Final Order — Money Services Business

Index: OFR 2026 - 397 STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION / DOCKE.TEO \ 8/7/2026 EGA.I. In Re: MMFL FLORIDA LLC, and MAHBUBUR RAHMAN, Case Number: 120534 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 conc]udes 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 7..µ,_ day of August, 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 to Brian D. Hess by electronic mail at brian@pcblaw.net.com on this ~ day of August, 2026. Agenc Cl Offi o • anci egul~ion P, t ce B9x805~ allahasse~ 50 Email: Agency.Clerk@flofr.gov Tel: (850) 410-9889 2

Exhibit A STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re: MMFL FLORIDA LLC, and MAHBUBUR RAHMAN, Case Number: 120534 Respondents. STIPULATION AND CONSENT AGREEMENT The State of Florida, Office of Financial .Regulation ("Office''), and MMFL FLORIDA LLC, and MAHBUBUR RAHMAN (together as "Respondents"), in consideration of the mutual promises herein, recite, stipulate, and agree as follows:

1. Baekgropnd. At all times material hereto, MMFL Florida LLC is and has been licensed as a Part III Money Services Business pursuant to chapter 560, Florida Statutes1 operating as a check casher, holding license number FD40001146. Mahbubur Rahman is and has been the President, Compliance Officer and Sole Owner of MMFL Florida LLC. The Office conducted an examination (No. 111994) of Respondents' business records and operations to ascertain compliance with chapter 560, Florida Statutes for the period of July 1, 2020, t~ough June 30, 2022. In lieu of continuing formal proceedings, the parties are 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 rules promulgated tberewider. The Office has jurisdiction to bring this administrative action against Respondents pursuant to chapter 560, Florida Statutes.
3. Findings. For purposes of this Stipulation and Consent Agreement, Respondents • neither admit nor deny but consent to the Office making the following findings:

a) Respondents failed to timely enter required information into the check cashing database ("CCDB"), or entered inaccurate infotmation1 in violation of section 560.310(2)(d), Florida Statutes, and Rule 69V￾560.704(5), Florida Administrative Code; b) Respondents failed to timely and accurately file Currency Transaction Reports ("CTR,,), as required by rule, in violation of section S60.123(3.)(c), Florida Statutes; c) Respondents failed to maintain and deposit payment instruments into their own commercial account with only control persons as authorized signatories, in violation of section 560.309(3), Florida Statutes, and Rul~ 69V-560.704(1)(b), Florida Administrative Code; d) Respondents failed to timely renew and maintain their Financial Crimes Enforcement Network ("FinCEN") registration, in violation of the requirements of 31 C.F.R. section 1022.380, which is a violation of section 560.1235(1), Florida Statutes; e) Respondents failed to maintain daily cash reconciliations and to reconcile cash on hand at the close of business, in violation of Rule 69V￾560. 704(3)(b )3 ., Florida Administrative Cod~, and thereby section S60.l 14(l)(a), Florida Statutes; f) Respondenm failed to maintain a legible copy of the front and back of each payment instrument cashed, in violation of sections 560.310(1) and 560.1105, Florida Statutes. and Rule 69V-560.704(2)(a), Florida Administrative Code; 2

' g) Respondents failed to timely report changes in the infonnation contained in their application by filing an amendment, in violation of section 560.126(2), Florida Statutes; h) Respondents failed to maintain records oflegible, valid, and acceptable personal identification presented by the customer, in violation of section 560.310(2)(b), Florida Statutes; i) Respondents failed to maintain required records relating to returned payment instruments, in violation of Rule 69V-560.704(3)(a)l. and 5., Florida Administrative Code, and thereby in violation of section 560.l 14(l)(a), Florida Statutes; j) Respondents failed to maintain complete customer files on all customers who cash corporate payment instruments, in violation of section 560.310(2)(a), Florida Statutes, and Rule 69V-560.704(4)(d), Florida Administrative Code; k) Respondents failed to endorse all cashed checks with Respondents• legal name, in violation of section 560.309(2), Florida Statutes;

1. Respondents failed to maintain records of customers' thumbprints, in violation of section 560.310(2)(c), Florida Statutes, and Rule 69V￾560.704(4)(a), Florida Administrative Code; and, m) Respondents failed to develop, implement, and maintain an effective Anti-Money Laundering Program, in violation of 31 C.F .R. section 1022.210, and thereby section 560.l 14(1)(y), Florida Statutes. 3

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. Th~refore, 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. AGREEMENT NOT TO CASH CERTAIN CHECKS. Respondents agree not to cash corporate payment instruments as defined in section 560.103(11), Florida Statutes, for a period of ten years from the date of the Final Order. b. ADMINISTRATIVE FINE. Respondents agree to pay the Office an administrative fine in the amount of Thirty Thousand Dollars ($30,000.00), 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 fonn of a wire, cashier's check or money order made payable to "Office of Fi11m1cial Regulation. " Such payment shall reference Case Number 120534 and shall be sent to the attention of Agency Clerk~ c/o David Tarbert, 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. 4

5. Final Order. Respondents consent to the entry of a Final Order, which incorporates the tenns 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 cl1apter 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 Statute~) 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 5

itselt 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 acJmowledge, concur, and stipulate that Respondents' failure to comply with any of the terms, obligations and conditions of this Stipulation and Consent Agreemen~ 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 prosec.µtion, 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 cmmterparts, 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, 6

modifications, or waivers of the provisions hereof shall be valid only when they have been reduced to writing, duly signed by the Office and Respondents hereto, attached to the original of this Stipulation and Consent Agreement, and subject to the approval of the Office. WHEREFORE, in consideration of the foregoing, the Office and Respondents execute this Stipulation and Consent Agreement for entry of a Final Order on the last date executed below. [this space intentionally left blank with signah,res appearing on the following page J 7

MMFLFLORIDA LLC,: Meh~r (Signature) ~ Name: Mahbubur Rahman Title: President, Compliance Officer and Sole Owner State of F \ orf AA County of Ba./ Mahbubur Rahman, as President, Compliance Officer and Sole Owner of MMFL Florida LLC., BEFORE ME by means of )lphysical presence or Q online notarization, has sworn (or affirmed) that be or she has read and understands the foregoing agreement and voluntarily signed the same. SWORN TO AND SUBSCRIBED before me this_J_ day of J W '-/ , 2026. LISAM. CARSTENS MY COMMISSION # HH 506197 EXPIRES: April 8, 2028 ;f~m,~ Notary Public Check the appropriate box: Personally known D OR Produced Identification ~ Type of identification produced B ofvfr;s License D Passport D Other _____ _ (Do not include ID number) 8

MAHBUBURRAHMAN: MJi~kv (Signature) ~ Name: Mahbubur Rahman State of Flor, ~ County o~ Baj Mahbubur Rahman, BEFORE ME by means of~ physical presence or Q online notarization. has sworn (or affirmed) that he or she has read and understands the foregoing agreement and voluntarily signed the same. ore me this_·l _ day of ' du '" 1 , 2026. ;f~ iYl~~ Notary Public Check the appropriate box: PersonalJy known D OR Produced ldcntification 0' FL￾Type of identification produced 0 Driver's License 0 Passport D Other _____ _ (Do not include ID number) OFFICE OF FINANCIAL REGULATION Gregory C. Oaks, Director Division of Consumer Finance 9 Date: 8/3/2026