

44. Pursuant to Rule 69V-560.609(2), Florida Administrative Code, and 31 C.F.R. 1022.320, Florida check cashers are required to submit such suspicious activity reports ("SARs") to FinCEN no later than thiny (30) calendar days after the date of initial detection of the facts that constitute the basis for filing the report. Paic 12 of23

45. As a part of the examination, the Oilicc rcviev•:ed a sample of 5 customer files where each file included the customer-specific annual check cashing limit set by Respondents.

46. The Office found that, for 3 of the 5 corporate customers, the total amount of checks cashed for that corporate customer in that particular year exceeded the annual limit set, as detailed below. Check Date Check Corporate Cashing Cashing Date Check Value of Checks Amount Check Customer Limit (Year Limit Cashing Limit Cashed During Cashing Limit was and Set Reviewed This Period* Exceeded By Amount) 08/2022 - $1.089.85 2021- 0l/1Y2022 09/2022 - $11,957.65 $35.000 09'30.2021 01/11:2023 $329,120.95 I 0/2022 - $983.50 (Monthly) 11/2022 - $8,500 TOTAL- $22.531.00 08/2021 - $20.368. 70 2021- 11/2021 - $22.019.25 $25,000 01 .. m12021 01/07/2022 $182,394.55 12/2021 - $11 ,877 TOTAL - $54,265 08 1 202 I -$26.250 2021- 08i30/2021 07,'04/2022 $77,718.93 03/2022 - $7.500 $10,000 042022 - $6,453.60 TOT AL - $40.204

47. The Office also reviewed Rt!spondents' FinCEN filings, and no SARs reporting this activity we.re filed by Respondents within 30 days.

48. Respondents failed to file SARs when the total of checks cashed by corporate customers exceeded the check cashing limits established for them by Respondents, in violation of section 560.309(5), Florida Statutes, and Rule 69V-560.609(4), Florida Administrative Code.

49. Pursuant to the Disciplinary Guidelines for Money Services Businesses Fon11 OFR￾560-09, incorporated by reference in Rule 69V-560. I 000, Florida Administ.rativc Code (2019), Page Jl of23

violation number 86, a licensee cited for violating section 560.309(5), florida Statutes, is subject to a "B" fine and revocation of license. 50. Therefore, the Office is seeking an administrative fine of $7,500 and revocation of license. COUNTIV 51 The above general allegations are hereby re-alleged and incorporated by reference as if fully staled herein. 52. Rule 69V-560.704(3)(b), Florida Administrative Code, requires that every check casher maintain, among other things, a daily cash reconciliation summarizing each day's activities and reconciling cash on hand at the dose of business for that day. The rule further provides that the daily cash reconciliation shall be sufficiently detailed to provide an audit trail of each day's business activity. 53. During the examination, the Office requested Respondents' daily cash reconciliations records. On April 13, 2023, Respondents submitted a signed statement indicating that the requested records could not be located, and that Respondents had no reasonable basis to believe they existed . 54. Respondents failed to maintain daily cash reconciliations, in violation of Rule 69V￾560. 707(3)(b), Florida Administrative Code, and thereby section 560.114(1 )(a), Florida Statutes. 55. Pursuant to the Disciplinary Guidelines for Money Services Businesses form OFR￾560-09. incorporated by reference in Rule 69V-560.1000, Florida Administrative Code t2019), violation number 3, a licensee cited for violating section 560.114(I)(a), Florida Statutes, is subject to an "A" levt!I administrative fine and revocation of license. !'age 14 of 23

56. Therefore. the Office is seeking an administrative fine of $1,500 and revocation of license. COUNTV

57. The above general allegations are hereby re-alleged and incorporated by reference as if fully stated herein.

58. Pursuant to section 560.126(3), Florida Statutes, and Rule 69V-560.20 l (3), Florida Administrative Code, a licensee must report any change in the partners, officers, members, joint venturers, di rec.tors, controlling shardwlders, or responsible persons of the licensee, or changes in the form of business organization, within 30 days through an amended license application.

59. As part of ils examination, the Office revkwed Respondents' Application for Licensure as a Money Services Business, and any amendments, and documents regarding owner.ship of Respondents' business.

60. The Office found that Respondents' October 5, 2022 amended application stated ownership as Socon-o Pires Moura Mendes with 97% and Antonio Monteiro Mendes Filho with 3%.

61. The Office found further that Respondents' "Management Operating Agreement," effective January 1, 2020, states the ownership as Socorro Pires Moura Mendes with 97% and Christianne Barbosa Almeida with 3%.

62. Further, Respondents' "First Amendment to Operating Agreement," adopted January I, 2022, changed the ownership to Socorro Pires Moura Mendes with 50% and Antonio Monteiro Mendes Filho with 50%. Pagi; 15 llf2J

63. Therefore. Respondents were untimely in notifying the Office of changes in ownership with hoth their October 5, 2022 and May 29, 2023 amended applications, as detailed below. Application Information Summary ~~ - 1---~~;e ~,- I Main Business Address Names of Owners I A 1 . . Percentage i pp 1cat1on -- ------- ! 97% Days Late Reported to the Office 7061 Grand National Dr, Suite 1 I 5 Socorro Pires Moura \iendes Orlando. FL 32819 l0'05i2022 -; 277 Days Late 7061 Grand National Dr, Suite 115 Orlando. FL 328 I 9 Antonio Monteiro Mendes Filho Socorro Pires Moura Mendes Antonio Monteiro Mendes Filho 05 29/2023 03% 50% 50% 513 Days f,ate

64. Respondents failed to repo11 change in the partners, officers, members, joint venturers, directors, controlling shareholders, or responsible persons of the license~, or changes in the form of business organization, within 30 days through an amended license application, in violation of section 560.126(3), Florida Statutes, and Rule 69V-560.20 I (3), Florida Administrative Code. 65 . Pursuant to the Disciplinary Guidelines for Money Services Businesses, Form OFR-560-09, incorporated by reference in Rule 69V-560. l 000, Florida Administrative Code (2019), violation number 48, a licensee cited for violating section 560.126(3), Florida Statutes, is subject to an ''A" level administrative tine.

65. Therefore, the Office is seeking an administrative fine in the amount of $2,000. COUNT VI 67 . The above general allegations are hereby re-alleged and incorporated by reference as if fully stated herein. Pap.c 16 <>f23

66. When a payment instrument of greater than $1,000 is cashed, section 560.310(2)(b ), Florida Statutes, and Rule 69V-5r50.704(4)(c), Florida Administrative Code: require a licensee to maintain a legible copy of acceptable personal identification that bear:-; a photograph of the customt:r.

67. Pursuant to section 560.310(2)(h), Florida Statutes, acceptable personal identification is limited Lo a valid driver license. a state identification card issued by any state of the United States or its territories or the District of Columbia and showing a photograph and signalure, a United States Government Resident Alien Identification Card, a passporl. oral inited States Military identification card .

68. As parl of its examination, and as detailed in the general allegations, there \J..1ere 5 72 payment instruments selected to review for compliance, 218 of which 'Vere for over Sl,000. The Office found that 67 payment instruments produced by Respondcms were duplicatt: CCDB entries; therefore, the Office reviewed Respondents' records for a sample of 151 payment instruments cashed that were over S 1,000. The Office also reviewed copies of the personal identification that had been presemed by cuscomcrs when they cashed those payment instruments.

69. The Office found that for 51 of the 15 l (33%) transactions, RespondenLs failed to maintain copies of valid, acceptable identifications. The Office 48 found instances in which the identification was not one of the acceptable forms, and 3 instances in which the identification was expired.

70. Respondents failed to maintain records of acccptahlc personal identifications, in violation of section 560.310(2)(b), Florida Statutes.

71. Pursuant to the Disciplinary Guidelines for Money Services Businesses Fom1 OFR￾560-09, incorporated by reference in Rule 69V-560.1000, Florida Administrative Code (2019), Pagd7of23

violation number 94, a licensee cited for violating section 560.310(2)(b), florida Statutes, is subject to an "A" level administrative fine and revocation of license. 74. Therefore: the Office is seeking an administrative fine of S 1,800 and revocation of license. COUNT VII 75. The above g~m::ral allegations are hereby re-alleged and incorporated by reference as if fully stated herein. 76. Pursuant to section 560.309(2), Florida Statutes, when licensees cash checks, they are required to endorse them with their legal name. 77. As part its examination., and as detailed in th~ general allegations, the Office reviewed Respondents' records for a sample of 572 payment instruments cashed during the examination period. 78. The Office found that 572 of the 572 (100%) checks reviewed were not endorsed with Respondents' legal name. 79. Respondents failed to endorse all cashed checks with their legal name, in violation of section 560.309(2), Florida Statutes. 80. Pursuant to the Disciplinary Guidelines for Money Services Businesses Forni OFR￾560-09, incorporated by reference in Ru le 69V-560. l 000, Florida Administrative Code (2019), violation numher 83, a licensee cited for violating section 560.309(2), Florida Statutes, is subject to an "A" level fine and revocation of license. 81 Pursuant to Rule 69V-560-I 000(3)(b), Florida Administrative Code, the Office shall consider certain aggravating factors when determining whether a dt:viation from the range of penalties in the disciplinary guidelines is warranted. Pag~ Iii of23

82. Therefore, the Office is seeking an administrative fine of $4,375 and revocation of lkense. COUNT VIII

83. The above g~nernl allegations are hereby re-alleged and incorporated by reference as if fully stated herein.

84. Pursuant to section 560.l 14(1)(y), Florida Statutes, a money services business is prohibited from violating 31 C.F. R. section I 022.210, which requires each money services business to develop, implement, and maintain an effective Anti-Money Laundering Program ("AML") that is reasonably designed lo prevent the money services business from being used to facilitate money laundering and the finam:ing of terrorisl activities.

85. As part of the examination, the Office requested, and Respondents provided, an AML entitled, "Check Cashing Policies Anti~Money Laundering Compliance Policies and Procedures," dated January l , 2021.

86. In accordance with section 560.310(2)(a). Florida Statutes, and Rule 69V￾560. 704(4)(d), Florida Administrative Code, Respondents' AML contains a set:tion titled "Nev,.: Business Account Opening Verification Procedures" regarding items that must be included iu a corporate customer tile.

87. As part of its examination, and as detailed in Count II, the Office reviewed a sample of Respondents' corpora le customer files and found that all of them failed to include at least one of these required items, contrary to the policies and procedures in Respondents' A Ml ..

88. Tn accordance with section 560.309(5). Florida Statutes, Respondents' AML contains a list of Compliance Officer Duties and Responsibilities that includes "Ensuring that all SARs on behalf of th1: Company are accurate, complete and filed in a timely manner" P;,g.e 19 of 23

89. As part of its examination, and as detailed in Count TIT, the Office found that the total amount of checks cashed fi.ir some corporate customers in a particular year exceeded the check cashing limit set by Respondents, and further that Respondents failed to file any SARs, contrary to the policies and procedures in Respondents' AML.

90. When Respondents failed to maintain complete customer files, and when Respondents failed to file SARs when required, Respondents failed to implement their AML.

91. Respondents violated 31 C.f.R. section 1022.210, and thereby section 560.114(1 )(y), Florida Statutes, by failing lo develop, implement, and maintain an etlective Anti￾Money Laundering Program.

92. Pursuant to the Disciplinary Guidelines for Money Services Businesses Form OFR￾560-09, incorporated by reference in Rule 69V-560. I 000, Florida Administrative Code (2019), violation number 26, a licensee cited for violating section 560.114(1 )(y), Florida Statutes, is suhjcc.t to a "B" fine and revocation.

93. Therefore, the Office is seeking an administrative fine of $3,500 and revocation of license. COUNT IX

94. The above general allegations are hereby re-alleged and incorporated hy reference as though fully stated herein.

95. Pursuant to section 560.128( 1 ), Florida Statutes, each money services business must provide each customer with a toll-free telephone number for the purpose of contacting the money services business or, in lieu of a toll-free telephone number, the address and telephone number of the Office of Financial Regulation may be provided. Page 20 of23

96. As part of its examination, the Office conducted an on-site visit of the Respondents' location at 7061 Grand National Dr., Suite 115, Orlando, FL, 32819.

97. The Office found that neither a toll-free number for customers to reach Respondents' money services business, nor the address and telephone number of the Office of Financial Regulation, was provided for customers.

98. Respondents failed to provide each customer with a toll-free telephone number for the purpose of contacting the money services business or, in lieu of a toll-free telephone number, the address and telephone number of the Office, in violation of section 560.128(1 ), Florida Statutes.

99. Pursuant to the Disciplinary Guidelines for Money Services Businesses Form OFR￾560-09, incorporated hy reference in Rule 69Y-560.1000, Florida Administrative Code, violation number 51, a lic.ensee cited for a violation of section 560.128( l ), Florida Statutes, is subject to an "A" level administrative fine. I 00. Therefore, the Office seeks an administrative fine of $1,000. WHEREFORE, Respondents, CFL CONSULTING GROUP LLC. d/b/a MONEY AGENCY, and SOCORRO PIRES MOURA MENDES, and ANTONIO MONTEIRO .MENDES FILHO, arc hereby notified that lhe Office intends to enter an Order imposing an administrative fine of Twenty-Six Thousand Four Hundred Seventy-Five Dollars ($26,475), and revocation of money services business license number FT340001231. Page 21 of23

NOTICE ffF RlGHTS The licensee is entitled to he 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 .Vith 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 he filed as follows: B, 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 BY Hand J)clivcrv Agency Clerk Office of Financial Regulation Office of General Counsel The Fletcher Building 101 East Gaines Street Tallahassee, FL 32399 Phone: (850) 410-9889 TO PRESERVE THE RIGHT TO A HEARING, A WRJTTEN RESPONSE MUST RR FILED WITH THE OFFICE OF FINANCIAL REGULATION WJTHIN TWENTY￾ONE (21) DAYS AFTER THE RECEIPT OF THE ADMINISTRATIVE COMPLAINT. SAID RESPONSE MUST BE RECEIVED BY TUE OFFICE NO LATER THAN 5:00 P.M. ON THE TWENTY-FIRST DAY AFTER THE RECEIPT OF THE ADMINISTRATIVE COMPLAINT. A FAJLURE 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 foil to follmv 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. Page 22 uf23

NOTICE TO RESPONDENTS ln 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 Oftice ofFinancial Regulation, The Fletcher Building, 200 East Gaines Street, Tallahassee, Florida 32399, Phone: (850) 410-9889, or by Email: Agency.Clerk@flofr.gov. DATED and SIGNED this 18th day ofNovember, 2025. By: David J. Tarbert Florida Bar No. 778461 Senior Attorney Office of Financial Regulation Office of General Counsel 200 E Gaines Street Tallahassee, FL 32399 Tel: (813)218-5340 Email: David.Tarbert 'ii flofr.!.!ov CERTIFICATE OF SERVICE l HEREBY CERTIFY that a true and correct copy of the foregoing Administrative Complaint has been sent for service hy U.S. Certified Mail to CFL Consulting Group LLC. d/b/a Money Agency, and Socorro Pires Moura Mendes, and Antonio Monteiro Mendes Filho at 7061 Grand National Dr., Suite 115, Orlando FL 32819 (and by email at Cflconsultinggroupllc@gmail.com) on this 18th day of November, 2025. 9489 0090 0027 6620 8157 47 ~ David J. Tarbert Page 23 of2J

STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION Case No: 120520 CFL Consulting Group LLC. d/b/a Money Agency Socorro Pires Moura Mendes, and Antonio Monteiro Mendes Filho 7061 Grand National Or., Suite 115 Orlando FL 32819 ELECTION OF PROCEEDING 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: D I do !1Q! 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 adoptin_g the findings of fact and conclusions 9f law in the Adm inistrative Complain aod imll_osing the penalties sought in the Administrative Complaint. OPTION #2: 0 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 teleconfer™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. OPT!.Pf'!.tt?: 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 28-106.201S(S)(c), FAC, 1 am attaching a cony of the material facts that I djsn.Ue. If you selected Option tt2 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 S:00 P.M . QN OR BEFORE T!:i~.TWENTY-FIRST DAY 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. Signature of Respondent or Mai!ing Address Authorized Representative of Respondent Printed Name & Title City State Zip Date E-mail Address Telephone Number Form: OFR-GC-13 (rev. 11 .19.2024) Pagelof2

STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION Case No: 120520 CFL Consulting Group LLC. d/b/a Money Agency Socorro Pires Moura Mendes, and Antonio Monteiro Mendes Filho 7061 Grand National Dr., Suite 115 Orlando Fl 32819 0 VOU ARE TO COMPLETE THE FOLLOWING ONLY IF YOU HAVE CHECKED OPTION #3 ON THE PRECEDING PAGE. If you need more space, you may provide additional pages. As Respondent or the authorized representative of Respondent, I am disputing the following material facts: --- ---~----------- Signature of Respondent or Authorized Representative Date Form: OFR-GC-13 (rev. 11.19.2024) Page 2 of 2

=1orida Office of Financial Regulation 200 East Gaines Street ! Tallahassee, Florida 32399-0370 :lETURN SERVICE REQUESfEO 1111111 II 11 9489 □□ 90 0027 6620 8157 □ "' ~ 8 t:i ~J 31 CFL Consulting Group LLC. d/b/a Money Agency Attn: Antonio Monteiro Mendes Filho 7061 Grand National Dr., Suite 115 Orlando, FL 32819

STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re: CF'L CONSULTING GROUP LLC. D/B/A MONEY AGENCY, SOCORRO PIRES MOURA MENO.ES, and ANTONIO MONTEIRO MENDES FJLHO, Respondents. ADMINISTRATIVE COMPLAINT Case Number: 120520 The State of Florida, Office of Financial Regulation ("Office"), files this Administrative Complaint against CFL CONSULTING GROUP LLC. d/b/a MONEY AGENCY, and SOCORRO PIRES MOURA MENDES. and ANTONIO MONTEIRO MENDES FILI-1O (together "Respondents"), alleging: GENERAL ALLEGATIONS Pursuant to sections 560. l 05 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(l)(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, 111, and IV of chapter 560, Florida Statutes, set forth the specific requirements of money services husincsses and licenses.

4. Section 560.l l 1l(l)(a), Florida Statutes, among other things, holds an "aniliated party" responsible for complying with any and all provisions of chapter 560, Florida Statutes, or its related rules.

5. Section 560.103( I). Flmida Statutes, defines an "affiliated party" as, among other things, an officer, responsible person, or a person who has a controlling interest in a money services business.

6. Section 560.103( I O)(a) Florida Statutes defines a "control person" as, among other things, an owner, pn;sidcnl, or compliance officer of a money services business.

7. Section 560.103(6), Florida Statutes, defines a "check casher" as a person who sells currency in exchange for payment instruments received, except travelers' checks.

8. Pursuant to section 560.103(29), Florida Statutes. a "payment instrument" means a check, draft, warrant, money order, travelers check, electronic instrument, or other instrument used for the transmission, exchange, or payment of currency or monetary value.

9. At all times material, CFL Consulting Group, LLC. ('·CFL Consulting") is and has been licensed as a Part TIT Money Services Business (License No. FT30800193) pursuant to chapter 560, Florida Statutes. I 0. At all times material, CFL Consulting is and has been operating as a check casher., as defined in section 560. l 03(6), Florida Statute::;. 11 . At all times material, Socorro Pires Moura Mendes ("Mendes") is and has been the President and 50% owner of CFL Consulting, and by operation of law, pursuant to section 560.103(1), Florida Statutes, Mendes is an "affiliated party'' who is liable for any and all violations of CFL Consulting. Pnge 2 nf 23

10. At all times material, Antonio Monteiro Mendes Filho ("F ilho") is and has been the Compliance Officer and 50% owner of CFL Consulting, and by operation of law, pursuant to section 560.l 03( 1 ), Florida Statutes, Filho is an "affiliated party" who is liable for any and all violations of CFL Consulting.

11. The O1lice conducted an examination (Exam Number 115186) of CFL Consulting's business records and operations for the period of April l, 2021 to March 3 1, 2023 ("examination period'').

12. Respondents produced, or attempted to produce, specified do~umcnts in response to the Office's various records requests throughout the examination. Pursuant to section 560.1105, Florida Statutes, Respondents are required to maintain all information necessary for determining compliance with chapter 560 and related rules for 5 years. Therefore, all the payment instruments and business records referenced here were not only in Respondents' possession and control during the examination period, but Respondents are under a legal obligation to possess and continue to mainlain the subject records pursuant to section 560.11 OS, Florida Statules.

13. During the examination period, Respondents cashed 4,177 payment instruments with a total face value of $5,040,738.68 and collected $103,673.32 in check cashing fees.

14. There v.·ere 572 payment instruments selected to review for compliance, 218 of which were for over S 1,000. The Office found that 67 payment instruments produced by Respondents were duplicate check cashing database ("CCDB"J entries. The payment instruments reviewed for compliance are identified below.

• ·- Actual Actual Total Payment Transaction Transaction Check Total Number Date Order Number of Transaction Instrument I Check~ Amount Amount 8519785 12/30;2022 I 1 1 $1,432.57 I $1,432.57 8635576 1/27/2023 1 $1,398.83 _'. j_l,398.83 J Page3 Clf23

~ 25_69 2/24/2023 1 1 2747 5/6/2022 1 ··· -·- - -·- 8908970 3/24/2023 1 1 $1,375.81 $1,375.81 j 1 ; si,310.12 s1,310.12 I 1 $1,317.67 $1~317.67 I I 8841911 8782684 8106323 8101488 8026985 --· 7973975 7918000 - 8459681 8457422 7797069 8642650 8106233 8565260 7068896 7004596 3/10/2023 1 - - ·, 3 /24/2023 I _ 1 9/23/?022 !- .! 9/23/2022 1 9/2/2022 1 1 J $1,314.36 $1,314.36 ~ 1 $1,256.70 $1,256.70 1 $1,197.90 $1,197.90 --- ----+---- 1 $1,197.90 $1,197 ~ 1 1 ---+--$1_,2_00.00 . $1,200.QQ____ 8/19/2022 1 1 $1,200.00 $1,200.00 ...------+-- 8/6/2022 1 1 $1,200.00 I $1,200.00 12/16/2022 • 2 I 12/16/2022 1 7/7/2022 I 10 1/28/2023 1 . - 9/23/2022 1 • 1111120n I 1 1/3/2022 I 1 12/16/2021 I 1 2 -----s- 2~6,326.2s T s1,119.41 -i----- L I_ 1 l 2 45 1 $26,326.25 $7,119.41 1 --j $6,825.00 $145.00 I_ ss!337.75 Y!.3~ 7.1s $4,855.68 $4,855.68 -- $4,000.00 $4,000.00 - - ,. $2,161.55 $2,161.55 $2,079.35 $2,079.35 8476095 t 12/20/2022 1 8475461 12/20/2022 i 1 I. $2,818.75 $_2,818.75 $2,818.75 $2,818.75 8675733 8675347 8018236 8243762 6358660 8910370 8459681 8457422 6656183 6605279 8910591 8494823 - · ·• 2/4/2023 1 2 $8,547 .06 $2,741.98 -~ 2/4/2023 1 I 9/112022 +- i9 7 10/28/2022 1 6/5/2021 I 1 I 3/24/2023 1 , 2 - , - 2 2 58 1 1 $8,547.06 $2,741.98 _$9,39_5.o_o ~$_s1_0.oo i $5,718.52 $5,718.52 -l $38,940.00 $38,940.00 I -+--- $35,307.50 $25,000.00 12115;2022 I 1 2 $26,326.25 $19,206.84 - ' 12/16/2022 2 8/24/2021 j 1 ~----,----- ---i---2---+-1 $26,326.25 $19,206.84 1 $13,288.00 $13,288.00 ~- • - • a-- ' • •- - • • -- 8/17/2021 1 3;2412023 I 1 1 $13,288.00 $13,288.00 ---'------,- 1 s1s,ooo.oo I s1s,ooo.oo -- 12/23/2022 I 1 1 $12,820.20 1$12!820.20 8491538 12/_23/2022 I 1 1 7694853 6/10/2022 1 1 $12,820.20 $12,374.00 $12,374.00 $12,820.20 $12,374.00 $12,374.00 $9,587.00 76_9_3_11_2 _ ___;6/10.c/_2_02_2 _, _1 _j 1 6685620 9/11/2021 1 I 1 $9,587.00 >----+--- --t 6685468 9/11/2021 2 2 $15,944.00 $9,587.00 t ··- 6605277 8/7/2021 $9,144.70 I $9,144.70 ~ 7-0-41- 5-68--1- 2-'-/2-'-4/2021 1 -I __ 1 ___ $.c_l.c.... 0,-482.25 • I $10,482 .25 7041062 12/24/2021 j -~ - 1 $10,_48~.3~ : $10,482.25 7008044 12/17/2021 j 1 • 1 $10,325 .00 $10,325.00 Pugc 4 of23

7007809 1 1_2/17fl02_1 Hl0,325.00 $10,325.00 8910370 I 3/~~/2023 . 1 2 $35,307.50 -· $10,307.50 I §§22792 8/2412021 $13,288.oo $13,2ss.oo ~ 33190 3/29/2023.. 1 1 $10,000.0LJ $10,000.00 f 8665713 2/3/2023 , 1 ___ 1__ $10,000.00 $10,000.00 8665472 2/3/2023 1 1 I $10,000.00 $10,000.00 8 _5_1_06_6_7--+, _1-'-2/_28/2022 r 3 3 ,_B3..!3~2.00 $9,990.00 8510565 J 1_2/2~;2022 I 3 3 $23,342.00 $9,990.00 7612855 I 5/2012022 -I 1 1 $9,9so.oo $9,950.00 ----- - - I 1 1 $9,9so.oo $9,9so.oo -- 7608490 I 5/20/2022 - - • 8422150 12/9/202 2 • 1 1 I $9,900.00 $9,900.00 - 8422094 12/9/2022 1 1 I $9,900.00 $9,900.00 7960526 8/17/2022 1 --=--=- ..! -1 $9,900.00 $9,900.00 - 2 1 1 $9,900.00 I $9,900.00 --· -1-~--1---$9-,900.00 1 $9,900.00 7959903 8/17/202 7645838 5/28/2022 7645288 5/28/202 2 1 _ _ 1 $9,900.00 l _gJ!9o~ 7698469 ' 6/11/2022 1 1 $9,872.00 ! $9,872.00 --+-- - - - - - 7694306 6/10/2022 1 1 _ __ $9,872.00 ~-~!~72.00 . 7431810 ~§/~~22 1 1 [ $~~580.00 j $6,580.00 __ 1 1 $6,sso.oo I $6,5ao.oo 8565020 1/11/2023 1 2 $19,618.00 I $9,809.00 7429904 4/6/2022 . -- ,..?565020 j !/11/2023 2 2 1 $19,618.00 $9,809.00 8564810 I 111112023 •- - 1 -- 2 1$19,618.oo $9,&o9.oo I ,... 8564810 I 1111/2023 2 2 $19,618.00 $9,809.oo 7585126 l s;13;2022 1 - 1-- $9,ao4.oo $9,804.oo 7583974 5/13/2022 . +- 8642635 1/28/2023 8841949 3/10/2023 r 8841072 3/10/2023 8917551 3/25/2023 8783095 2/25/2023 8780503 -- -- 7975021 8/20/2022 7974770 8/20/2022 7974998 8/20/2022 7974821 8/20/2022 . 8449127 12/15/2022 8448852 12/15/2022 - 8632285 1/26/2023

• ·-- 8631285 1/26/2023 8553562 1/7/2023 1 3 1 4 1 $9,804.00 $9,804.00 __ $3_0_,8_8_1.99---+ $9,800.00 , $8,715.83 $8,715.8~ $~1_7_15_.8_3 $8,715.83 I $7,827.07 $7,827.07 $6,120.00 ~---~ $6,120.00 $6,120.00 l $6,120.00 $6,100.00 $6,000.00 1 1 $5,943.01 $5,943.01 T $5,943.01 $4,997.76 ----- 1 1 $4,997.76 1 1 $4,637.00 Page S of23 $5~~ j $4,997.76 $4,997.76 j $4,637.00

8553137 7973915 7969090 8548569 -- 8548259 1/7/2023 8/19/2022 8/19/2022 1/6/2023 1/6/2023 I 1 l 1 · - - - --t￾8659912 -- 1/31/2023 1 -- -~ 8657582 l/31/2023 1 8864799 3 /14/2023 1

• • 8864319 3 /14/2023 1 8737370 2 /17/2023 2 l 8736887 2 /17/2023 1 8459283 1 2/16/2022 1 8456216 l 2/16/2022 1 8753721 2 /21/2023 1 8753671 4 2 121L2023 1 8917788 3/25/2023 1 8841038 3/1012023 r 1 - - 8838539 3/9/2023 1 8836703 .. 3/9/2_02~ 1 8599853 1 . .). 1 2 2

1

1

J $4,637.00 $4,637.00 $3,292.88 $3,292.88 $2,755.00 $2,755.00 $2,470.00 $2 , 470 00 $1,852.00 $1,852.00 $2,517.50 $2,517.50 $1,337.25 $1,337.25 $1,330.00 $1,330.00 $3,292.88 $3,292.88 $2,755.00 $2,755.00 i_$2,470.00 $2 470 00 I I $1,852.00 $1,852.00 $1,615.00 $1,615.00 - - $1,337.25 $1,337.25 $1,330.00 $1,330.00 2 $2,425.50 $1,270.35

I 7 J

• 1 $1,260 .45 I $1,260.45 1 $1,240 .43 J__g,240.4~ 1 $!J4~ :~~ J $1,240.43 1 $1,227 .31 I $1,227.31 8580349 .31 8282498 1/14/2023 1/14/2023 I 111512022 1 $1,227 --1--------ll l $1,227.31 8280452 8211063 8210744 j 11/S/i022 f 10/21/2022 j 10/21/2-02_2 __ 1 j-?1,214 1 $1,214 1 1
• · _ ___. __ _ 1 1 $1,207 1 .18 I $1,214.18 .18 $1,214.18 - .65 $1,207.65 , __ _ .65 T 11512023 1/5/2023 1 4/8/2022 1 j $1,207 1 1 $1,227 ; $1,207.65 , 8541811 8541661 7442001 7438800 8519909 8517464 8728787 8728709 8917788 8656844 --- 8655697 8608464 8608166 8662122 8661467 8548405 1 .58 $1,227.58 1 1 $1,227 .58 $1,227.58
• 1 1 $1,185 .36 I $1,185.36 - 4/8/2022 1 1 $1,185 .36 i $1,185.36 f 12/30/2022 I 12;30;2022 1 1 .00 [ $1,200.00 .00 I $1,200.00 1 $1,200 -~--- 1 $1,200 i. 2/16/20:t3 I 2/16/2023 3/25/2023 . 1 1 2 .35 $1,141.35 .35 j $1,141.35 1 l $1,141 1 $1,141 2 s2,42s.50 __ $1, 1_ss.1s 1/31/2023 1 1 $1,124.62 $1,124.62 1/31/2023 1 1 $1,124.62 $1,124.62 ------- 1/20/2023 1 1 $1,097.55 $1,097.55 ~ .. -- 1/20/2023 1 1 $1,097.55 $1,097.55 2/2/2023
• • 1 1 $1,075.35 $1,075.35 I - -1---------- 2/2/2023 1 1 $1,075.35 $1,075.35 1/6/2023 -1 L 1 _ $1.~1.~ s1,os1:.?5 Page (, of23

8545401 I 1/6/202'}_ ~-1-~ __ 1 _ 8844219 3/10/2023 1 1 8842652 I 3/10/2023 1 1 --- 8337493 11/18/2022 8335799 11/18/2022 ~ I l- 8418509 12/8/2022 1 --j- 1 8418437 12/8/2022 1 1 7425050 I 4/4/2022 1 I 1~ 8459551 r1211G12022 J: 1 1--1 8459506 I 12/16/2022 I 1 - -1 1 --+------ 8457276 12/1612022 1 I 1 8394731 12/2/2022 ! 1 1 . ----- 8392151 121212022 I 1 I 1 -----· 833 7540 11/18/2022 -'"-· 1 j_ 1 8335773 1!£18/2~ .J:.... j 1 8273304_j 11/4J2022 1 I 1 8272654 11/4/2022 1 l 8281902 11/5/2022 8281078 11/5/2022 1 1 8790908 2/27/2023 1 -- 8790768 I 2/2112023 1 -~---- 8737370 : 2/17/2023 1 8736887 °2/17/20231 2 ~ 8_2_7_52_0_1~1_1_1/4/2022 _ 1~·~ 1 2 2 1 l i l,O_S_l.6_5 __ $1,0_5_1.65 I- s1,023.33 s1,023.33 , $1,023.33 $1,023.33 ♦• --,T- r $1,049.30 $1,0 49.30 - $1,049.30 $1,0 -- 49.30 15.04 15.04 50.00 40.00 40.00 $1,015.04 $1,015.04 $1,050.00 $1,040.00 - $1,040.00 --- - $1,040.00 $1,040.00 ,L $1,040.00 l $1,020.00 $1,020.00 $1,002.00 J_ $1,002.00 $1,031.94

$1,0 -, $1,0 40.00 , $1,0 40.00 I 40.00 j 40.00 $1,040.00 $1,020.00 $1,020.00 $1,002.00 $1,002.00 $1,031.94 ) -----+--- $1,031.94 j $2,517.50 $2,517.50 $1,214.18 $1,031.94 $902.50 $902.50 $1,214.18 1 7. The Office also reviewed these 5 of the 22 corporate cuslomer files that Respondents were required to maintain during the examination period. Page 7 llf23

18. As pare of the examination, Respondents met with the Olli cc for an exit conference on May 30, 2023.

19. After the examination was concluded, Respondents were sent a letlt!r dated September 28, 2023, attaching the Report of Examination. The letter specifically requested that Respondents "review the report and provide a written response to the [Office] ,vithin fifteen ( 15) business days." The letter further informed Respondents that their written response "may include advising the Oflice of any exceptions or disagreements with the report, any actions taken to correct the possible violations, and any mitigating circumstances you would like us to consider that might reflect the need for a lesser sanction in the event a violation has occurred."

20. The Report of Examination identified potential violations of the specific statutory provisions of chapter 560, Florida Statutes, and the accompanying rules of the Florida Administrative Code. For each finding, the Report of Examination also briefly stated how Respondents violated the applicable statute and/or rule. 21 Pursuant to Rule 69V-560. l 000(5), Florida Administrative Code, the range for an "A" level fine is between $1,000 and $3,500.

21. Pursuant to Ruic 69Y-560.1000(5), Florida Administrative Code, the range fi.>r a "B" level fine is between $3,500 and $7,500. 23 . Pursuant to section 560.114(1 )(a), florida Statutes, each money services business and its aflil iated patties must comply with all provisions of chapter 560, Florida Statutes, the Otlicc may revoke a money services business license for such failure to comply. COUNTI

22. The above general allegations arc hereby re-alleged and incorporated by reference as i frul ly stated herein. Page~ of23

23. Pursuant to section 560.310(2)( d), Florida Statutes, when payment instruments ("checks") over $1,000 are cashed, licensees are required to submit certain information into the check cashing database ("CCDB") before providing currency to the person cashing Lhe check.

24. Pursuant to section 560.3 I 0(2)( d), Florida Statutes, and Rule 69V-560. 704(5), Florida Administrative Code, among the infonnation required to be submitted into the CCDB are the following: • Transaction date; • Payor name; • Payee name; • Conductor's name; • Payment instrument amount; • Amount of currency provided; • Payment instrument type; • Check cashing fee; • Branch or location where the check was accepted; • Personal identification type and number presented by payee or conductor; • Payee's workers' compensation policy number or exemption certificate number; • Payee's Corporate Document Number issued by the Secretary of State; and, • Payee's Federal Employee Identification Number. 27 As part of its examination, and as detailed in the general allegations, the Office reviewed a sample Respondents' records for a sample of 572 of Respondents' check cashing transactions that were required to be submitted into the CCDB.

25. The Office found that 67 of the 572 ( 11 %) entries were duplicate entries of the same transaction.

26. During the examination period, Respondents entered inaccurate infomiation into the CCDB, in violation of section 560.310(2)(d), Florida Statutes, and Rule 69V-560.704(5), Florida Administrative Code.

27. Pursuant to the Disciplinary Guidelines for Money Services Businesses Form OFR￾560-09, incorporated by reference in Rule 69V-560. I 000, Florida Administrative Code (2019), r ~g.< 9 of23

violation number 96, a licensee cited for violating section 560.310(2)(d), Florida Statutes, is subject to an "A" level administrative fine and revocation of license. 31. Therefore, the Office is seeking an administrative fine of $1,300 and revocation of license. COUNT II 32. The above general allegations are hereby re-alleged and incorporated by reference as if fully stated herein. :n. Pursuant to section 560. 103( 11 ), Florida Statutes, a '"corporate payment instrument'' is a payment instrument (check) on which the payee named on the check's face is other than a natural person. 34. Pursuant to section 560.310(2)(a), Florida Statutes, licensees arc required to create and maintain a customer file for each entity listed as the payee on corporate checks accepted by the licensee that exceed $1,000. 35. Pursuant to Rules 69V-560.704(4)(d), Florida Administrative Code, each customer file must include the following information: • Documentation from the Secretary of State (so-called ''SUNBIZ") verifying registration as a corporation showing the listed officers and FEID registration number; • Articles oflncorporation or other such documentation which establishes a legal entity in vvhatcver form authorized by law. For purposes of this rule a sole proprietor operating under a fictitious name registered with the Secretary of State shall not have to present such documentation; • Documeniation of the business license/occupational lict:!nse, business tax receipt, or its equivalent from the county where the entity is located; • A copy of the search results screen page from Compliance Proof of Coverage Query Page wcbpagc from the Florida Dcpa1tmcnt of Financial Services - Division of Workers' Compensation website PHS'-' 1fl of 23

\ htrns://dwcdatanortal.fldfs.com/ProofOfCovera~e.aspx J: • If the entity has an active workers' compensation policy, the licensee must also maintain a copy of the policy declaration page or other document provided by the insurer indicating the amount of coverage; • Documentation of individuals authorized Lo negotiate payment instruments on the corporation or fictitious entity's behalf including corporate resolutions; and, • A written corporate customer profile which includes: the full legal name of each beneficial owner, as defined in 31 C.F.R. s. l 0 l 0.230(d), effective July 1, 20 I 8, is hereby incorporated by reference and available at httr ://www. flrules.orn/Gatewav/rcfcrenc~i!§QiNit=:R~.f: 1 J 4J:i4, of the corporate customer; an explanation of the customer's business model; typc(s) of services offered; projected annual volume of check cashing; and annual check cashing limits as they relate to the corporate customer's workers' compensation policy coverage limits. 36. As part of its examination, and as detailed in the general allegations above, the Office reviewed a sample of 5 of Respondents' corporate customer files and found the following: • Regarding the SlJNBIZ document, 3 of the 5 files reviewed <lid not contain this document; • Regarding the business tax receipt, in 5 of the 5 files this document was missing; • Regarding the proof of worker's compensation coverage, 5 of the 5 files failed to include this document; • Where an active workers' compensation policy existed, none of those customer files contained a copy of the policy declaration page or other document provided by the insurer indicating the amount of coverage; • Regarding the required written corporate customer pro tiles, Respondents failed to include an explanation of the customer's business model in all 5 files. 37. Respondents failed to maintain complete corporate customer files, in violation of section 560.310(2)(a), Florida Statutes, and Rules 69V-560.704(4)(d), Florida Administrative Code. 38. Pursuant to the Disciplinary Guidelines for Money Services Businesses Form OFR￾560-09, incorporated by reference in Rule 69V-560. l 000, Florida Administrative Code (2019), violation number 93, a licensee cited for violating section 560.3 I 0(2)(a), Florida Statutes, 1s subject to an ';A" level administrative fine and revocation of license. Page II of23

39. Therefore, the Office is seeking an administrative fine of $3,500 and revocation of license. COUNT III

40. The abow g1.:ncral allegations are hereby w-allcgcd and incorporated by reference as if fully stated herein.

41. Pursuant to section 560.3 l0(2)(a), Florida Statutes, a licensee must maintain customer files if the licensee is cashing payment instruments from the corporate customer that exceed $1,000. Pursuant to Rule 69V-560.704(4)(d)7., Florida Administrative Code, each customer file must contain a written corporate customer profile which sets an annual check cashing limit.

42. Pursuant to Rule 69V-560.609(4), Florida Administrative Code, check cashing transactions involving corporate payment instruments that exceed the annual check cashing limits set by the licensee are deemed suspicious and require the check casher to file a suspicious activity report ("SAR") for each transaction.

43. Pursuant to section 560.309(5), Florida Statutes, a licensee must report all suspicious activity to the Office, in accordance with the criteria in 31 C.F.R. 1022.320. Pursuant to Rule 69V-560.609(2), Florida Administrative Code, the Office has designated FinCEN as the appropriate regulator to receive the reports.

44. Pursuant ro Rule 69V-560.609(2), Florida Administrative Code, and 31 C.F.R. I 022.320, Florida check cashers are required to submit such suspicious activity reports ("SARs") lo FinCEN no later than thirty (30) calendar days after the date of initial detection of the facts that constitute the basis for filing the report. l'ag.- 12 of23

45. As a part of the examination, the Office reviewed a sample of 5 customer files where each file included the customer-specific annual check cashing limit sel by Respondents.

46. The Office found that, for 3 of the 5 corporate customers, lhe total amount of checks cashed for that corporate c-U!itomcr in lhal particular year exceeded the annual limit set, as detailed below. Check Date Check Corporate Cashing Cashing Date Check Value of Checks Amount Check Customer Limit (Year Limit Cashing Limit Cashed During Cashing Limit was and Set Reviewed This Period* Exceeded By Amount) 0812022 - $1 ,089.85 2021- 01/1312022 09i2022 - $11.957.65 $35.000 09·30-2021 Ol/1 J:2023 $329,120.95 I 0/2022 - $983.50 (Monthly) 11 /2022 - $8.500 TOTAL- $22.531.00 08/2021- $20,368.70 2021- I 1/2021 - $22,019.25 $25,000 01 /07/2021 01 /07.-·2022 $182,394.55 12/2021 - $11,877 TOT AI , - $54,265 08/2021 - $26,250 2021 - 08.'30/2021 07.041 2022 $77.718.93 03/2022 - $7.500 $10,000 04 ·2022 - $6,453.60 TOTAL - $40 204 4 7. The Office also reviewed Respondents' finCEN filings, and no SA Rs reporting this activity were filed by Respondents within 30 days.

47. Respondents failed to file SARs when the total of checks cashed by corporate customers exceeded the check cashing limits established for them by Respondents, in violation of section 560.309(5), Florida Statutes, and Ruic 69V-560.609(4), Florida Administrative Code.

48. Pursuant to the Disciplinary Guidelines for Money Services Businesses Form OFR￾560-09, incorporated by reference in Ruic 69V-560.I000, Florida Administrative Code (2019),

violation number 86, a licensee cited for violating section 560.309(5), Florida Statutes, is subject to a "B" fine and revocation of license. 50. Th(!rcfore, the Office is seeking an administrative fine of $7,500 and revocation of license. COUNT IV 51 The above general allegations arc hereby re-alleged and incorporated by reference as if fully stated herein. 52. Rule 69V-S60.704(3)(b), Florida Administrative Code, requires that every check casher maintain, among other things, a daily cash reconciliation summarizing each day's activities and reconciling cash on hand at the close of business for that day. The rule further provides that the daily cash reconciliation shall be sufficiently detailed to provide an audit trail of each day's business ac1ivity. 53. During the examination, the Office requested Respondents' daily cash reconciliations records. On April 13, 2023, Respondents submitted a signed statement indicating that the requested records could not be located, and that Respondents had no reasonable basis to believe they existed. 54. Respondents failed to maintain daily cash reconciliations, in violation of Rule 69V￾560. 707(3)(h), Florida Administrative Code, and thereby section 560.114(1 )(a), Florida Statutes. 55. Pursuant to the Disciplinary Guidelines for Money Services Businesses Form OFR￾560-09, incorporated by reference in Ruk 69V-560.IO00, Florida Administrative Code (2019), violation number 3, a licensee cited for violating section 560.114(1 )(a), Florida Statutes, is subject to an "A" level administrative fine and revm:ation of license. Page J4 of2J

56. Therefore, the Office is seeking an administrative fine of $1,500 and revocation of lil:ense. COUNTV

57. The above general allegations are hereby re-alleged and incorporalcd by reference as if fully stated herein. 5 8. Pursuant to section 560. l 26(3), Florida Statutes, and Ruic 69V-560.201 (3 ), Florida Administrative Code, a licensee must report any change in the partners, officers, members, joint venturers, directors, controlling shareholders, or responsible persons of the licensee, or changes in the form of business organization, within 30 days through an amended license application.

58. As part of its examination, the Office reviewed Respondents' Application for Licensure as a Money Services Business, and any amendments, and documents regarding ownership of Respondents' business.

59. The Orne~ found that Respondents' October 5, 2022 amended application stated ownership as Socorro Pires Moura Mendes with 97% and Antonio Monteiro Mendes Filho with 3%.

60. The Office found further that Resrondents' "Management Operating Agreement," effective January 1, 2020, states the ownership as Socorro Pires Moura Mendes with 97% and Christianne Barbosa Almeida with 3%.

61. Further, Respondents' "First Amendment to Operating Agreement," adopted January 1, 2022, changed the ownership to Socorro Pires Moura Mendes with 50% and Antonio Monteiro Mendes Filho with 50%. Page 15 r,f23

62. Therefore, Respondents vvere untimely in notifying the Ofiicc of changes in ownership \Vith both their October 5, 2022 and May 29, 2023 amended applications, as detailed below. r Application Jnfonnation Summ~ Main Business Address Names of Owners ;7061 Grand National Dr, Suite 115 Socorro Pires Moura Mendes Orlando, FL 32819 ,-- - - • --- --- ; 7061 Grand National Dr, Suite I 115 Urlando, FL 3_~~19 __ Antonio Monteiro Mendes Filho Soc.orro Pires Moura Mendes Antonio Monteiro Mendes Filho Date of Application 10-05/2022 05.29/2023 Days Late -~ - Percentage Reported to __, _1te Qffic~ 97% 03% 50% 50% '277 Days Latr 5 13 Days Lat!

63. Respondents failed to report change in the partners, officers, members, joint venturers, direcrors, controlling shareholders, or responsible persons of the licensee, or changes in the fonn of business organization, within 30 days through an amended license application, in violation of section 560.126(3), Florida Statutes, and Rule 69V-560.20 I (3), Florida Administrative Code.

64. Pursuant to the Disciplinary Guidelines for Money Services Businesses, Form OFR-560-09, inc-orporated by reference in Ruic 69V-560.1000, Florida Administrative Code (2019), violation number 48, a licensee citt:d for violating section 560.126(3), Florida Statutes, is subject to an "A" level administrative fine.

65. Therefore, the Otlice is seeking an administrative fine in the amount of $2,000. COUNT VI 67 The above general allegations are hereby re-alleged and incorporated by refcrcnre as if fully stated herein. Page J(i of 23

66. When a payment instrument of greater than $1,000 is cashed, section 560.3 J 0(2)(b ). Florida Statutes, and Rule 69V-560.704(4)(c), Florida Administrative Code, require a licensee to maintain a legible copy of acceptable personal identification that bears a photograph of the cus(omer.

67. Pursuant to section 560.310(2)(b). Florida Statutes, acceptable personal identification is limited to a valid driver license, a state identification card issued by any state of the United States or its territories or the District of Columbia and showing a photograph and signature, a United States Government Resident Alien Tdentification Card, a passport, or a United States Military identification card.

68. As part of its examination, and as detailed in the general allegations, there were 572 payment instruments selected to review for comp I iance, 218 of which were for over $ I ,000. The Office found that 67 payment instruments produced by Respondents were duplicate CCDB entries; therefore, the Office reviewed Respondents' records for a sample of 151 payment instruments cashed that were owr $1,000. The Office also reviewed copies of the personal identification that had been presented by customers \Vhen they cashed those payment instruments.

69. The Office found that for 51 of the 151 (33%) transactions. Respondents failed lo maintain copies of valid, acceptable identifications. The Office 48 found instances in which the identification was not one of the acceptable forms, and 3 instances in which Lhe identification was expired.

70. Respondents failed to maintain records of acceptable personal identifications, in violation of section 560.310(2)(b), Florida Statutes.

71. Pursuant to the Disciplinary Guidelines for Money Services Businesses Form OfR￾560-09, incorporated by reference in Rule 69V-560. I 000, Florida Administrative Code (2019). Pagr 17 of23

violation number 94, a licensee cited for violating section 560.310(2)(b), Florida Statutes, is subject to an "A" level administrative fine and revocation of license. 74. Therefore, the Office is seeking an administrative fine of $1,800 and revocation of license. COUNT VU 75. The above general allegations are hereby re-alleged and incorporated by reference as if fully stated herein. 76. Pursuant to seclion 560.309(2), Florida Statutes, when licensees cash checks, they are required to endorse them with their legal name. 77. As part its examination, and as detailed in the general allegations, the Office reviewed Respondents' records for a sample of 572 payment instruments cashed during the examination period. 78. The Office found that 572 of the 572 ( I 00%) checks reviewed were not endorsed with Respondents' legal name. 79. Respondents failed to endorse all cashed checks with their legal name. in violation of section 560.309(2), Florida Statutes. 80. Pursuant to the Disciplinary Guidelines for Money Services Businesses Form OFR￾560-09, incorporated by reference in Rule 69V-560. l 000, Florida Administrative Code (2019), violation number 83, a licensee cited for violating section 560.309(2), Florida Statutes, is subject to an "A" level tine and revocation of license. 81 Pursuant to Rul1.: 69V-560-l 000(3)(b), Florida Administrative Code, the Office shall consider certain aggravating factors when determining .vhethcr a deviation from the range of penalties in the disciplinary guidelines is warranted. Page l!I of23

82. Therefore, the Office is seeking an administrative fine of S4,375 and revocation of license. COUNT VIII

83. The above general allegations are hen.:by n.;-alkged and im:orporated by reference as if fully stated herein.

84. Pursuant to section 560.114(1 )(y), Florida Statutes, a money scrvi~es business is prohibited from violating 31 C.F. R. section I 022.210, which requires each money services business to develop, implement, and maintain an effective Anti-Money Laundering Program ("AML") that is reasonably designed to prevent the money services business from being used to facilitate money laundering and the financing of terrorist activities.

85. As part of the examination, the Office requested, and Respondents provided, an AML entitled, "Check Cashing Policies Anti-Money Laundering Compliance Policies and Procedures," dated January I, 2021.

86. In accordance with section 560.310(2)(a). Florida Statutes, and Rule 69V￾560.704(4)(d), Florida Administrative Code, Respondents' AML contains a section titled "New Business Account Opening Verification Procedures" regarding items that must be included in a corporate customer file.

87. As part of its examination, and as detailed in Count II, the Office reviewed a sample of Respondents' corporate customer files and found that all of them failed to include at least one of these required items, contrary to the policies and procedures in Respondents' AML.

88. In accordam:c ·with section 560.309(5), Florida Statutes, Respondents' AML contains a list of Compliance Officer Duties and Responsibilities that includes "Ensuring that all SA Rs on behalf of th~ Company are accurate, complete and filed in a timely manner." Page 19 of23

89. As part of its examination, and as detailed in Count lll, the Otlicc found that the total amount of checks cashed for some corporate customers in a panicular year exceeded the check cashing limit set by Respondents, and further that RcspondenL'i failed to file any SARs, contrary to the polkics and procedures in Respondents' AML.

90. When Respondents failed to maintain complete customer files. and when Respondents failed to fik SA Rs when required, Respondents failed to implement their AML. 9 l. Respondents violated 31 C.F.R. section 1022.210, and thereby section 560.114( 1 )(y), Florida Statutes, by failing to develop, implement, and maintain an effective Anti￾Money Laundering Program.

91. Pursuant to the Disciplinary Guidelines for Money Services Businesses Form OFR￾560-09, incorporated by reference in Rule 69V-560. I 000, Florida Administrative Code (2019), violation number 26, a licensee cited for violating section 560.114( I )(y), Florida Statutes, is subject to a "B" fine and rcvocalion.

92. Therefore, the Office is seeking an administrative fine of $3,500 and revocation or license. COUNT IX

93. The above general allegations are hereby re-alleged and incorporated by reference as though fully stated herein.

94. Pursuant to section 560.128(1 ), Florida Statutes, each money services business must provide each customer with a toll-free telephone number for the purpose of contacting the money services business or, in lieu of a toll-free telephone number, the address and telephone number oflhe Office of Financial Regulation may be provided. Page 20 of23

95. As part of its examination, the Office conducted an on-site visit of the Respondents' location at 7061 Grand National Dr., Suite 115, Orlando. FL, 32819.

96. The Office found that neither a toll-free numher for customers to reach Respondents' money services business, nor the address and telephone number of the Office of Financial Regulation, was provided for customers.

97. Respondents failed to provide each customer with a toll-free telephone number for the purpose of contacting the money services business or, in lieu of a to I I-free telephone number, the address and telephone number of the Office, in violation of section 560.128(] ). Florida Statutes.

98. Pursuant to the Disciplinary Guidelines for Money Services Businesses Form OFR￾560-09, incorporated hy reference in Rule 69V-560. l 000, Florida Administrative Code, violation number 51, a licensee cited for a violation of section 560.128( I), Florida Statutes, is subject to an "A" level administrative fine. I 00. Therefore. the Office seeks an administrative fine of $1 ,000. WHEREFORE, Respondents, CFL CONSULTING GROUP LLC. d/b/a MONEY AGENCY, and SOCORRO PIRES MOURA MENDES, and ANTONIO MONTEIRO MENDES FILHO, are hereby notified that the Office intends to enter an Order imposing an administrative line of Twenty-Six Thousand Four Hundred Seventy-Five Dollars ($26,475), and revocation of money services business I iccnse number FT340001231 Page 21 of23

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 pursuantto sections 120.569 and 120.57, Florida Statutes. Such request must comply v,dth Rules 28-106.2015 and 28-106.1 04, Florida Administrative Code. An Election of Proceeding form is attached for your convenience. Any such request must be filed as follows: B\ 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 B, Hand Deliven Agency Clerk Office of Financial Regulation Office of General Counsel The Fletcher Building 10 I East Gaines Streel Tallahassee, FL 32399 Phone: (850) 410-9889 TO PRESERVE THE RIGHT TO A HEARING, A WRITTEN RESPONSE MUST BE FILED WITH THE OF:ncE OF FINANCIAL REGULATION WITHIN TWENTY￾ONE (21) DAYS AFTER THE RECEIPT OF Tiffi ADMINISTRATIVE COMPLAINT. SAID RESPONSE MUST BE RECEIVED BY THE OFFICE NO LATER THAN 5:00 P.M. ON THE TWENTY-f'IRST DAY AFTER THE RECEIPT OF THF. 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. Pugc 22 of2J

NOTICE TO RESPONJ>ENTS In accordance with the Americans with Disabilities Act, persons with disabilities needing special accommodation to particiratc in this proceeding should contact the Agency Clerk no later than seven (7) days prior to the tiling 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@1lofr.gov. DATED and SIGNED this -- 18th day ofNovembcr, 2025. . By: David J. Tarbert Florida Bar No. 778461 Senior Attorney Office of Financial Regulation Office of General Counsel 200 E Gaines Street Tallahassee, FL 32399 Tel: (813)218-5340 Email: David.Tarbert'u flofr <!ov CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Administrative Complaint has been sent for service by U.S. Certified Mail to CFL Consulting Group TLC. d/b/a Money Agency, and Socorro Pires Moura Mendes, and Antonio Monteiro Mendes Filho at 7061 Grand National Dr., Suite 115, Orlando FL 32819 (and by email at Ctlconsultinggroupllc@gmail.com) on this 18th day of November, 2025. pt;· <==>-- 9489 0090 0027 6620 8157 30 David J. Tarbert Page23 of23

STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION Case No: 120520 CFL Consulting Group LLC. d/b/a Money Agency Socorro Pires Moura Mendes, and Antonio Monteiro Mendes Filho 7061 Grand National Dr., Suite 115 Orlando FL 32819 ELECTION OF PROCEEDING 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: 0 I 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~- final order ado tin the f n in s of fact and conclusfons of law In the Administrative Complaint, and imposing the penalties sought in the Administrative Complaint. OPTION #2: 0 I QQ 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. 0 Submit a written statement with supporting documentation to a Hearing Officer appointed by the Office. QF>JION #3: 0 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 cony 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: 0 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 DAY 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. Signature of Respondent or Mailing Address Authorized Representative of Respondent Printed Name & Title City State Zip Date E-mail Address Telephone Number Form: OFR-GC-13 (rev. 11.19.2024) Page 1 of 2

STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION Case No: 120520 CFL Consulting Group LLC. d/b/a Money Agency Socorro Pires Moura Mendes, and Antonio Monteiro Mendes Filho 7061 Grand National Dr., Suite 115 Orlando FL 32819 **VOU ARE TO COMPLETE THE FOLLOWING ONLY IF YOU HAVE CHECKED OPTION #3 ON THE PRECEDING PAGE. If you need more space, you may provide additional pages. As Respondent or the authorized representative of Respondent, I am disputing the following material facts:

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Signature of Respondent or Authorized Representative Date Form: OFR-GC-13 (rev. 11.19.2024) Page 2 of2

Fron,: To: Subject: Date: auto-repfy@usos.com USPS® Item Jivered, Left with Individual 9489009000276620815730 Monday, December 1, 2025 1:44:15 PM Hello David Tarbert, EXHIBIT B Your item was delivered to an individual at the address at 12:05 pm on November 24, 2025 in ORLANDO, FL 32819. Tracking Number: 9489009000276620815730 Package Shipped from: PITNEY BOWES SPARK Delivered, Left with Individual

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