Final Order — South Exchange, Inc. and Silvio Anspach

Index: OFR 2026 - 393 STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re: SOUTH EXCHANGE, INC., and SILVIO ANSPACH, Case Number: 123638 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 3rd day of August, 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 by electronic mail to South Exchange, Inc., and Silvio Anspach at jamesdefrantz@gmail.com on this ~( J day of August, 2026. 2 -8050 mat: gency. erk@flofr.gov Tel: (850) 410-9889

STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re: SOUTH EXCHANGE, INC. and SILVIO ANSPACH, Respondents. Exhibit A Case Number: 123638 STIPULATION AND CONSENT AGREEMENT The State of Florida, Office of Financial Regulation ("Office"), and SOUTH EXCHANGE INC. ("South Exchange") and SILVIO ANSPACH ("Anspach") (together "Respondents"), in consideration of the mutual promises herein, recite, stipulate, and agree as follows:

1. Background. At all times material hereto, South Exchange, Inc., is and has been a Part II Money Services Business in the State of Florida, having been issued license number FT20700122. At all times material, Silvio Anspach is and has been the president and ninety (90) percent owner of South Exchange, Inc. The Office conducted an examination (No. 111840) to ascertain Respondents' compliance with chapter 560, Florida Statutes. The Office issued an Administrative Complaint ("Complaint") on March 11, 2025, and Respondents timely requested a hearing on March 27, 2025 pursuant to section 120.57(1), Florida Statutes. The parties are herein resolving the matters at issue before conducting any hearing 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 purposes of this Stipulation and Consent Agreement, Respondents consent to the Office making the following findings: a) Respondents failed to report aggregated cashed checks that exceeded $1,000 to the CCDB, in violation of section 560.310(2)(d), Florida Statutes, 560.114(l)(a), Florida Statutes, and Rule 69V-560.704(5) and 69V-560.7042(1), Florida Administrative Code; b) Respondents failed to timely report to the Office a change in financial information, in violation of section 560.126(2), Florida Statutes; c) Respondents failed to maintain and deposit payment instruments into their own commercial account, in violation of section 560.309(3) aa 560.114(l)(a), Florida Statutes; d) Respondents failed to obtain and maintain all information required by their AML manual for incoming and outgoing payment orders, and therefore failed to implement their AML manual, in violation of section 560.114(1 )(y), Florida Statutes and 31 C.F .R. 1022.21 O; and e) Respondents failed to include all required provisions in their vendor agreements, in violation of section 560.2085(2)(b) and 560.l 14(1)(a), 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 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 2

of the Office's forbearance from further litigation, Respondents agree to the following tenns 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. FUTURE APPLICATION. Respondents, South Exchange, Inc. and Silvio Anspach will not cash checks including in the aggregate over $1,500 for five years. This includes both checks that individually are $1,500 or more, and multiple checks from any one person or entity that on any given day total $1,500 or more when aggregated, from the date of entry of the Final Order adopting this Stipulation and Consent Agreement. c. ADMINISTRATIVE FINE. Respondents agree to pay the Office an administrative fine in the amount of Ten Thousand Dollars ($10,000.00), to be paid at the time of the execution and delivery of this Stipulation and Consent Agreement. Tiris administrative fine shall be submitted in the form of a wire, cashier's check or money order made payable to "Office of Financial Regulation ". Such payment shall reference Case Number 123638 and shall be sent to the attention of Agency Clerk - c/o Jennifer Blakeman, 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. 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 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 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 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 ofthis matter. The Office accepts this release and waiver by Respondents on behalf of 4

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 tenns, obliga~ions, 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. 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. 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, 5

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] 6

SOUTH t,:XeHANGF; INC.: {~~:_ --!'."" .... (Signature) / Name: Silvio Anspach Title: president and ninetv (90) percent owner State of® c•d..s. _ County of t Z>a.... '. l J ~~ Silvio Anspach, as president and ninety (90) percent owner of South Exchange Inc., BEFORE ME by ineans of ~~sence 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 befureme this / ~y of /J---tu I Check the appropriate box: Personally kn.own D OR Produced Identification ~ Type of identification produced ~ s License D Passport D Other (Do not include ID number) 7 , 2026.

Date: Name: Silvio Anspach '::p/c · Stateof ~ ,,~ J__ r.--- ! County of (U~ Silvio Anspach, BEFORE ME by means of~ 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 /7 day of k // Check the appropriate box: Personally known D OR Produced Identification~ Type of identification produced ~ense Passport Other □ □ -------- (Do not include ID number) OFFICE OF FINANCIAL REGULATION :5Ez:rz.~;i?c~ Date: 7/29/2026 Division of Consumer Finance 8 , 2026.