Final Order — Money Services Business

Index: OFR 2026 - 252
STATE OF FLORIDA
OFFICE OF FINANCIAL REGULATION
CltETEO \
4/2026
EG~t.
In Re:
KOBTRANSFER, LLC, and
JEAN ALEX ST. SURIN,
Case Number: 133239
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 ~ 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 by electronic mail to Counsel for Respondents, Gabriella Carballo at gcarballo@avilalaw.com and Patricia M. Hernandez at phernandez@avilalaw.com on this /,5--/-"'- day of May, 2026. 2 cial Regulation ox 8050 Tallah ssee, FL 32314-8050 Email: Agency.Clerk@flofr.gov Tel: (850) 410-9889

ST ATE OF FLORIDA
OFFICE OF FINANCIAL REGULATION
In Re:
KOBTRANSFER, LLC, and
JEAN ALEX ST. SURIN,
Respondents.
Exhibit A
Case Number: 133239
STIPULATION AND CONSENT AGREEMENT
The State of Florida, Office of Financial Regulation ("'Office"), and KOBTRANSFER, LLC, and JEAN ALEX ST. SURIN (together "Respondents"), in consideration of the mutual promises herein, recite, stipulate, and agree as follows:

1. -Background. At all times material, Kobtransfer, LLC ( .. Kobtransfer"), is and has
   been licensed as a Part rr Money Services Business pursuant to chapter 560, Florida Statutes, operating as a money transmitter as defined in section 560.103(24 ), Florida Statutes, under License Number FT23000368. At all times material, Jean Alex St. Surin is and has been the Sole Owner and Chief Executive Officer of Kobtransfer. By operation of law, pursuant to section 560.103( I), Florida Statutes, Jean Alex St. Surin is an affiliated party who is liable for all violations of Kobtransfcr. The Office conducted an examination (Examination Number 128614) to ascertain Respondents' compliance with chapter 560, Florida Statutes, and the corresponding rules, for the period of April I, 2023, through March 31, 2025 ("'Examination period"). On November 5, 2025, the Office issued an Administrative Complaint ("Complaint"). The Complaint was served via U.S. certified mail on November 7, 2025. 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 place the property of a customer in a segregated account in a federally insured FDIC institution in violation of section 560.208( 4 ), Florida Statutes; b) Respondents failed to maintain monthly financial institution statements for two bank accounts in violation of section 560.211 ( l )( d), Florida Statutes; c) Respondents failed to renew their Money Services Business registration with the Financial Crimes Enforcement Network ("FinCEN") in violation of 31 C.F.R. section 1022.380(b) and section 560.1235( I), Florida Statutes; d) Respondents failed tu prepare and maintain a list of agents as required by FinCEN in violation of 31 C.F.R. 1022.380(d)( I) and section 560.211(1 )(g), Florida Statutes; e) Respondents failed to timely notify the commencement uf several vendors in violation of section 560.2085( 1 ), Florida Statutes, and rule 69V-560. l 07( l )(a), Florida Administrative Code; f) Respondents failed to timely report the addition of two bank accounts. Respondents also failed to timely report the removal of two bank accounts in violation of section 560.126(2), Florida Statutes, and rule 69V-560.102(5), Florida Administrative Code; g) Respondents failed to report the appointments of their Vice President and Chief Compliance Officer in violation of section 560.126(3), Florida Statutes, and rule 69V-560.20 I, Florida Administrative Code; 2

h) Respondents failed to maintain the net worth required by section 560.209(1), Florida Statutes, in violation of section 560.209( I), Florida Statutes; i) Respondents failed to obtain an annual FAR for the fiscal year ending in 2024 and submit it to the Office within 120 days after the end of the fiscal year in violation of rule 69V-560.606(2), Florida Administrative Code, and section 560.209(2), Florida Statutes; j) Respondents failed to maintain complete money transmission logs, in violation of rule 69V-560.703(1), Florida Administrative Code, and thereby section 560.l 14(1)(a), Florida Statutes; k) Respondents failed to maintain an effective AML program in violation of 31 C.F.R. l 022.210 and section 560.1235(2), Florida Statutes; I) RespondenL-. failed to implement the provision of their AML program which required them to ensure that their computer program blocked or flagged OF AC transactions accurately and also failed to maintain a compliance officer. Respondents' failure to implement their AML program constituted a violation of 31 C.F.R. I 022.21 0(d)( I )(i), 31 C.F.R. 1022.210(d)(4), and thereby section 560.114(l)(y), 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. TI1e parties acknowledge they have read this Stipulation and Consent Agreement and fully understand the rights, obligations, tenns, duties, and responsibilities with respect to its contents. TI1erefore, in compromise and settlement of the foregoing findings and in consideration of the Office's forbearance from further litigation, Respondents agree to the following tenns and conditions:
3

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. LICENSE SURRENDER. Respondents shall voluntarily surrender their money services business license (License Number FT23000368). The license termination shall be effectuated by the Office on the date that the Final Order adopting and incorporating this Stipulation and Consent Agreement is entered. At that time, any and all rights and privileges pertaining to those holding such license shall terminate.
c. FUTURE APPLICATION. Respondents, Kobtransfer and Jean Alex St. Surin,
each shall not act as an affiliated party of any money services business licensed or required to be licensed by the Office, nor shall Respondents apply for any license pursuant to chapter 560, Florida Statutes, for a period of 15 years from the date of entry of the Final Order adopting this Stipulation and Consent Agreement. The fact that Respondents are not barred by the terms of this agreement from thereafter submitting any such application should not be construed as offering any opinion, suggestion, or insinuation concerning whether such license might be granted by the Office. Any application will be evaluated in the usual statutorily established manner. The facts surrounding this Stipulation and Consent Agreement may be fully considered in any future licensing requests. d. ADMINISTRATIVE FINE. Respondents agree to pay the Office an administrative fine in the amount of Two Thousand Five Hundred Dollars ($2,500.00), 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 4

made payable to "Office of Financial Regulation " 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 5

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 fu)I 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 accept.:; 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. 6

I 0. SeverabiJity. The patties 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 counterpa1ts, 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. [this space intentionally left blank with signatures appearing on the following page} 7

KOBTRANSFER, LLC:
Name: JEAN ALEX ST .. SURIN Title: Sole Owner and Chief Executive Officer State of ::y'C￾County of ~0::-~--;J,._ JEAN ALEX ST. SURJN, as Sole Owner and Chief Executive Officer ofKOBTRANSFER, LLC, BEFORE ME by means o~sical presence or O onlinc 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./u_ day of /}ftl L~ ~ . N6tary Public .-·~:,.,,1 •11.-··... ANDRES GARCIA {f~-, Notary Public - State of Florida Check the appropriate box: ~4'./ commission II HH 416405 ··-... fl.'.,f;'.• •• My Comm. Expires May 24, 2027 Personally known 0 OR Produced TdentificationL Type of identification produced ~r's License 0 Passport 0 Other ______ _ (Do not include ID number) 8 , 2026.

Name: JEAN ALEX ST. SURfN
S talc of ::::;f?:' L..
County of ~ c-....)--V--d{., •
JEAN ALEX ST. SURIN, BEFORE ME by means o~sical presence or □ onlinc 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 /ftJ!t l . , 2026. Notfuoy ~ Public Check the appropriate box:
Personally known D
OR Produced Identificat~
... ,;:w··~· -~-,. ANDRES GARCIA t
-;.{ ,Z; Notary PubUc • State of Flori,J,1 ;
~ 0
$,..- Commission # HH 41 640~ ,
Type of identification produced~er's License
D Passport
·····~-~--·· My Comm. Expires May 24. lUF !,
D Other _______ _
(Do not include JD number)
OFFICE OF FINANCIAL REGULATION
4-~c.()~
Gregory C. Oaks, Director
Division of Consumer Finance
Date: 5/11/2026
9