Final Order — Moonpay USA LLC

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Index: OFR 2026 - 277
STATE OF FLORIDA
KETEO \
/2026
OFFICE OF FINANCIAL REGULATION I.
In Re:
MOONPAY USA LLC,
Respondent.
Case Number: 132189
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:
I. 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 :Z.1 day of May, 2026, in Tallahassee, Leon County, Florida. ~P,:;;;; u 2 ry~~~ p~ez::::c'S":;;:a;:n:i:;~~~_!~~~~~~Y' Chie( Operating Officer By Delegation

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing Final Order has been furnished by email to counsel for Respondent, Alexandra Bell, at abell@moonpay.com and Global Regulatory Compliance Manager, Hannah DeSantis, at hdesantis@moonpay.com on this 271-ity of May, 2026. 2 ncial Regulation Post 1c ox 8050 Tall assee, FL 32314-8050 Email: Agency.Clerk@tlofr.gov Tel: (850) 410-9889

Docusign Envelope ID: 3F0DEBBO-F2C0-4AFE-BAE7-2DCFD27BA315 STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re:
MOONPAY USA LLC,
Respondent.
Exhibit A
Case N um her: 132189
STIPULATION AND CONSENT AGREEMENT
The State of Florida, Office of Financial Regulation ("Office"), and MOONPAY USA LLC {"Respondent"), in consideration of the mutual promises herein, recite, stipulate, and agree as follows:

1. Back!round. At all times material, Respondent is and has been licensed as a Part
   JI Money Services Business (License number FT230000327) per chapter 560, Florida Statutes. The Office conducted an examination (Examination Number 127546) to ascertain Respondent's compliance with chapter 560, Florida Statutes. In lieu of initiating a formal proceeding, the parties 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 an administrative action against Respondent pursuant to chapter 560, Florida Statutes.
3. Findincs. For purposes of this Stipulation and Consent Agreement. Respondent
   neither admits nor denies but consents to the Office making the following findings:
   a) Respondent failed to report, on a form adopted by rule {Form OFR-560-01 ), any change in the financial information contained in the initial license application

Docusign Envelope ID: 3FDDEBBD-F2C0-4AFE-BAE7-2DCFD27BA315 form, any amendment to such application, or the appointment of an authorized vendor within 30 days after the change became effective. in violation of Rule 69V-560.201(2). Florida Administrative Code, and section 560.126(2), Florida Statutes; and b) Respondent failed to report any change in the control persons of the licensee or changes in the form of business organization by written amendment in such form (Form OFR-560-01) and at such time (within 30 days) in violation of Rule 69V~560.201(3), Florida Administrative Code, and thereby section 560.126(3), 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. The parties acknowledge 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, Respondent agrees to the following tenns and conditions:
a. FUTURE COMPLIANCE. Respondent agrees to cease and desist from future violations of chapter 560, Florida Statutes, and the rules promu]gated thereunder. b. ADMINISTRATIVE FINE. Respondent agrees to pay the Office an administrative fine in the amount of Two Thousand Dollars ($2,000.00), 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 form of a wire, cashier's check or money order made payable to the "Office of Financial Regulation." Such payment shall reference Case Number 132189 and shall be sent to the attention of Agency Clerk - c/o Damaris E. Reynolds, Post Office Box 8050, 2

Docusign Envelope ID: 3F0DEBBD-F2C0-4AFE-BAE7-2DCFD27BA315 Tallahassee, Florida 32314-8050. Respondent acknowledges and agrees 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 sha11 not be construed as a final acceptance of the Stipulation and Consent Agreement absent full execution thereof and entry of a Fina] Order adopting same.
5. Final Order. Respondent consents to the entry of a Final Order, which incorporates
the terms of this Stipulation and Consent Agreement. Respondent understands and agrees 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 Respondent's consent to the entry of a Final Order with respect to this
proceeding, Respondent waives:
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

Docuslgn Envelope ID: 3F0DEBBD-F2C0-4AFE-BAE7-2DCFD27BA315
7. Releases. Upon full execution of this Stipulation and Consent Agreement,
Respondent waives, releases, and forever discharges the Office and its agents, representatives, and employees from any and all causes of action, in law or in equity, which Respondent may have arising out of this matter. The Office accepts this release and waiver by Respondent 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 Com1>h-. Respondent acknowledges, concurs, and stipulates that
Respondent's 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 Respondent's right to contest any finding or determination of non-compliance.
9. Attornev'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. I 0. Severabilitv. 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 wHJ be deemed to be an original but all of which together will constitute but one Stipulation and Consent 4

Docusign Envelope ID: 3F0DEBBD-F2C0-4AFE-BAE7-2DCFD27BA315 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 Ac,reement. This Stipulation and Consent Agreement represents the entire
agreement by and between Respondent 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 Respondent, 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 Respondent 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] 5

Docuslgn Envelope ID: 3F0DEBBD-F2C0-4AFE-BAE7-2DCFD27BA315 MOONPAY USA LLC:
l:Jw ,111 a111•~eo•sr,-..~ D ate: 4/1/2026

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(Signature)
Name: IV AN DAVID SOTO-WRIGHT Title: Chief Executive Officer and Manager State of Hillsborough Countyof F_lo_rld_a __ _ IV AN DAVID SOTO-WRIGHT, as Chief Executive Officer and Manager, of MOONP A Y USA LLC, BEFORE ME by means of □ physical presence or 0 online notarization, has sworn ( or affinned) that he has read and understands the foregoing agreement and voluntarily signed the same. 1 April SWORN TO AND SUBSCRIBED before me this __ day of ______ , 2026. Check the appropriate box:
Personally known fZJ
OR Produced Identification D
Type of identification produc.ed O Driver's License D Passport Nalafzsd ldll&uelng audlo-wdao GIIMUllcaliun ~ -- L ~ -- ~@• B~~ Ele:On,:~~( .il ):}) sta1ofF1orichi Cammission#: HH 519432:
:lri~ /commission Expires: 04/23/2028 , .... ,~- D Other_ (Do not include ID number) OFFICE OF FINANCIAL REGULATION 4-m c.«?M,v Gregory . Oaks, Director Date: __ 5_11_1_12_0_26 ___ Division of Consumer Finance 6