Final Order — Money Services Business

Index: OFR 2026 - 353
STATE OF FLORIDA
OFFICE OF FINANCIAL REGULATION
In Re:
RAFE BROS LLC, and
AMRO ABUELUF,
Case Number: 134589
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 tenns of the Stipulation and Consent Agreement. DONE and ORDERED this )4* day of July, 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 Rafe Bros LLC and Amro Abueluf, by electronic mail to their Attorney of Record:
Kelley S. Roark, Esq. at kelleysroark@gmail.com on this ~ ay of July, 2026. 2 n al Regulation X 8050 L 32314-8050 .Clerk@flofr.gov Tel: (850) 410-9889

STATE OF FLORIDA
OFFICE OF FINANCIAL REGULATION
In Re:
RAFE BROS LLC AND
AMRO ABUELUF,
Respondents.
EXHIBIT A
Case Number: 134589
STIPULATION AND CONSENT AGREEMENT
The State of Florida, Office of Financial Regulation ("Office"), and RAFE BROS LLC and AMRO ABUELUF ("Respondents") in consideration of the mutual promises herein, recite, stipulate, and agree as follows:
1. Background. Rafe Bros LLC is licensed as a money services business, having been
issued license number FT340001313, pursuant to chapter 560, Florida Statutes. Amro Abueluf is the Sole Owner and Manager of Rafe Bros LLC. The Office conducted an examination (examination number 130951) to ascertain Respondents' compliance with chapter 560, Florida Statutes, for the period of July I, 2023 through June 30, 2025. Based on the examination, grounds existed to initiate an administrative proceeding against Respondents pursuant to chapter 560, Florida Statutes, and on March 12, 2026, the Office issued an Administrative Complaint. Respondents submitted a timely response. The parties are resolving the issues herein with this Stipulation and Consent Agreement in lieu of a formal proceeding in this matter.
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 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 finding that:
a. Respondents failed to timely renew their registration with the Financial Crimes Enforcement Network ("FinCEN'), in violation of section 560.1235(1 ), Florida Statutes; b. Respondents failed to timely submit a Currency Transaction Report ("CTR") to FinCEN, as required by rule, in violation of section 560.123(3)(c), Florida Statutes;
c. Respondents failed to maintain copies of acceptable personal identifications
("IDs") and accepted invalid IDs at the time of the check cashing transaction, in violation of section 560.310(2)(b ), Florida Statutes; d. Respondents failed to maintain records of customers' tbumbprints, in violation of
section 560.310(2)( c ), Florida Statutes;
e. Respondents failed to endorse cashed checks with their legal name, in violation of
section 560.309(2), Florida Statutes;
f. Respondents failed to report accurately required check cashing transaction information into the Check Cashing Database ("CCDB"), in violation of section 560.310(2)(d), Florida Statutes; g. Respondents failed to maintain records of check cashing transactions where the checks were returned due to non-sufficient funds, in violation of Rule 69V-560.704(3)(a), Florida Administrative Code, and thereby in violation of section 560.114(1)(a), Florida Statutes; h. Respondents failed to maintain their corporate customer files, in violation of Rule 69V-560.704(4), Florida Administrative Code, and section 560.310(2)(a), Florida Statutes; and,
1. Respondents failed to pay the examination fee, which was due on January 5, 2026,
in violation of section 560.l 14(1)(t), Florida Statutes.
2

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 not violate any provision of chapter 560, Florida Statutes, and the corresponding rules, and they shall comply with
chapter 560, Florida Statutes, and corresponding rules.
b. ADMINISTRATIVE FINE. Respondents agree to pay the Office an administrative fine in the amount of Ten Thousand Two Hundred Dollars ($10,200.00) 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 shall be sent to the attention of Agency Clerk - c/o Attorney Maria A. Guitian, 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.
c. ADDITIONAL REGULATORY REQUIREMENT. Respondents agree to not
cash corporate payment instruments or checks for a period of ten (10) years from the date of entry of the Final Order adopting this Stipulation and Consent Agreement. 3

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 with respect to the findings identified in Section 3 above 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; d. Any right to an administrative hearing or issuance of a Recommended Order pursuant to chapter 120, Florida Statutes; and e. 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. 4

8. Failure to Complv. 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 detennination of non-compliance.
9. Attorney Fees. Each party herein shall be solely responsible for its separate costs
and attorney 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. 5

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. RAFE BROS LLC:
Name: Amro Abueluf
State of H o(ic{o-... ----,-~-=-,---- -
County of_tt£- D~ d~~----~ __
Date: __ l.;__../~{..../2~V ___ _
Title: Sole Owner and Manager of Rafe Bros
LLC
Arnro Abueluf, as Sole Owner and Manager of Rafe Bros 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/_ day of Jun9, 2026.,., Check the appropriate box:
Personally known~
OR Produced Identification D
Type of identification produced □
□
□
~llkdY;fa{~
Notary Public
Driver's License
Passport
Other - ----- - (Do not include ID number)
6
PAMELA KELLER
MY COMMISSION # HH 643478
EXPIRES: May 6, 2029

AMRO ABUELUF: iJ ~ · Stgna Date: __ 6 __ /~( ,_ / ~~ lf ___ ,, __ Name: Amro Abueluf Amro Abueluf, 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 th~s_/ _ day of Ht, 2026 L/JaflJv. L· t,i___ Notary Public Check the appropriate box:
Personally known ~
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 PAMELA KELLER MY COMMISSION # HH 643478 EXPIRES: May 6, 2029 Date: 7/10/2026 --- -------- Gregory C. Oaks, Director Division of Consumer Finance 7