Final Order — Money Services Business

Index: OFR 2026-524

DOCKETED 10/29/2026
LEGAL BH

STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION

In Re:
ATM OPS INC.,
D/B/A BISTOP, and
ANDREW C. BARNARD,
Respondents.
Case Number: 132517

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 29th day of October, 2026, in Tallahassee, Leon County, Florida.

Russell C. Weigel, III
Commissioner

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing Final Order has been furnished by electronic mail to Counsel for Respondents, Jonathan Greenberg, Esquire, at jon@lalchandanisimon.com and Kuhs Lalchandanisimon@kubs@lslawpl.com on this Y ~ ay of October, 2026.

30th

Agency Clerk
Office of Financial Regulation
Post Office Box 8050
Tallahassee, FL 32314-8050
Tall~ e, FL 32314-8050
Email: Agency.Clerk@flofr.gov
Tel: (850) 410-9889

Exhibit A

STATE OF FLORIDA
OFFICE OF FINANCIAL REGULATION

In Re:
ATM OPS INC.,
D/B/A BITSTOP, and
ANDREW C. BARNARD,
Respondents.

Case Number: 132517

STIPULATION AND CONSENT AGREEMENT

The State of Florida, Office of Financial Regulation ("Office"), and ATM OPS INC., D/B/A BITSTOP, and ANDREW C. BARNARD (together "Respondents"), in consideration of the mutual promises herein, recite, stipulate, and agree as follows:

1. Background. At all times material, ATM OPS INC., d/b/a BITSTOP, is and has been licensed as a Part II Money Services Business pursuant to chapter 560, Florida Statutes, operating as a foreign currency exchanger and money transmitter as defined in section 560.103(24), Florida Statutes, under License Number FT230000131 since February 16, 2015.

At all times material, Andrew C. Barnard is and has been the President, Chief Executive Officer, Director and Treasurer of ATM OPS INC. By operation of law, pursuant to section 560.103(1), Florida Statutes, Andrew C. Barnard is an affiliated party who is liable for all violations of ATM OPS INC.

The Office conducted an examination (No. 127586) to ascertain Respondents' compliance with chapter 560, Florida Statutes, and the corresponding rules.

On October 30, 2025, the Office issued an Administrative Complaint ("Complaint"). The Complaint was served by U.S. certified mail on May 7, 2026. The parties have reached an agreement and are herein resolving the matters at issue.

2. Jurisdiction. The Office is the state agency charged with the administration and enforcement of chapter 560, Florida Statutes, and the rules promulgated thereunder. The Office has jurisdiction to bring this action against Respondents pursuant to chapter 560, Florida Statutes.

3. Findings. For purposes of this Stipulation and Consent Agreement, Respondents neither admit nor deny but consent to the Office making the following findings:

a) Respondents failed to amend their initial application to report a change in bank accounts within 30 days of the change, in violation of Rule 69V-560.201 (2), Florida Administrative Code, and section 560.126(2), Florida Statutes;

b) Respondents failed to timely amend their initial application to report a change in control person, in violation of Rule 69V-560.201(3), Florida Administrative Code, and section 560.126(3), Florida Statutes;

c) Respondents failed to implement the provision of their AML program pertaining to transaction monitoring, pursuant to page 71 of their AML program effective as of February 7, 2023, and page 78 of their AML program effective as of January 9, 2024. Respondents failed to implement the provision(s) pertaining to transaction monitoring in violation of section 560.114(1)(y), Florida Statutes, which prohibits any violation of 31 C.F.R. Chapter X and United States Treasury Interpretive Release 2004-1; and

d) Respondents failed to maintain monthly financial institution statements and reconciliation records for a bank account in violation of section 560.211(1)(d), 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 they have read this Stipulation and Consent Agreement and fully understand the rights, obligations, terms, duties, and responsibilities with respect to its contents.

Therefore, in compromise and settlement of the foregoing findings and in consideration of the Office's forbearance from further litigation, Respondents agree to the following terms and conditions:

a. FUTURE COMPLIANCE. Respondents agree that they shall cease and desist from violations of chapter 560, Florida Statutes, and the rules promulgated thereunder, and comply with all provisions of chapter 560, Florida Statutes, and the rules promulgated thereunder.

b. ADMINISTRATIVE FINE. Respondents agree to pay the Office an administrative fine in the amount of Seven Thousand Dollars ($7,000.00), 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 or money order made payable to "Office of Financial Regulation" and reference Case No. 132517 and be sent to the attention of Agency Clerk - c/o Damaris Reynolds, 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 560 and 120, Florida Statutes.

6. Waiver. By Respondents' consent to the entry of a Final Order with respect to this proceeding, Respondents waive:

a) Any right to separately stated Findings of Fact and Conclusions of Law;

b) Any right to receipt of a Notice of Rights pursuant to chapter 120, Florida Statutes;

c) Any right to an administrative hearing or issuance of a Recommended Order pursuant to chapter 120, Florida Statutes; and

d) Any right to contest in any administrative forum or judicial proceeding (including, but not limited to, an appeal pursuant to section 120.68, Florida Statutes) the validity of any term, condition, obligation, or duty expressly created in this Stipulation and Consent Agreement and the Final Order.

7. Releases. Upon full execution of this Stipulation and Consent Agreement, Respondents waive, release, and forever discharge the Office and its agents, representatives, and employees from any and all causes of action, in law or in equity, which Respondents may have arising 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.

10. Severability. The parties agree that if any provision of this Stipulation and Consent Agreement or the application thereof to any person or circumstance is held invalid, the Stipulation and Consent Agreement will be given effect without the invalid provision, and to this end, the provisions of this Stipulation and Consent Agreement are declared severable.

11. Counterparts. This Stipulation and Consent Agreement may be executed in any number of counterparts, and by the parties in separate counterparts, each of which will be deemed to be an original but all of which together will constitute but one Stipulation and Consent Agreement. Copies of this Stipulation and Consent Agreement transmitted by facsimile or electronic mail shall have the same validity as if bearing an original signature.

12. Entire Agreement. This Stipulation and Consent Agreement represents the entire agreement by and between Respondents and the Office. Any alterations, variations, changes, modifications, or waivers of the provisions hereof shall be valid only when they have been reduced to writing, duly signed by the Office and Respondents hereto, attached to the original of this Stipulation and Consent Agreement, and subject to the approval of the Office.

WHEREFORE, in consideration of the foregoing, the Office and Respondents execute this Stipulation and Consent Agreement for entry of a Final Order on the last date executed below.

Name: ANDREW C. BARNARD
State of Florida
County of Miami-Dade
Title: President Chief Executive Officer,
Director and Treasurer

ANDREW C. BARNARD, as President, Chief Executive Officer, Director and Treasurer of ATM OPS INC., D/B/A BITSTOP, BEFORE ME by means of ☐ physical presence or ☐ online notarization, has sworn ( or affirmed) that he has read and understands the foregoing agreement and voluntarily signed the same.

SWORN TO AND SUBSCRIBED before me this 30th day of September, 2026. , 2026.

MICHAEL CARRILLO
MV COMMISSION f HH 335512
EXPIRES: February 6, 2027
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Notary Public

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Personally known if
OR Produced Identification D
Type of identification produced D Driver's License D Passport D Other ______ _ (Do not include ID number) OFFICE OF FINANCIAL REGULATION 8 ;&~1.m, Date: 10/29/2026 , 2026.
----------- Bill Morin, Interim Director
Division of Consumer Finance
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