Immediate Final Order Against Espana Top Legion Finance

Index: OFR 2026 - 325 "
CKETEO \
STATE OF FLORIDA
OFFICE OF FINANCIAL REGULATION
In Re:
ESPANA TOP LEGION FINANCE, and
HTTPS://ESPANATOPLEGIONFINANCE.COM
Respondents.
IMMEDIATE FINAL ORDER
/2026
G'-l.
Case No.: 138408
The State of Florida, Office of Financial Regulation ("Office"), being authorized and directed to administer and enforce chapter 655, Florida Statutes, governing financial institutions in the state of Florida, pursuant to sections 20.121(3)(a)2, 655.001, and 655.012(1), Florida Statutes, hereby finds that the unlawful activity of Espana Top Legion Finance and https://espanatoplegionf1nance.com ("Respondents") constitutes an immediate danger to the public health, safety, or welfare. Therefore, the Office hereby issues and serves this Immediate Final Order pursuant to sections 120.569(2)(11), and 655.922(5), Florida Statutes. Respondents and all persons acting in concert or cooperation with Respondents shall immediately CEASE and DESIST all continuing violations of
chapter 655, Florida Statutes, and take corrective action as detailed herein. This Order is
based on the findings of fact and conclusions of law set forth below which are made on behalf of the Office by Russell C. Weigel, III, Commissioner of the Office of Financial Regulation, as agency head within the meaning of sections 20.121(3)(a)2, and 120.569(2)(n), Florida Statutes.

FINDINGS OF FACT

1. The Office is the State of Florida's agency responsible for the
   administration and enforcement of chapter 655, Florida Statutes.
2. The Office obtained information prompting an investigation into whether
   Respondents were offering or providing unauthorized banking services, contrary to provisions of chapter 655, Florida Statutes.
3. The findings of fact independently made herein are based, in part, upon the
   verified declaration of Financial Investigator Reina Rivero, Bureau of Financial Investigations, Office of Financial Regulation, which includes exhibits 1 through 14. Reina Rivero's declaration, along with its exhibits, is attached hereto as Attachment "A." Respondents' Status
4. Respondent Espana Top Legion Finance is not registered to lawfully
   operate as a business entity in Florida. The website, https://espanatoplegionfinance.com, is managed by Respondent Espana Top Legion Finance.
5. Respondents' website contains several references to a financial institution
   registered in Florida. These include references to the registered financial institution's routing number and NMLS number. Therefore, Respondents have certain minimum contacts with Florida for jurisdictional purposes.
6. Respondents have never been a chartered or licensed financial institution
   according to the Federal Financial Institutions Examination Council's National Information Center which is a repository of financial data and institution characteristics collected by the Federal Reserve System on financial institutions worldwide.
7. Respondents have never been chartered or licensed by the Office to do
   2

business in the state of Florida as a financial institution, as defined in section 655 .005(1 )(i), Florida Statutes.
8. Respondents have never been members of the Federal Deposit Insurance
Corporation ("FDIC"), and any funds deposited with Respondents are not insured by the FDIC. Respondents' Website
9. Respondents published and operate a website with Uniform Resource
Locator (URL) of https://espanatoplegionfinance.com, that:
a) offers banking services to individuals located within the state of Florida; b) offers members of the public, including individuals in Florida, to communicate with Respondents by clicking the "Contact Us" tab; c) solicits members of the public, including individuals in Florida, to establish online personal checking and savings accounts with Respondents; d) offers various business account services, including business checking accounts, business savings accounts, business debit and credit cards; e) offers small business loans; and f) offers various mortgage products for home buyers.
10. Respondents' website advertises, represents, and holds itself out to the
general public, including Florida citizens, as a financial institution.
11. Respondents' website reasonably implies that the business being solicited,
3

conducted, or advertised is the kind or character of business transacted or conducted by a financial institution.
12. The current domain name registrar ofhttps://espanatoplegionfinance.com
is Hostinger International Ltd.
Ongoing Immediate Danger
13. Entities and individuals that falsely hold themselves out to the public as
authorized and qualified to operate as a financial institution pose an immediate danger to the public health, safety, or welfare and particularly to those depositors or creditors who rely upon those false representations.
14. As of June 18, 2026 the URL https://espanatoplegionfinance.com is
currently accessible and active with an IP address of 64.20.38.219 and is hosted by Hostinger International Ltd.
15. The status of Respondents' website as active constitutes an ongoing and
immediate danger to public health, safety, or welfare.
16. Respondents are currently using the services ofHostinger International Ltd.
to facilitate fraudulent activity and violations of Florida Statutes.
17. Respondents' actions, including publication of the website, are unlawful
and the current circumstances constitute an ongoing and immediate danger to the public health, safety, or welfare.
18. Respondents' actions are likely to continue in the future, and an immediate
final order is necessary and fair under the circumstances to stop the ongoing violation. 4

CONCLUSIONS OF LAW
19. The Office is responsible for the administration and enforcement of chapter
655, Florida Statutes, pursuant to section 655.012, Florida Statutes.
20. The undersigned, Russell C. Weigel, III, as Commissioner of the Office,
and as its agency head within the meaning of sections 20.121(3)(a)2 and 120.569(2)(n), Florida Statutes, is authorized to make the findings of fact and conclusions of law set forth herein. 21 . The Office has jurisdiction over Respondents because they have been found to have engaged in unauthorized banking activity in the state of Florida, contrary to sections of chapter 655, Florida Statutes.
22. Chapter 655, Florida Statutes, is designed to protect the public welfare by
requiring that each entity engaged in offering banking services to the public or holding itself out to the public as being a financial institution is authorized to do business in this state. None of these protections of the public health, safety, or welfare are provided when an individual or an entity engages in the business of a financial institution in this state without in fact being authorized to do business as a financial institution pursuant to state or federal law. Unauthorized Banking Activity
23. Section 655.922(1), Florida Statutes, provides that only a financial
institution authorized to do business in this state may engage in the business of soliciting or receiving funds for deposit, issuing certificates of deposit, paying checks, or establishing or maintaining a place of business in this state for any of the functions, transactions, or purposes identified in the subsection. 5

24. Section 655.922(1), Florida Statutes, is designed to protect the public
    health, safety, or welfare by prohibiting unauthorized persons or entities from engaging in banking activities. A violation of this statute constitutes, in addition to a regulatory violation, a felony of the third degree punishable by up to a five-year prison sentence.
25. By soliciting or receiving funds from the public through its website and
    offering to establish business and personal bank accounts and to perform other related banking services while not being authorized to do business in this state, Respondents are in violation of section 655.922(1), Florida Statutes. Unauthorized Claims
26. Section 655.922(2)( c ), Florida Statutes, provides that only a financial
    institution authorized to do business in Florida may "circulate or use any ... electronic media, internet website, posting, or writing of any kind or otherwise advertise or represent in any manner which indicates or reasonably implies that the business being solicited, conducted, or advertised is the kind or character of business transacted or conducted by a financial institution or which is likely to lead any person to believe that such business is that of a financial institution .... "
27. By using electronic media or a website that indicates or reasonably implies
    that the business being solicited, conducted, or advertised is that of a financial institution or which is likely to lead a person to believe that the business is a financial institution, Respondents are in violation of section 655.922(2)( c ), Florida Statutes. Summary Administrative Action
28. Section 655.922(5), Florida Statutes, provides that the Office may issue an
    emergency cease and desist order, without first issuing an administrative complaint, against 6

any person who violates any provision of section 655.922, Florida Statutes.
29. Section 120.569(2)(n), Florida Statutes, provides that an immediate final
order may be issued when an agency head finds the existence of an immediate danger to the public health, safety, or welfare and when that danger requires an immediate final order.
30. The statutory violations committed by Respondents, and the status of their
website noted above, constitute an ongoing, continuing, and immediate danger to the public health, safety, or welfare.
31. The unlawful activity committed by Respondents and the status of their
website, as outlined above, constitute an ongoing, continuing, and immediate danger to the public health, safety, or welfare.
32. It is necessary for the Office to immediately prevent Respondents from the
ability to continue to violate Florida law and continuing to pose an immediate danger to the public health, safety or welfare, to wit:
a. it is necessary to have Respondents immediately cease and desist from holding themselves out to the general public, including Florida citizens, as a financial institution; and b. it is necessary to have Respondents immediately cease and desist from soliciting financial transactions or deposits from the general public, including Florida citizens, through the use of their website or other methods.
33. After careful consideration of the facts of this case and due process
procedural safeguards as contained in the Florida Statutes and as outlined in the attached Notice of Rights page, the need for summary administrative action in the form of this Immediate Final Order is concluded to be fair, just, and necessary under the totality of 7

circumstances herein.
34. In entering this Immediate Final Order, the Office considered but ultimately
decided against using other remedies. Issuing an administrative complaint or a cease and desist order would be insufficient to adequately address Respondents' ongoing violations of the law. Neither of these options would be effective upon service, and an indeterminate amount of time would pass before a final order could be issued against Respondents. Moreover, the potential for harm to Florida's consumers posed by Respondents' ongoing conduct is severe and cannot be abated until an immediate final order is issued. By contrast, any potential harm from issuing an immediate final order in this instance is likely to be de minimis.
35. The Office of Financial Regulation is entering this Immediate Final Order
to prevent Respondents from posing a continuing and immediate danger to the public health, safety, or welfare. Accordingly, IT IS HEREBY ORDERED:
A. Respondents and all persons acting m concert or cooperation with Respondents shall immediately CEASE and DESIST from:
i. representing or holding themselves out as a financial institution;
ii. advertising, soliciting or performing, directly or indirectly, any and all
banking activity, including but not limited to the solicitation or receipt of funds for deposit, opening business or personal bank accounts, issuing certificates of deposit, and paying any check in this state; m. operating, registering, storing, passively maintaining, or actively maintaining the website found at https://espanatoplegionfinance.com and 8
•

any files or electronic data associated therewith; or
iv. operating, registering, storing, passively maintaining, or actively
maintaining the domain name https://espanatoplegionfinance.com and any files or electronic data associated therewith. DONE and ORDERED this ~ day of June, 2026, in Tallahassee, Leon County, Florida. Commissioner NOTICE OF RIGHTS NOTICE IS HEREBY given that the foregoing Immediate Final Order is entered pursuant to section 120.569(2)(n), Florida Statutes, which provides that the Order is appealable or enjoinable from the date rendered. Section 120.68, Florida Statutes, further provides that any party to these proceedings who is adversely affected by this final agency action is entitled to judicial review.
Section 120.68, Florida Statutes, and Rule 9.110, Florida Rules of Appellate
Procedure, provide that judicial review must be instituted by filing a petition or notice of appeal with the Agency Clerk, Office of Financial Regulation, Office of General Counsel, Suite 504, Fletcher Building, 200 E. Gaines Street, Tallahassee, Florida 32399-0379, and a copy accompanied by filing fees prescribed by section 35.22, Florida Statutes, 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. Filings may also be made through the Florida Courts E-Filing Portal at 9

https://www.myflcourtaccess.com.
All review proceedings must be instituted within thirty (30) days after the rendition of this Order. Respondents may also apply to the District Court of Appeal for a supersedeas, or to the Office of Financial Regulation for a stay of this Order, pursuant to section 120.68(3), Florida Statutes. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished as set forth below to the following parties on this.~ y of June, 2026:
Espana Top Legion Finance
Boulevard Maurine Lemonnier 125
1000 Bruxelles
Hostinger International Ltd. compliance@hostinger.com lorida 32314-8050 y.Clerk@flofr.gov Tel: (850) 410-9889

VERIFIED DOCUMENT BY WRITTEN DECLARATION
Page 1 of 3
STATE OF FLORIDA )
) s.s.
COUNTY OF ORANGE )
I, Reina Rivero, declare and state as follows;
1. I am Reina Rivero, Financial Investigator Criminal Enforcement (FICE) with the Emergent Financial Crimes Unit
of the Bureau of Financial Investigations (BFI), for the Florida Office of Financial Regulation (OFR).
2. I have been working with the BFI since February 2023. Operating in an official capacity, I conduct criminal,
administrative, and civil investigations within the regulatory jurisdiction of the OFR. I am experienced in reviewing complaints, interviewing witnesses and targets, collecting and processing intelligence, and preparing investigative reports. I have earned the Chainalysis Reactor Certification (hereinafter referred to as “CRC”), Chainalysis Cryptocurrency Fundamentals Certification (CCFC), and the Chainalysis Ethereum Investigations Certification (CEIC) issued by the blockchain analysis firm Chainalysis. I have successfully completed 40 hours of continuing professional education. The majority of these specialized courses relate to subject matter that pertains to conducting investigations that involve engaging in fraud for financial gain, forfeiture procedures, financial documents analysis, and Cyber Investigations through the National White Collar Crime Center, Florida Public Safety Institute, Association of Certified Fraud Examiners, and International Association of Financial Crimes Investigators. I have been a Certified Fraud Examiner (hereinafter referred to as “CFE”) in good standing with the International Association of Certified Fraud Examiners (hereinafter referred to as “ACFE”) since June
2024. I received a Bachelor of Science Degree in Accounting.
3. On April 7, 2026, I was alerted by BFI Manager/Computer Examiner, Kris Ignatowicz of information reflecting
the online presence of an unchartered/unlicensed financial institution operating as Espana Top Legion Finance (“Espana”).
4. The information centered on representations made via Espana’s website, which is active as of the date of this
declaration:
a) Espana’s website has a URL of https://espanatoplegionfinance.com.
5. The website indicated that Espana offers banking services that include business and personal banking, savings and
checking accounts, lending, mortgages, and online and mobile banking among others (Exhibit 1). Espana’s website provided a section for “Business Accounts” that highlights business checking and savings accounts, certificates of deposit, money market accounts, and business debit & credit cards (Exhibit 2), a “Lending” section that offers small business loans, SBA loans, USDA business loans, and business relief programs (Exhibit 3), a “Personal” section that lists checking and savings accounts, debit & credit cards, and online and mobile banking, (Exhibit 4), a “Mortgages” section that offers mortgage products such as First-Time Home Buyer, Down Payment Assistance, Fixed & Adjustable Rate, FHA, VA & USDA, and Jumbo Home Loans (Exhibit 5). Additionally, there is a section to log in that provides fields to enter an account number and password (Exhibit 6).
6. The website indicates the physical location for Espana’s corporate office is Boulevard Maurice Lemonnier 125,
1000 Bruxelles; however, it lists routing and NMLS numbers associated with an unrelated, registered financial entity in Florida (Exhibit 7). The website also displays in its section “Giving Back” pictures that correspond to charitable events that have been published on the unrelated financial entity's website (Exhibit 8).
7. On April 8, 2026, I verified Espana is not, and has never been, a chartered or licensed financial institution through
research and review of information found on the website National Information Center (NIC) which is a repository of financial data and institution characteristics collected by the Federal Reserve System on financial institutions ATTACHMENT A

VERIFIED DOCUMENT BY WRITTEN DECLARATION
Page 2 of 3
worldwide (Exhibit 9). Furthermore, I confirmed that Espana is not, and has never been, a member of the Federal Deposit Insurance Corporation (FDIC) (Exhibit 10). I have confirmed that Espana has never been registered to lawfully operate as a business entity in Florida based on research and review of the Florida Department of State, Division of Corporations, at Sunbiz.org.
8. On April 9, 2026, I verified Espana is not and has never been registered with the Financial Industry Regulatory
Authority, through research and review of information found on the website FINRA.org (FINRA), which is a self￾regulatory organization for member broker-dealers that is responsible under federal law for supervising member firms. I further confirmed that the entity is not and has never been licensed with the Office of Financial Regulation (OFR).
9. On April 13, 2026, using open-source tools such as WHOis.domaintools.com and ICANN.org, I found the
Registrar of espanatoplegionfinance.com is Hostinger International Ltd, and the website was registered on December 25, 2022 (Exhibit 11). According to Sitereport.NetCraft.com, the IP Address associated with the website creation is 64.20.38.219, which ARIN shows was registered on April 7, 2005 (Exhibit 12). Google search indicates that the website was first indexed in December 2022 (Exhibit 13). Utilizing WebsiteSEOChecker shows the espanatoplegionfinance.com website does not receive enough traffic for daily and/or monthly figures to register (Exhibit 14).
10. On March 23, 2026, I served subpoena # 2026-12 to Hostinger International Ltd (“Hostinger”) to identify the
owner of the domain espanatoplegionfinance.com. On March 24, 2026, the subpoena recipient provided information showing that the email address associated with Espana’s website is davidbakers1990@airsworld.net. Using open-source tools such as Usercheck.com, I found that airsworld.net (the e-mail domain server associated with the e-mail account) operates as a disposable email domain, also known as a temporary or throwaway email service. These domains are often used to create short-lived email accounts with mailboxes that typically exist only briefly. The production also indicated that the IP address associated with the most recent login is 45.130.203.163 on 1/08/2026. Subsequently, I asked Hostinger to provide additional information that assists in determining the domain owner.
11. On April 3, 2026, upon reviewing further information provided by Hostinger, I found that the domain owner is
David Baker, whose registered address, according to the records received is, 30 Fletcher Street, Bondi, New South Wales, 2026, Australia, with the phone number +61 876-548-2670. The most recent payment made by the user was on 1/08/2026 through Coingate.com for $20.19 to renew the domain for 1 year.
12. On June 18, 2026, I inquired of Tammie Dull, the Records Custodian for the Florida Office of Financial
Regulation, Division of Financial Institutions (the state agency responsible for chartering all state financial institutions), as to the licensure or registration status of Espana Top Legion Finance. She confirmed there was no record of registration for that entity with the Office. Websites Utilized

1. Federal Deposit Insurance Corporation’s (FDIC) Details and Financials Institutions – Institutions
   Directory website at https://www7.fdic.gov/idasp/advSearchLanding.asp
2. Federal Financial Institution Examination Counsel’s NIC website at https://www.ffiec.gov/NPW
3. Financial Industry Regulatory Authority website at https://brokercheck.finra.org/
4. REAL System Regulatory Enforcement and Licensing website at
   https://real.flofr.gov/datamart/selSearchType.do
5. Florida Department of State, Division of Corporations at www.sunbiz.org
6. Google Search at https://www.google.com/search?q=About+https://www.espanatoplegionfinance.com/
7. Who is Domain Lookup at https://whois.domaintools.com
8. ICann Look Up at www.Lookup.icann.org
9. American Registry for Internet Numbers at www.Arin.net

VERIFIED DOCUMENT BY WRITTEN DECLARATION
Page 3 of 3
10. Website SEO Checker at www.websiteseochecker.com
11. User Check at https://www.usercheck.com/domain/hldrive.com
Pursuant to Section 92.525, Florida Statutes, under penalties of perjury, I declare that I have read the foregoing document and that the facts stated in it are true. /s/ Reina Rivero Dated: June 18, 2026

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