Final Order — Money Services Business

Index: OFR 2026 - 481 ....
DOCK
9/30/2026
LEG~
STATE OF FLORIDA
OFFICE OF FINANCIAL REGULATION
In Re:
MONEYWAYS LLC, Case Number: 135591
Respondent.
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 3t:74.. day of September, 2026, in Tallahassee, Leon County, Florida. Commissioner

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing Final Order has been furnished by email to counsel for Respondents: Marta Colomar Garcia, Esquire, at mcolomar@diazreus.com and Juan Villa, Esquire, at jvilla@diazreus.com on this ~ ay of September, 2026.

• Regulation
  32314-8050
  Email: Agency.Clerk@flofr.gov
  Tel: (850) 410-9889

~I Pactima
Digitally Certified Document
Full name MICHEL NICOLAS
Commission ID HH692754
Country us - State FL
County Miami Dade
II I II IIIII Ill II II I II II I IIIII II I Ill II II I Ill 1111111111111111 II I Ill II I IIII IIII I II I 111111111111111 Ill I II I IIII 1111111111111111 Ill Ill lllllllllll I II IIIII IIII I II Ill llll I II II Ill lllll lllll I 111111111111111 llll ~~tl~i1~MII Exhibit A As part of Pactima's Digital Certification program, the identity of the notary listed above was verified and validated. The various validations included knowledge-based authentication, identity verification, and more. This certification was done based the PACTJMA_ISSUED_V1 PK! standard. To confirm the validity of this document contact Pactima's Compliance team via compliance@pactima.com.

Paclima eNotary (RON) Package ID: Vf71Q3_A-eiuJ93oWnU_C STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re:
MONEYWAYS LLC, Case Number: 135591
Respondent.
STIPULATION AND CONSENT AGREEMENT
The State of Florida, Office of Financial Regulation ("Office"), and MONEYW A YS LLC, ("Respondent"), in consideration of the mutual promises herein, recite, stipulate, and agree as follows:

1. Background. At all times material hereto, Respondent is and has been a Part II Money
   Services Business in the State of Florida, having been issued license number FT230000356. At all material times hereto, Enrique Masia and Alejandro Gonzalez are and have been directors and managing members of Respondent and each owns a 20.4% ownership interest in Respondent. Armando Millan is also a director/member of Respondent who owns a 20.4% ownership interest in Respondent. Mr. Masia, Mr. Gonzalez, and Mr. Millan have been authorized by Respondent to be the signatories to this Stipulation and Consent Agreement. The Office conducted an examination (No. 130820) to ascertain Respondent's compliance with chapter 560, Florida Statutes. In lieu of initiating a formal proceeding, the parties are herein resolving the matters at issue.
2. Jurisdiction. The Office is the state agency charged with the administration and
   enforcement of chapter 560, Florida Statutes, and the rules promulgated thereunder. The Office has jurisdiction to bring this administrative action against Respondent pursuant to chapter 560, Florida Statutes.
3. Findings. For purposes of this Stipulation and Consent Agreement, Respondent
   neither admits nor denies but consents to the Office making the following findings:

a) Respondent failed to possess at all times permissible investments of at least the aggregate face amount of all outstanding money transmissions in violation of section 560.210(1 ), Florida Statutes, during 2023 and 2024; b) Respondent failed to timely submit its 2023 Security Device Calculation Form in violation of Rule 69V-560.402, Florida Administrative Code, and section 560.114(1 )(a), Florida Statutes; c) Respondent failed to report changes in financial information within thirty days of the change, in violation of Rule 69V-560.201 (2), Florida Administrative Code, and thereby section 560.126(2), Florida Statutes; d) Respondent failed to report the removal of or change in control person(s) of the licensee and failed to timely report the addition of a compliance officer, in violation of Rule 69V￾560.201 (3), Florida Administrative Code, and thereby section 560.126(3), Florida Statutes; e) Respondent failed to file a Location Notification Form reporting commencement of an authorized vendor within sixty days in violation of Rule 69V-560. l 07(1 ), Florida Administrative Code, and section 560.l 14(1)(a), Florida Statutes; f) Respondent failed to develop and implement written policies and procedures to monitor compliance with applicable state and federal law by its authorized vendor(s), in violation of Rule 69V-560.703(4), Florida Administrative Code, and section 560.2085(3), Florida Statutes; g) Respondent failed to maintain, review, and update an effective anti-money laundering ("AML") program in violation of section 560.1235(2), Florida Statutes; and h) Respondent failed to implement its AML program, specifically its policies and procedures as it relates to providing training to the company's seven directors, in violation of 31 C.F.R. 1022.210 and section 560. l 14(1)(y), Florida Statutes.

Pactima eNotary (RON) Package ID: Vf7tQ3_A-eiuJ93oWnU_C
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, Respondent agrees to the following terms and conditions:
a. FUTURE COMPLIANCE. Respondent agrees to cease and desist from future violations of chapter 560, Florida Statutes, and the rules promulgated thereunder, and comply with all the provisions of chapter 560, Florida Statutes, and the rules promulgated pursuant thereto. b. ADMINISTRATIVE FINE. Respondent agrees to pay an administrative fine in the amount of Twenty Thousand Dollars ($20,000.00), 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." Such payment shall reference Case Number 135591 and shall be sent to the attention of Agency Clerk - c/o Damaris Reynolds, Post Office Box 8050, Tallahassee, Florida 32314-8050. Respondent acknowledges and agrees 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. Respondent consents to the entry of a Final Order, which incorporates
the terms of this Stipulation and Consent Agreement. Respondent understands and agrees 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

Pactima eNotary (RON) Package ID: Vf71Q3_A-eiuJ93oWnU_C 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 Respondent's consent to the entry of a Final Order with respect to this
proceeding, Respondent waives:
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 J 20, 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 J 20.68, 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, Respondent
waives, releases, and forever discharges the Office and its agents, representatives, and employees from any and all causes of action, in law or in equity, which Respondent may have arising out of this matter. The Office accepts this release and waiver by Respondent 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. Respondent acknowledges, concurs, and stipulates that
Respondent's 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 J 20 and 560, Florida Statutes. Such non-compliance may

Pactima eNotary (RON) Package ID: Vf71Q3_A-eiuJ93oWnU_C result in the issuance of an emergency cease and desist order. However, nothing herein shall be construed to limit Respondent's right to contest any finding or determination of non-compliance.
9. Attorne''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. Severabilit . 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 Respondent 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 Respondent 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 Respondent execute this Stipulation and Consent Agreement for entry of a Final Order on the last date executed below.

Pactima eNotary (RON) Package ID: Vf7tQ3_A-eiuJ93oWnU_C MONEYWAYS LLC:
(Signature)
Name: ENRIQUE MASIA
State of-'--'Fl~o~rid~a._____ ___ _
County of Miami Dade
Date: 08/28/2026
Title: Director/Managing Member and 20.4%
Owner ofMoneyways LLC, as authorized by
Moneyways LLC
Enrique Masia, as Director/Managing Member and 20.4% Owner for Moneyways LLC, as authorized by Moneyways LLC, 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~ ::-:A:::::11u_t1~-,u•fl----: ... t_;;.;_ ... -_-..... ~-~-.~., 2026. Notary Public Check the appropriate box:
Personally known D
OR Produced Identification ~
Type of identification produced D Driver's License ~ Passport D Other _____ _ (Do not include ID number)

Pactima eNotary (RON) Package ID: Vf71Q3_A-eiuJ93oWnU_C MONEYWAYS LLC:
(Signature)
Name: ALEJANDRO GONZALEZ
State of~Fl~o=rid=a~----
County of Miami Dade
Date: 08/28/2026
Title: Director/Managing Member and 20.4%
Owner ofMoneyways LLC, as authorized by
Moneyways LLC
Alejandro Gonzalez, as Director/Managing Member and 20.4% Owner for Moneyways LLC, as authorized by Moneyways LLC, BEFORE ME by means of D physical presence or q 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--2!L_ day of August , 2026. The foregoing instrument was acknowledged before me by means of Online Notarization : - ~ ~ -tile-.--.-- .--. - - By: Alejandro Gonzalez Molina ___ ....,._ ~ - - _ ,;. ____ __, ______ _ Check the appropriate box:
Personally known D
OR Produced Identification ~
Type of identification produced D Driver's License ~ Passport D Other _______ _ (Do not include ID number)

Pactima eNotary (RON) Package ID: Vf7tQ3_A-eiuJ93oWnU_C MONEYW AYS LLC:
(Signature)
Name: ARMANDO LUIS MILLAN
State of ~fl=o~rid=a~----
County of Miami Dade
Date: 08/28/2026
Title: Director/Member and 20.4% Owner ofMoneyways LLC, as authorized by Moneyways LLC Armando Luis Millan, as Director/Member and 20.4% Owner of Moneyways LLC, as authorized by Moneyways LLC, BEFORE ME by means of D 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~ day of_A_u~gu_st ___ -,--_,, 2026.

• • ~ - ~-~--~ The foregoing instrument was acknowledged before me by means of Online Notarization :
    By: Armando Luis Millan Ferro
    ~ ----- Notary Public
    Check the appropriate box:
    Personally known D
    OR Produced Identification ~
    Type of identification produced D Driver's License ~ Passport D Other _______ _ (Do not include ID number) OFFICE OF FINANCIAL REGULATION f3 ;It~~ Interim Director Grogs~• C. Oaks, Direo~er Division of Consumer Finance Date: 9/29/2026