Final Order — Money Services Business

Index: OFR 2026 - 293 STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re: LINCOLN EXCHANGE & GIFTS LLC, D/B/A LINCOLN CURRENCY EXCHANGE, and MARY MAVROS, Respondents. FINAL ORDER . DOCKETED ( !!_512026 ) ~ I.EG,t,I. ~ _J31!..- Case Number: 131025 The State of Florida, Office of Financial Regulation ("Office"), being authorized and directed to administer and enforce chapter 560, Florida Statutes, hereby enters this Final Order with Notice of Rights ("Final Order") as authorized by the provisions of chapters 120 and 560, Florida Statutes, against LINCOLN EXCHANGE & GIFTS LLC, D/B/A LINCOLN CURRENCY EXCHANGE, and MARY MA VROS, ("Respondents"). FINDINGS OF FACT

1. On April 10, 2026, the Office issued an Administrative Complaint ("Complaint") against Respondents, alleging violations of chapter 560, Florida Statutes. (Exhibit A).

2. Within the Complaint was a Notice of Rights that afforded Respondent an opportunity to request a hearing in accordance with sections 120.569 and 120.57, Florida Statutes, including the following information: TO PRESERVE THE RIGHT TO A HEARING, A WRITTEN RESPONSE MUST BE FILED WITH THE OFFICE OF FINANCIAL REGULATION WITHIN TWENTY-ONE (21) DAYS AFTER THE RECEIPT OF THE ADMINISTRATIVE COMPLAINT. SAID RESPONSE MUST BE RECEIVED BY THE OFFICE NO LATER THAN 5:00 P.M. ON THE TWENTY-FIRST DAY AFTER THE RECEIPT OF THE ADMINISTRATIVE COMPLAINT. A FAILURE TO TIMELY RESPOND IN WRITING WILL CONSTITUTE A WAIVER OF THE LICENSEE'S RIGHT TO REQUEST A HEARING AND A FINAL ORDER MAY BE ENTERED WITHOUT FURTHER NOTICE.

3. The Office served Respondents with the Complaint via certified mail on April 16,

4. (Exhibit B).

5. Respondents' written response to the Complaint was due by May 7, 2026. To date, the Office has neither received a written response to the Complaint nor has Respondent submitted a claim of equitable tolling.

6. The Statement of Facts as alleged in the Complaint are incorporated herein by reference as if fully set forth herein, and being uncontested by Respondents, are accepted as true and correct and are adopted by the Office as Findings of Fact for purposes of this Final Order. CONCLUSIONS OF LAW

7. The Office is responsible for the administration and enforcement of chapter 560, Florida Statutes, and has jurisdiction over the subject matter and of Respondents pursuant to chapter 560, Florida Statutes.

8. The Findings of Fact that have been adopted herein serve as the basis of the entry of this Final Order against Respondent.

9. Section 120.569(2)(a), Florida Statutes, and Rule 28-106.111(2), Florida Administrative Code, require that a response or a petition to an action which affects the substantial interests of a party be filed with the agency within 21 days ofreceipt of written notice of the action.

10. Pursuant to Rule 28-106.111(4), Florida Administrative Code, the failure of Respondents to timely respond to the Complaint constitutes a waiver of Respondents' right to an administrative proceeding.

11. The doctrine of equitable tolling can be applied in administrative cases when a party has been misled or lulled into inaction, i.e., has in some extraordinary way, been prevented from asserting his rights, or has timely asserted his rights in the wrong forum. Machules, v. Department of Admin., 523 So. 2d 1132 (Fla. 1988). 2

12. Without any evidence of equitable tolling, it is appropriate for the Office to conclude there was none. Patz v. Dept. of Health, 864 So.2d 79, 80 (Fla. 3d DCA 2003).

13. Respondents failed to file a petition or any other document in response to the Notice within the 21-day time period allowed by law. Respondents further failed to present a claim of equitable tol1ing. As such, the waiver of the right to an administrative hearing by Respondents is complete. See Patz v. Dept. of Health, 864 So.2d 79, 80 (Fla. 3d DCA 2003).

14. Based on the Findings of Fact adopted herein, the Office concludes that Respondents violated the specific statutes and rules charged in the Complaint and, as such, the specific charges in the Complaint are adopted in this Final Order as Conclusions of Law.

15. The waiver of a hearing by Respondents, taken together with the Findings of Fact and Conclusions of Law adopted herein, constitutes sufficient grounds for the Office to take administrative action against Respondents, including the imposition of an administrative fine. Based on the foregoing Findings of Fact and Conclusions of Law, it is hereby ORDERED: A. Within thirty (30) days of the docketing of this Final Order, Respondents shall pay an ADMINISTRATIVE FINE of Thirteen Thousand Six Hundred Twenty-Five Dollars ($13,625.00). B. Respondents shall submit the administrative fine in the form of a wire, money order or cashier's check made payable to the "Office of Financial Regulation." Such payment shall reference Case Number 131025 and shall be sent to the attention of Agency Clerk, c/o Damaris E. Reynolds, Post Office Box 8050, Tallahassee, FL 32314-8050. DONE and ORDERED this 5-f.l. day of June, 2026, in Tallahassee, Leon County, Florida. 3

NOTICE OF RIGHTS A PARTY WHO IS ADVERSELY AFFECTED BY THIS FINAL ORDER IS ENTITLED TO JUDICIAL REVIEW PURSUANT TO SECTION 120.68, FLORIDA STATUTES. REVIEW PROCEEDINGS ARE GOVERNED BY THE FLORIDA RULES OF APPELLATE PROCEDURE. SUCH PROCEEDINGS ARE COMMENCED BY FILING THE ORIGINAL NOTICE OF APPEAL WITH THE AGENCY CLERK FOR THE OFFICE OF FINANCIAL REGULATION AS FOLLOWS: By Mail, Facsimile or Email Agency Clerk Office of Financial Regulation Office of General Counsel P.O. Box 8050 Tallahassee, FL 32314-8050 Phone: (850) 410-9889 Fax: (850) 410-9663 Email: Agency.Clerk@flofr.gov OR By Hand Delivery Agency Clerk Office of Financial Regulation Office of General Counsel The Fletcher Building 101 East Gaines Street Tallahassee, FL 32399 Phone: (850) 410-9889 A COPY OF THE NOTICE OF APPEAL, ACCOMPANIED BY THE FILING FEES AS REQUIRED BY LAW, MUST ALSO BE FILED WITH THE DISTRICT COURT OF APPEAL, FIRST DISTRICT, 2000 DRAYTON DRIVE, TALLAHASSEE, FLORIDA 32399-0950, OR WITH THE DISTRICT COURT OF APPEAL IN THE APPELLATE DISTRICT WHERE THE PARTY RESIDES. THE NOTICE OF APPEAL MUST BE FILED WITH BOTH THE AGENCY CLERK FOR THE OFFICE OF FINANCIAL REGULATION AND THE DISTRICT COURT OF APPEAL WITHIN 30 DAYS OF THE RENDITION OF THE ORDER TO BE REVIEWED. 4

CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Final Order was furnished via U.S. Certified Mail to: Mary Mavros and Shari Apatov, 311 Lee Street #1, Hollywood, Florida, 33019 on this 5 -fVJay of June, 2026. 9489 0090 0027 6214 9312 04 5 Email: Agency.Clerk@flofr.gov Tel: (850) 410-9889

ST ATE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re: LINCOLN EXCHANGE & GIFTS LLC, D/B/A LINCOLN CURRENCY EXCHANGE, and MARY MAVROS, Respondents. ADMINISTRATIVE COMPLAINT Exhibit A Case Number: 131025 The State of Florida, Office of Financial Regulation ("Office"), files this Administrative Complaint against LINCOLN EXCHANGE & GIFTS LLC, D/B/A LINCOLN CURRENCY EXCHANGE, and MARY MA VROS (together "Respondents"), alleging: GENERAL ALLEGATIONS

1. Pursuant to sections 560.105 and 560.109, Florida Statutes, the Office is charged with administering and enforcing the provisions of chapter 560, Florida Statutes, and conducting examinations and investigations to determine whether any provision of chapter 560, Florida Statutes, has been violated.

2. Parts II, III, and IV of chapter 560, Florida Statutes, set forth the specific requirements of money services businesses and licenses.

3. Section 560.103(23), Florida Statutes, defines "money services business" as any person located in or doing business in this state, from this state, or into this state from locations outside this state or country who acts as a payment instrument seller, foreign currency exchanger, check casher, or money transmitter.

4. Section 560.103(6), Florida Statutes, defines a "check casher" as a person who sells currency in exchange for payment instruments or checks received, except travelers' checks.

5. Section 560.103(11 ), Florida Statutes, defines "currency" as the coin and paper money of the United States or any other country which is designated as the legal tender, and which circulates and is customarily used and accepted as a medium of exchange in the country of issuance.

6. Section 560.103(29), Florida Statutes, defines a "payment instrument" as a check, draft, warrant, money order, travelers check, electronic instrument, or other instrument, payment of money, or monetary value whether or not negotiable.

7. Section 560.103(10), Florida Statutes, defines a "corporate payment instrument" as a payment instrument (check) on which the payee named on the check's face is other than a natural person.

8. Section 560. 103(1 ), Florida Statutes, defines an "affiliated party" as, among other things, an officer, control person, or a person who has a controlling interest in a money services business.

9. Section 560.103(10)(a), Florida Statutes, defines a "control person" as, among other things, the president, or the compliance officer, of a money services business.

10. Section 560.l 14(1)(a), Florida Statutes, provides that an "affiliated party" is responsible for, among other things, complying with all provisions of chapter 560, Florida Statutes, and its related rules. 1 l. Pursuant to section 560.l 14(1)(a), Florida Statutes, failure to comply with any provision of chapter 560, Florida Statutes, or related rule, constitutes grounds for disciplinary action. 2

11. At all times material, Respondents are and have been licensed as a Part III Money Services Business (license number FT340000724) pursuant to chapter 560, Florida Statutes, and have been operating as a "check casher," as defined in section 560.103(6), Florida Statutes.

12. At all times material, MARY MAVROS is and has been listed as the Controlling Officer, Responsible Person, and Sole Owner of LINCOLN EXCHANGE & GIFTS LLC, D/B/A LINCOLN CURRENCY EXCHANGE, and by operation of law, pursuant to section 560.103, Florida Statutes, she is an "affiliated party" and "control person" who is liable for all violations of LINCOLN EXCHANGE & GIFTS LLC, D/B/A LINCOLN CURRENCY EXCHANGE.

13. The Office conducted an examination (No. 129559) for the period of April 1, 2023, through March 31, 2025 ("examination period") to ascertain Respondents' compliance with chapter 560, Florida Statutes.

14. Respondents' manager, Shari Apatov, met with the examiner for both an entrance conference on May 27, 2025, and an exit conference on July 14, 2025.

15. After the examination was concluded, Respondents were sent the Report of Examination, which identified the specific statutory provisions of chapter 560, Florida Statutes, and the corresponding rules that the Office found were potentially violated.

16. Pursuant to section 560.1141, Florida Statutes, the Office has adopted disciplinary guidelines with ranges of designated penalties applicable to each ground for disciplinary action.

17. Pursuant to rule 69V-560.l 000(5), Florida Administrative Code, the range for an "A" level administrative fine is between $1,000.00 and $3,500.00.

18. Pursuant to Rule 69V-560.l000(5), Florida Administrative Code, the range for a "B" level administrative fine is between $3,500.00 and $7,500.00. 3

COUNTI 20. The above general allegations are hereby re-alleged and incorporated by reference as if fully stated herein. 21. Pursuant to section 560.309(3), Florida Statutes: A licensee under this part must maintain and deposit payment instruments into its own commercial account at a federa11y insured financial institution. If a licensee ceases to maintain such a depository account, the licensee must not engage in check cashing until the licensee reestablishes such an account and notifies the office of the. account as required bys. 560.126(4). 22. Pursuant to Rule 69V-560.704(1)(b), Florida Administrative Code, the authorized signatories of the account referenced in section 560.309(3), Florida Statutes, must be a control person as defined in section 560.103(10), Florida Statutes. A licensee may not grant, through power of attorney, written agreement, or any other means, another person access to its own commercial account to withdraw, withhold, or deposit money. 23. As part of its examination, the Office found that Respondents had granted an unauthorized signatory with no controlling interest (the manager's brother) access to their commercial account to withdraw, withhold, or deposit money, in violation of section 560.309(3), Florida Statutes, and Rule 69V-560.704(l)(b), Florida Administrative Code. 24. Pursuant to the Disciplinary Guidelines for Money Services Businesses, Form OFR-560-09, incorporated by reference in rule 69V-560.1000, Florida Administrative Code (2019), violation number 84, a licensee cited for violating section 560.309(3), Florida Statutes, is subject to a "B" level administrative fine. 25. Therefore, the Office is seeking an administrative fine of $7,500.00. 4

COUNT II 26. The above general allegations are hereby re-alleged and incorporated by reference as if fully stated herein. 27. Pursuant to section 560.126(2), Florida Statutes, and Rule 69V-560.201(2), Florida Administrative Code, a money services business or its affiliated party must report any change in the information contained in its initial license application, or any amendment to such application, within thirty (30) days of the change. 28. As part of the examination, the Office reviewed Respondents' license application, and any amendments thereto. 29. During its examination, the Office found that Respondents failed to timely report to the Office, via written amendment to its application (Form OFR-560-01), that Mary Mavros was the compliance officer. 30. Respondents' failure to timely notify the Office that Mary Mavros was serving as compliance officer constitutes a violation of section 560.126(2), Florida Statutes, and Rule 69V-560.201(2), Florida Administrative Code. 31. Previously, in OFR legal case no. LG12117, which was related to Exam No. 102904, it was determined that Respondents failed to timely report the addition of an officer. The case was closed by final order, which imposed an administrative fine, on August 9, 2024. 32. Pursuant to the Disciplinary Guidelines for Money Services Businesses, Form OFR-560-09, incorporated by reference in rule 69V-560.1000, Florida Administrative Code (2019), violation number 46, a licensee cited for violating section 560.126(2), Florida Statutes, is subject to an "A" level administrative fine. 33. Therefore, the Office is seeking an administrative fine of $1 ,000.00. 5

COUNT III 34. The above general allegations are hereby re-alleged and incorporated by reference as if fully stated herein. 35. Pursuant to section 560.118(2), Florida Statutes, every money services business must submit accurate and timely quarterly reports to the Office in the format and including the information specified by rule 69V-560.602, Florida Administrative Code, which provides that quarterly reports must be filed within 45 days of the end of each quarter. 36. Upon reviewing Respondents' quarterly report submissions to ensure timeliness and accuracy, the Office found Respondents failed to submit a timely quarterly report for the Third Quarter of 2024, ending September 30, 2024. The report was found to have been filed 46 days late, in violation of rule 69V-560.602, Florida Administrative Code, and thereby section 560.118(2), Florida Statutes. 37. Previously, in OFR legal case no. LG125018, which was related to Exam No. 124021, it was determined that Respondents failed to submit timely quarter reports for the First Quarter of 2024, ending March 31, 2024, and the Second Quarter of 2024, ending June 30, 2024. The case was closed by final order, which imposed an administrative fine, on March 5, 2025. 38. Pursuant to the Disciplinary Guidelines for Money Services Businesses Form OFR￾560-09, incorporated by reference in Rule 69V-560.1000, Florida Administrative Code (2019), violation number 31, a licensee cited for a second violation of section 560.118(2), Florida Statutes, is subject to an "A" level administrative fine. 39. Therefore, the Office is seeking an administrative fine of $1,625.00. 6

COUNTIV 40. The above general allegations are hereby re-alleged and incorporated by reference as if fully stated herein. 41. Pursuant to section 560.l 14(l)(y), Florida Statutes, any violation of 31 C.F.R sections 1010.306, 1010.311, 1010.312, 1010.340, 1010.410, 1010.415, 1022.210, 1022.320, 1022.380, and 1022.410, and United States Treasury Interpretive Release 2004-1 by a money services business, authorized vendor, or affiliated party constitutes grounds for the issuance of a cease and desist order; the issuance of a removal order; the denial, suspension, or revocation of a license; or any other action within the authority of the office pursuant to chapter 560. 42. As part of its examination, the Office reviewed Respondents' BSA/AML program and noted that Respondents failed to implement their BSA/AML program, which provides on page 29 for an Independent Audit of the BSA/AML program, as required by section 1022.210 of Chapter X. Specifica11y, the BSA/AML program provides as follows: "Independent Review Since Lincoln Currency Exchange (LX) is conducting currency transactions as an Agent of Currency Exchange International (CXI) an Independent Review is conducted.frequently from CXI Moreover, since LX currently is not conducting business under their own license an independent review will be conducted every 18-24 months of their Anti Money Laundering Programs. " 43. During the examination, Ms. Apatov explained that she had not provided an independent review audit report because all LX activity had been conducted under the license of CXI, as a CXI vendor. Ms. Apatov indicated that she would contact CXI to ask for the independent review they had conducted on LX. Ms. Apatov subsequently provided an email, stating that no significant notable issues were observed during an agent visit to LX, but she did not provide an independent audit report. 7

44. Respondents failed to implement the provisions of their BSA/ AML program, which require an independent audit, in violation of 31 C.F .R. 1022.210, and thereby section 560.114(1)(y), Florida Statutes.
45. Previously, in OFR legal case no. LG71504, it was determined that Respondents failed to implement its BSA/ AML policies as it related to maintaining training documentation. The case was closed by final order, which imposed an administrative fine, on November 29, 2017.
46. Pursuant to the Disciplinary Guidelines for Money Services Businesses, Form OFR-560-09, incorporated by reference in rule 69V-560. l 000, Florida Administrative Code (2019), violation number 26, a licensee cited for violating section 560.114(1 )(y), Florida Statutes, is subject to a "B" level administrative fine. 4 7. Therefore, the Office is seeking an administrative fine of $3,500.00. WHEREFORE, Respondents are hereby notified that the Office intends to enter an Order imposing an administrative fine of Thirteen Thousand Six Hundred Twenty-Five Dollars ($] 3,625.00). [this space intentionally le.ft blank with Notice of Rights on next page J 8

NOTICE OF RIGHTS The licensee is entitled to be represented by counsel or another qualified representative. The licensee also has the right to request a hearing pursuant to sections 120.569 and 120.57, Florida Statutes. Such request must comply with Rules 28-106.2015 and 28-106.104, Florida Administrative Code. An Election of Proceeding form is attached for your convenience. Any such request must be filed as follows: By Mail, Facsimile or Email Agency Clerk Office of Financial Regulation Office of General Counsel P.O. Box 8050 Tallahassee, FL 32314-8050 Phone: (850) 410-9889 Fax: (850) 410-9663 Email: Agency.Clerk@flofr.gov OR Bv Hand Delivery Agency Clerk Office of Financial Regulation Office of General Counsel The Fletcher Building 101 East Gaines Street Tallahassee, FL 32399 Phone: (850) 410-9889 TO PRESERVE THE RIGHT TO A HEARING, A WRITTEN RESPONSE MUST BE FILED WITH THE OFFICE OF FINANCIAL REGULATION WITHIN TWENTY￾ONE (21) DAYS AFTER THE RECEIPT OF THE ADMINISTRATIVE COMPLAINT. SAID RESPONSE MUST BE RECEIVED BY THE OFFICE NO LATER THAN 5:00 P.M. ON THE TWENTY-FIRST DAY AFTER THE RECEIPT OF THE ADMINISTRATIVE COMPLAINT. A FAILURE TO TIMELY RESPOND IN WRITING WILL CONSTITUTE A WAIVER OF THE LICENSEE'S RIGHT TO REQUEST A HEARING AND A FINAL ORDER MAY BE ENTERED WITHOUT FURTHER NOTICE. You may not make an oral request for an administrative hearing. With regard to a written request, if you fail to follow the outlined procedure, your request may be dismissed. Any request for an administrative proceeding received prior to the date of this notice is deemed abandoned and to be considered, must be timely renewed in compliance with the procedure set forth above. Mediation of this matter pursuant to section 120.573, Florida Statutes, is not available. 9

NOTICE TO RESPONDENTS In accordance with the Americans with Disabilities Act, persons with disabilities needing special accommodation to participate in this proceeding should contact the Agency Clerk no later than seven (7) days prior to the filing deadline or proceeding, at the Office of Financial Regulation, The Fletcher Building, 200 East Gaines Street, Tallahassee, Florida 32399, Phone: (850) 410-9889, or by Email: Agency.Clerk@flofr.gov. By: !u,~4i Damaris E. Reynolds Assistant General Counsel Office of Financial Regulation Office of General Counsel Fla. Bar No. 0037176 200 E. Gaines Street Tallahassee, FL 32399-0370 Tel: (850) 410-9830 Email: Damaris.Reynolds@flofr.gov

CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Administrative Complaint has been sent for service via U.S. Certified Mail to: Lincoln Exchange & Gifts, LLC, and Mary Mavros, 311 Lee Street# 1, Hollywood, Florida, 33019 on this 10th day of April, 2026. ~ Damaris E. Reynolds Assistant General Counsel Office of Financial Regulation 11

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