Final Order — Money Services Business

Index: OFR 2026 - 225 STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION .. ~ 1/ OOCKETEO ·, 4/28/20f;j6 Lt~l. BH ;:-__, In Re: EVITA PAY, INC., and IURII GUGNIN, Case Number: 130794 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 2 ~~ day of April, 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 via U.S. Mail to Evita Pay, Inc. and Iurii Gugnin, at 66 W. Flagler St. STE 900, Miami, FL 33130 and to Thomas A. Firestone, by email at thomas.firestone@squirepb.com on this?~ day of April, 2026. _____}~89 0090 0027 _ 66~1!,_8138 11 2 egulation 50 32314-8050 Email: Agency.Clerk@flofr.gov Tel: (850) 410-9889

I Exhibit A STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re: EVITA PAY, INC. and IURII GUGNIN, Case Number: 130794 Respondents. STIPULATION AND CONSENT AGREEMENT The State of Florida, Office of Financial Regulation ("Office"), and Evita Pay, Inc., and lurii Gugnin (together "Respondents") in consideration of the mutual promises herein, recite, stipulate, and agree as follows:

1. Background. At all times material hereto, Evita Pay, Inc. ("Evita Pay") is and has been a money services business in the state of Florida, pursuant to chapter 560, Florida Statutes - ' having been issued license number FT230000481. The Office conducted an examination (Exam No.# 131142) of Evita Pay's business records and operations pursuant to chapter 560, Florida Statutes. Iurii Gugnin, signatory on this Stipulation and Consent Agreement, is the president and sole owner of Evita Pay. The parties are resolving the issues herein with this Stipulation and Consent Agreement in lieu of the Office conducting further proceedings on this matter.
2. Jurisdiction. The Office is the state agency charged with the administration and enforcement of chapter 560, Florida Statutes, and the rnles promulgated thereunder. 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 consent to the Office's findings that Respondents failed to at all times maintain a corporate surety 1

bond or collateral deposit in the required amount, in violation of section 560.209(5), Florida Statutes. 4. Terms and Conditions. Respondents and the Office agree that the issues raised can be expeditiously resolved without a hearing and that further litigation can be avoided 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 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 (number FT230000481 ). 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 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 ten (10) 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 2

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. 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 Pact 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. 3

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 4

/ I ! 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. 5

Jl'i ~NT IURII GUGNIN: [signature) State of New York county of Kings I, lurii Gugnin, under penalties of perjury, declare that I have read the foregoing Stipulation and Consent Agreement, voluntarily signed the same, and that the facts stated in it are true. SWORN by lurii Gugnin on this I\ S l day of April 2026. (S)6 (Signature) 6

BY RESPONDENT EVITA PAY, INC. By t-06 (Signature) Name: Iurii Gugnin State of New York County of Kings Date: Li /r /2 .. b Title: President and sole owner I, Iurii Gugnin, as the President and sole owner of Evita Pay, Inc., under penalties of perjury, declare that I have read the foregoing Stipulation and Consent Agreement, voluntarily signed the same, and that the facts stated in it are true. SWORN by lurii Gugnin, as the President and sole owner of Evita Pay, Inc. on this 1 S:- .(- day of April, 2026. (Signature) OF~E OF FINANCIAL REGULATION /d~ C.{()dv GREGORY C. OAKS, Director Division of Consumer Finance Office of Financial Regulation Date: 41271206 7