Final Order — Money Services Business

Index: OER 2QJJ.o-2 lo<? STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re: EURO EXCHANGE CORP Case Number: 111052 D/B/A EURO EXCHANGE USA, and LUIS GASPARINI, Respondents. FINAL ORDER This cause came on for consideration and final agency action. Upon review of the record and being otherwise fully advised in the premises, the Office of Financial Regulation ("Office") hereby finds:

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

CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Final Order has been furnished to Euro Exchange Corp d/b/a Euro Exchange USA, and Luis Gasparini, by electronic mail at luigi@euroexchange.com, luisgasp@aol.com on this1JAay of May, 2026. Office of Financial Regulation Post Office Box 8050 Tallahassee, FL 32314-8050 Email: Agency.Clerk@flofr.gov Tel: (850) 410-9889 2

ST ATE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re: EURO EXCHANGE CORP d/b/a EURO EXCHANGE USA, and LUIS GASPARINI, Respondents. Exhibit A Case Number: 111052 STIPULATION AND CONSENT AGREEMENT The State of Florida, Office of Financial Regulation (the "Office"), and EURO EXCHANGE CORP d/b/a EURO EXCHANGE USA ("EEC") and LUIS GASPARINI ("Gasparini") (collectively "Respondents"), in consideration of the mutual promises herein, recite, stipulate, and agree as follows: I. Background. At all times material EEC is and has been licensed as a money services business authorized to operate as a money transmitter pursuant to Part II, chapter 560, Florida Statutes, including the authority to operate as a foreign currency exchanger pursuant to Part III, chapter 560, Florida Statutes, having been issued license number FT20800062 by the Office on March 13, 2001. EEC's license is not due to expire until April 30, 2028. At all times material Gasparini is and has been the Chairman of the Board of Directors and sole owner of EEC. In 2019, the Office's Division of Consumer Finance ("Division") conducted an examination (No. 94850) to ascertain Respondents' compliance with chapter 560, Florida Statutes, and its related rules. The Office determined that grounds existed to initiate an administrative proceeding against Respondents based on findings made subsequent to I) the Division's 2019 examination and 2) Respondents' 2022 document production made in response to the Division's follow-up records request concerning certain of the 2019 findings. In 2025, the Division conducted a periodic examination (No. 131059), in part, to determine whether certain deficiencies identified

during the 2019 examination had since been adequately remedied. One such deficiency pe11ained to section 560.208(4), Florida Statutes, which requires a money transmitter licensee such as EEC to place customer assets in segregated accounts at federally insured financial institutions. During 2019 and 2020, however, EEC listed one account held at a foreign financial institution on the license application where EEC was required to list all accounts used for licensed activity, i.e., those used to deposit and transmit customer funds. On November 26, 2025, the Office issued a three-count Administrative Complaint ("Complaint") to Respondents, alleging violations of chapter 560, Florida Statutes, and its related rules. Respondents filed a time~y request for an administrative hearing, along with a request to engage in settlement negotiations. During the parties' settlement communications, Respondents amended EEC's license application to clarify that in the future only federally insured financial institutions - not foreign financial institutions-would be used for licensed activity. Respondents further clarified this matter by submitting a written statement to the Office which represented that "all customer funds are deposited and maintained exclusively in FDIC-insured institutions .... [and n]o customer funds are held, pooled, or exposed in non-FDIC insured accounts." In lieu of conducting an administrative hearing, the parties are herein resolving the matters at issue in the Complaint, including those allegations which pertain to findings made in examination numbers 94850 and 131059. 2. Jurisdiction. The Office is the state agency charged with the administration and enforcement of chapter 560, Florida Statutes, and its related rules. The Office has jurisdiction to bring this administrative action against Respondents pursuant to chapter 560, Florida Statutes. 3. Findings. For the purposes of this Stipulation and Consent Agreement, Respondents neither admit nor deny, but consent to the Office's findings that Respondents: a. Failed to timely and accurately file currency trnnsaction reports in violation 2

of sections 560.114(1) and 560.123(3)( c ), Florida Statutes, and Rule 69V-560.608, Florida Administrative Code; b. Failed to place assets that are the property of its customers in segregated accounts in a federally insured financial institution and maintain separate accounts for operating capital and the clearing of customer funds, in violation of section 560.208(4), Florida Statutes; and c. Failed in eight (8) instances to timely report to the Office a change in the closing and opening of the bank accounts through which they conducted money services business within 30 days of such occurrence, in violation of section 560.126(2), Florida Statutes. 4. Terms and Conditions. The parties agree that the issues raised can be expeditiously resolved without further litigation by the execution of this Stipulation and Consent Agreement. The parties acknowledge that they have read this Stipulation and Consent Agreement and fully understand the rights, obligations, terms, duties, and responsibilities with respect to its contents. Therefore, in compromise and settlement of the foregoing findings and in consideration of the Office's forbearance from further litigation, Respondents agree to the following terms and conditions: a. FUTURE COMPLIANCE. Respondents agree that they shall cease and desist from violations of chapter 560, Florida Statutes, and its related rules, and comply with all the provisions of chapter 560, Florida Statutes, and its related rules. b. ADMINISTRATIVE FINE. Respondents agree to pay the Office a total administrative fine in the amount of Eighteen Thousand Dollars ($18,000.00), to be paid at the time of the execution and delivery of this Stipulation and Consent Agreement. This administrative fine shall be submitted in the form of a wire, cashier's check, m· 3

money order made payable to "Office of Financial Regulation. "Such payment shall reference Case Number 111052 and shall be sent to the attention of Agency Clerk - c/o Attorney George Bedell, Post Office Box 8050, Tallahassee, Florida 32314-8050. Respondents acknowledge and agree that in accordance with section 215.31, Florida Statutes, regarding the deposit of monies: (i) the tendered fine or settlement check may be deposited in advance of full execution or acceptance of the Stipulation and Consent Agreement; and (ii) such deposit shall not be construed as a final acceptance of the Stipulation and Consent Agreement absent full execution thereof and entry of a Final Order adopting same. 5. Final Order. Respondents consent to the entry of a Final Order, which incorporates the terms of this Stipulation and Consent Agreement. Respondents understand and agree that this Stipulation and Consent Agreement is subject to the final approval of the Office of Financial Regulation and the entry of the Final Order adopting such Agreement. In the event that the Final Order is not entered, this Stipulation and Consent Agreement shall be null and void. The Final Order incorporating this Stipulation and Consent Agreement constitutes final action by the Office for which the Office may seek enforcement pursuant to the provisions of chapters 120 and 560, Florida Statutes. 6. Waiver. By Respondents' consent to the entry of a Final Order with respect to this proceeding, Respondents waive: a. Any right to separately stated Findings of Fact and Conclusions of Law; b. Any right to receipt of a Notice of Rights pursuant to chapter 120, Florida Statutes; c. Any right to an administrative hearing or issuance of a Recommended Order pursuant to chapter 120, Florida Statutes; and d. Any right to contest in any administrative forum or judicial proceeding (including, but not limited to, an appeal pursuant to section 120.68, Florida Statutes) the validity of any term, 4

condition, obligation, or duty expressly created in this Stipulation and Consent Agreement and the Final Order. 7. Releases. Upon full execution of this Stipulation and Consent Agreement, Respondents waive, release, and forever discharge the Office and its agents, representatives, and employees from any and all causes of action, in law or in equity, which Respondents may have arising out of this matter. The Office accepts this release and waiver by Respondents on behalf of itself, its agents, representatives, and employees without acknowledging, and expressly denying, that any such right or cause of action may exist. 8. Failure to Comply. Respondents acknowledge, concur, and stipulate that Respondents' failure to comply with any of the terms, obligations and conditions of this Stipulation and Consent Agreement, and the Final Order adopting it, is a violation of the written agreement and the Final Order entered pursuant to chapters 120 and 560, Florida Statutes. Such non￾compliance may result in the issuance of an emergency cease and desist order. However, nothing herein shall be construed to limit Respondents' right to contest any finding or determination of non-compliance. 9. Attorney's Fees. Each party herein shall be solely responsible for its separate costs and attorney's fees incurred in the prosecution, defense, or negotiations in this matter up to and including the entry of the Final Order adopting this Stipulation and Consent Agreement. I 0. Severability. The parties agree that if any provision of this Stipulation and Consent Agreement or the application thereof to any person or circumstance is held invalid, the Stipulation and Consent Agreement will be given effect without the invalid provision, and to this end, the provisions of this Stipulation and Consent Agreement are declared severable. 11. Counterparts. This Stipulation and Consent Agreement may be executed in any number of counterparts, and by the patties in separate counterparts, each of which will be deemed 5

to be an original but all of which together will constitute but one Stipulation and Consent Agreement. Copies of this Stipulation and Consent Agreement transmitted by facsimile or electronic mail shall have the same validity as if bearing an original signature. 12. Entire Agreement. This Stipulation and Consent Agreement represents the entire agreement by and between Respondents and the Office. Any alterations, variations, changes, modifications, or waivers of the provisions hereof shall be valid only when they have been reduced to writing, duly signed by the Office and Respondents hereto, attached to the original of this Stipulation and Consent Agreement, and subject to the approval of the Office. WHEREFORE, in consideration of the foregoing, the Office and Respondents execute this Stipulation and Consent Agreement for entry of a Final Order on the last date executed below. [this section i11te11tio11a/ly left bla11k,followetl by signatures 011 next page] 6

GE CORP d/b/a EURO EXCHANGE USA: Title: Chairman of the Board of Directors and sole owner of Euro Exchange Corp d/b/a Euro Exchange USA State of Florida . J) 1 . County of M JA11:t, i e-,U/2- . Luis Gasparini, as Chairman of the Board of Directors and sole owner of Euro Exchange Corp d/b/a Euro Exchange USA, BEFORE ME by means of ~sical presence or D online notarization, has sworn (or affirmed) that he has read and understands the foregoing agreement and voluntarily signed the same. SWORN TO AND SUBSCRIBED before me thisJ!l day of May, 2026. Check the appropriate box: Personally known D / OR Produced Identification ~ Type of identification produced D ~•s License ~Passport D Other ____ __ _ (Do not include ID number) 7

LUIS GASPARINI: Jii/fa: Date: ----"t)_ $ - ~/ ~ij -- 2L) _ 2--,,,.? __ State of Florid~ . " }" County of~M_._._1....,A-=---M..,.,__,~..c...-= Luis Gasparini, BEFORE ME by means of ~sical presence or □ online notarization, has sworn (or affirmed) that he has read and understands the foregoing agreement and voluntarily signed the same. SWORN TO AND SUBSCRIBED before me this Check the appropriate box: Personally known D / OR Produced Identification~ Type of identification produced D ~ 's License tsa'Passpo1t D Other _ ____ _ (Do not include ID number) OFFICE OF FINANCIAL REGULATION Date: 5/22/2026 mar Agarwal .. #HH308796 res: September 25, 2026 tary Public • Sta• of Florida ~ m?.ks~ir~~ ----------- Division of Consumer Finance 8