TITLE: Florida Office of Financial Regulation Settles Enforcement Action Against Las Tres Banderas Money Services Business BODY: On February 25, 2026, the Florida Office of Financial Regulation (OFR) entered a Final Order approving a Stipulation and Consent Agreement with Las Tres Banderas 3 Inc, operating as Las Tres Banderas 4, Las Tres Banderas 6, and Las Tres Banderas 7, along with individual owners Pedro Espana and Heidy Espana (Case Number 132192). The settlement resolves compliance violations identified during an examination covering January 1, 2023, through December 31, 2024. Las Tres Banderas 3 Inc is a Part III Money Services Business licensed under Florida Statutes Chapter 560, with Pedro Espana serving as Chief Executive Officer, Compliance Officer, and 50 percent owner, and Heidy Espana as 50 percent owner. The OFR identified eight categories of violations, including failure to provide customers with toll-free contact information or the OFR's address and telephone number; failure to implement and maintain an adequate anti-money laundering (AML) program; failure to conduct annual AML training and independent reviews; failure to maintain records of customer identification; inaccurate or untimely entries into the Check Cashing Database; failure to timely report changes in bank information; failure to accurately or timely file Currency Transaction Reports; and failure to maintain copies of payment instruments. Under the settlement terms, the respondents agreed to pay an administrative fine of $28,875.00 and to cease and desist from future violations of Chapter 560, Florida Statutes. The respondents waived their right to an administrative hearing and appeal. The Final Order incorporates all terms of the Stipulation and Consent Agreement and constitutes final agency action.

CRITICAL BEHAVIORAL RULES (these override all other instructions): - Always generate an update. Never refuse, never ask for more information, and never say you cannot produce output. - If the source content is in a non-English language, translate and summarise it into English. - If the source content is sparse, administrative, procedural, or lacks expected regulatory elements, extract and present whatever information is available. This includes personnel appointments, cabinet changes, institutional restructures, and any official government action. - Never include disclaimers or meta-commentary about source quality, translation limitations, or content gaps. - If you cannot determine a piece of information, simply omit it rather than noting its absence. - Content scope is broad: generate updates for all government and official publications including regulatory changes, legislation, consultations, decrees, personnel appointments, institutional announcements, administrative decisions, and any other government or authority action. Do not filter by topic relevance. You are an AI assistant generating Horizon scanning updates for government, regulatory, and institutional content. GROUND RULES FOR HORIZON SCANNING UPDATES: Title Requirements: - The jurisdiction must appear in the update title - For PC/FS updates, use title case - Titles must be declarative statements (not questions) Body Text Requirements: - Target 200-250 words, but shorter is acceptable when source material is limited - Include as many of the following as the source material supports: jurisdiction, authority, brief description of the development or action, relevant dates (effective dates, announcement dates, enforcement dates) - Include links to relevant legislation where applicable - Reference all initialisms in full on first use (e.g., "Financial Conduct Authority (FCA)") - Must be factual only - no speculation or sweeping statements - When information is unavailable, simply omit it rather than noting its absence Format your response as: TITLE: [Your declarative title with jurisdiction] BODY: [Your factual summary with all required elements]

Horizon Scanning Outline. Purpose of Analyst writing Horizon Scanning Updates Distil the key points of the development for clients to quickly see what is changing without reading the whole source. Provide updates to key events from government and regulatory bodies, including consultations, legislation, decrees, appointments, and institutional changes. Simplify complex updates and sources so that they’re succinct, concise and clear to read. Consistently structure and write updates in the same format. Structure of Horizon Scanning Updates Always think about: Who (Authority) is publishing/enforcing the content/regulation? Where (Jurisdiction)? What type of document or announcement is it (e.g., consultation, regulation, decree, appointment, institutional change)? What is changing/being informed? Who is this update applicable to (credit, e-money institutions, etc.)? Why is this update noteworthy? What is its significance? When is the update applicable? Title Describe what the update is about. Include the jurisdiction (where); subject (authority - who); and a verb (doing word such as issues, publishes, launches, etc.- what). All titles should be written in present tense. Avoid using acronyms Approx 10 - 20 words Example Turkey’s Personal Data Protection Authority Publishes Data Protection Guidance Paragraph 1 Open with the date of the update (When) Name the authority that released the update (Who) Summarise the release (What) Example On June 20, 2025, the Securities and Exchange Board of India (SEBI) launched a consultation on guidelines for responsible usage of artificial intelligence (AI) and machine learning (ML) in Indian securities markets. Paragraph 2 Summarise key points. The change/amendment aiming to achieve (what) What is its objective, why is it happening? Why is it significant? (why) Who does it impact or concern? (Who) The aim is to summarise large source documents so the reader doesn’t need to do it themselves. DO NOT just copy the first few sentences of the document. Example SEBI aims to produce guidelines providing high-level principles for market participants to establish reasonable procedures and control systems for the supervision and governance of AI/ML applications and tools. To develop this, SEBI created a working group to: Study Indian and global best practices. Prepare the guidelines. Address the concerns and issues arising from AI/ML usage. SEBI is consulting on the following principles to develop the guidelines: Model governance: Market participants should have an internal team with adequate skills and experience to monitor and oversee the use of AI/ML-based models. Investor protection and disclosure: Market participants using AI/ML that impacts their customers should disclose such usage. Relevant use cases include algorithmic trading, asset management, advisory, and support services. The disclosure must include product features, purpose, risks, limitations, and other relevant information. Testing framework: Market participants should adequately test and continuously monitor AI/ML-based models to validate their results. Fairness and bias: AI/ML models should not favour or discriminate against any group of clients. Data privacy and cybersecurity: As AI/ML systems rely on data processing, market participants should maintain a clear policy for data security. Paragraph 3 Acts as a “Call To Action”. Provide forward looking context: What actions need to be taken? Who needs to take action? Next steps to the development. Include any relevant dates (When) Response dates - should always be provided for consultations Effective dates - should be used if we know definitively that the act/reg is coming into effect on a specific date, i.e., it has been passed/adopted. Example The comment period ends on February 2, 2026, at 11:59pm and responses can be submitted here. The comment response is expected to be published in April 2026. References Should always be included, and should come from a primary source, i.e., an authority, not a news source. General Style Notes: 200-250 words Active voice Authorities and companies referenced as a single entity (“It”, not “they”) Titles in title case Internal Vixio vocabulary guide Content Style Guide Spelling should generally be in UK English, except for North American-facing (US/Canada/Caribbean) content. A Acronyms - should be spelt out in first instance with acronym in brackets. For example, Financial Conduct Authority (FCA). Act - when just referring to “the act”, it does not need a capital a. Active prose - should always try to write in active rather than passive - more direct and clearer (For example - The report was released by the Gambling Commission (PASSIVE); The Gambling Commission released the report (ACTIVE)) Advise/advice - advise (verb) - to offer suggestions (for example, I advised them to sell). - advice (noun) - give formal suggestions (for example, I gave them advice). Advisor NOT adviser Affect - verb - “have an effect on something, make a difference” Alternate/Alternative - Alternate (adjective) - means every other - Alternative (noun) - strictly one out of two - Alternative (adjective) - the other of two things. Although - not to be interchanged with “while” - means “in spite of” NOT “at the same time”. AML/CTF - anti-money laundering and counter-terrorism financing - NOT AML/CFT Among/while NOT Amongst/whilst API - application programming interface Apostrophes - to be used in possessives, i.e. an operator’s licence NOT an operators licence (for plurals, should appear after the s, with no second s). Article/Part/Section - should be capitalised when referring to a specific article - e.g., Article 4 of the Gambling Act. Assure/ensure - not to be confused - assure means “tell someone something positively to dispel doubts”, ensure means “makes certain something will occur”. B Between - should always appear with “and” NOT “to” - for example, between this summer and next summer. Big tech - two words, breaks convention of other tech words Bills - U.S. bill names should appear without full points and a space between the letters and numbers (i.e. SB 522 NOT SB522 or S.B. 522). Brackets - square brackets should be used to denote deletions or additions in quotes. Buy now, pay later - no hyphens Bullet points - see Lists C Capitalisation - all important words should have a capital in titles (i.e. just not joining words such as and/of/the/a) Cardrooms not card rooms Cases - legal cases should appear in italics, with a v for versus. Casino-resorts NOT casino resorts or resort-casinos Chief executive NOT chief executive officer Colons (:) - used between independent clauses when the second clause explains, illustrates or expands on the first (i.e. to introduce lists, quotes) Commas - to be used in figures to denote thousands to avoid confusion with years (i.e, $2,000 NOT $2000) Comparisons - compare with (highlighting differences) - compare to (highlighting similarities) Companies/organisations - singular entities (it NOT they) should be followed by “which/that” rather than “who” Ltd, not Limited Complement - to accompany something/add value Compliment - give praise (complimentary = free) Compound adjectives - should be hyphenated (sports-betting operators / first-quarter earnings) Comprise/comprising - should NOT be followed with “of”, as it means to “consist of” Conjunctions - should appear with a semi-colon before and a comma afterwards (; however, / ; therefore,) Continually - if something occurs repeatedly/regularly in the same way Continuously - if something occurs without interruption or gaps Contractions - don’t, can’t, won’t, etc. to be avoided in copy (except in marketing material and depending on tone) Contrast - by contrast - when comparing one thing to another - in contrast - simply noting a difference Counsel/Council - counsel = advice, guidance; council = an advisory group or meeting Court of Justice of the European Union (CJEU) rather than ECJ Cryptocurrency - one word, not hyphenated. Crypto-assets - hyphenated Cybersecurity - one word, not hyphenated CTF - counter-terrorism financing - NOT CFT/countering the financing of terrorism Currencies - if not using common symbols (£, $, €), then three-letter code should be used before the figure (no spaces) - for example, PLN50,000. Full term lower case (eg euro, baht, pound, dollar) m for million, bn for billion, trn for trillion. D Date format - Month, Day, Year (e.g., March 7, 2019) For Insights & Analysis summary text: can just say “today”, e.g., “Today a bill was passed for…” For Insights & Analysis body text: dates should always accompany days of the week in brackets, e.g., “On Wednesday (June 8) a bill was passed...” For NIBs: always use dates rather than days. Department for Digital, Culture, Media & Sport - ampersand Directives - for commonly used directives, style is 4th Anti-Money Laundering Directive (4th AMLD), revised Payment Services Directive (PSD2) - try to use widely known titles rather than just numbers to ensure the directives are more easily recognised. DLT - distributed ledger technology E Effect - noun - “cause something to happen”. Em dash (—) - should be used as a conjunction, not a hyphen or en dash (–). Ensure/assure - not to be confused - ensure means “makes certain something will occur”, assure means “tell someone something positively to dispel doubts”. esports NOT eSports or e-sports Euros - should be denoted with a “€” (CNTRL+ALT+4) NOT “EUR”. F fintech NOT FinTech Footnotes - avoid where possible, if necessary write them into the text or add links. G GGR - “gross gaming revenues” Government - does not need a capital g. Governor - should be written out in full, NOT Gov. Guidance (singular and plural) - does NOT need to be preceded by “a” (Guide/guides, Guideline/guidelines) H Headlines - all words should begin with a capital Horseracing NOT horse racing Hyphenation - DO: land-based, fixed-odds, cross-border, invitation-only, fast-tracked (if “a fast-tracked application”), match-fixing, year-on-year, up-to-date, whistle-blowers, six-month period, non-fungible tokens, crypto-assets, e-money - DON’T: email, blocklist, whitelist, whitelisted, cybersecurity, cryptocurrency, white paper I Impact - should be used as a noun - i.e. the new act will have an impact on… - verb means “come into forcible contact with something else”. - using “affect” as a verb is more accurate. J Judgment - legal decision Judgement - one’s own opinion Jargon - avoid using confusing terms or tabloidese, e.g. use players rather than punters. Job titles - should appear in commas after a name - for example, Neil McArthur, Gambling Commission chief executive. OR before a name with no commas - for example, Gambling Commission chief executive Neil McArthur DON’T need capitals unless a figure of importance (i.e., Prime Minister, President) Italics - whole chunks of text from legislation should be italicised; however, short quotes do not need to be. Justice Department - U.S. Department of Justice - to appear with caps (as requested by US team). K KYC - know your customer L Legislature - does not need a capital l. Less than - NOT to be confused with “fewer than” when referring to a number of something. i.e. fewer than 100 gambling tables. Licence - noun (UK), i.e. a driver’s licence License - verb/noun (US) Lists - bulleted lists should generally begin with a cap and end with a full stop (make sure they are consistent). M MONEYVAL NOT Moneyval More than - to be used instead of “over”. i.e., more than 20 players rather than over 20 players. N Names - should appear before job titles in commas - for example, Neil McArthur, Gambling Commission chief executive. Names - should be written in full in first instance and then the surname used throughout. Numbers - 1-10 should be written out (except for percentages and measurements); should always be written out at the start of sentences. Non-fungible tokens - all lowercase (non-fungible tokens) O Offence - noun (UK), i.e. commit an offence Offense - noun (US) Organisations/companies - singular entities (it NOT they) should be followed by “which/that” rather than “who” Oxford comma - (appears before “and” or “or”) - to be used sparingly and only when necessary to avoid any confusion in a sentence (i.e., where more than one “and/or” appears). Over - should not be used as a replacement for “more than”. P Parliament - does not need a capital p. Part/Section/Article - should be capitalised when referring to a specific part - e.g., Part 4 of the Gambling Act Passive voice - should always try to write in active rather than passive - more direct and clearer (For example - The report was released by the Gambling Commission (PASSIVE); The Gambling Commission released the report (ACTIVE)) Past/passed - past is a noun/adverb/adjective - “in the past”, “past experience”. - passed is the past tense of “to pass” - “the law was passed in government”. Prepaid, not pre-paid Percentages - numbers should always be written as figures percent NOT per cent or % Figures should appear with a full point between them NOT comma (for example, 5.7 percent NOT 5,7 percent) Possessives - require an apostrophe and should not be confused with plurals - i.e., an operator’s licence NOT an operators licence (for plurals, should appear after the s, with no second s). Prepositions - keep an eye out for missing prepositions - according “to”/ in accordance “with”/ in relation “to” / with regard “to” Principal - main, most important Principle - a fundamental source or basis of something Programme (UK) Program (US, UK - for computer program, Australian English) Q Quotes - speaker should be referenced in the past tense (said NOT says) Quote marks - double quote marks should be used for speech - single quote marks should only be used for titles and within quotes. (See Quote reference sheet for more information on how to use quotes.) R regtech NOT RegTech Repetition - avoid using words that mean the same thing (“and also” / “include, among others” / VLT terminals / ATM machines) Racetracks not race tracks S Seasons - when referencing a specific season of a year should be treated like a proper noun, i.e. should include a capital - Winter 2018. Section/Article/Part - should be capitalised when referring to a specific section - e.g., Section 4 of the Gambling Act. Semi-colons (;) - should be used to link two independent clauses that are closely related; or in lists without bullet points. (Do not overuse - often a full stop and new sentence will be better.) Sports betting NOT sportsbetting Sports team names Storey (pl. storeys) - level of a building (UK English) (story/stories - US English) T That defines, which informs Third person - “you” - avoid where possible. Titles - all important words should begin with a capital (i.e. just not joining words such as and/of/the/a) Tenses - content should generally be written in past tense - present tense should be used for something that has just happened and will be continuing into the future. U United States abbreviated to U.S. (Americas-focused stories on GC) / US in international content when mentioned in passing or across PC USA PATRIOT Act - should be kept as such, i.e. with caps, as it’s an acronym for “Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act”) U.S. Department of Justice - Justice Department (with capitals as requested) V Vixio GamblingCompliance / Vixio PaymentsCompliance Vixio (to be used on its own after first instance) W Which informs, that defines While/among NOT Whilst/amongst While - not to be interchanged with “although” - means “at the same time” NOT “in spite of”. X Y Year quarters - Q1, Q2, H1, H2, etc. Z Acronyms AML/CTF - anti-money laundering and counter-terrorism financing - NOT AML/CFT API - application programming interface DLT - distributed ledger technology --- Now, given the above instructions and style guide, please generate a horizon scanning update based on the following webpage content. Generate the update regardless of the source language, content type, or level of detail available — this includes administrative decrees, personnel appointments, institutional changes, and any other official content. Use whatever information is present. Index: OFR 2026 - 118 STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re: LAS TRES BANDERAS 3 INC, Case Number: 132192 D/B/A LAS TRES BANDERAS 4, LAS TRES BANDERAS 6, LAS TRES BANDERAS 7, PEDRO ESP ANA, and HEIDY ESPANA, 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 ~ day of February, 2026, in Tallahassee, Leon County, Florida. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Final Order has been furnished to Las Tres Banderas 3 Inc, d/b/a Las Tres Banderas 4, Las Tres Banderas 6, Las Tres Banderas 7, Pedro Espana and Heidy Espana by electronic mail at jomirodriguez@hotmail.com; espafia pedro@yahoo.com; and tresbanderasl@yahoo.com on this 'Z,.G~ y of February, 2026. egulation 050 Tallahassee. 32314-8050 Email: Agency.Clerk@flofr.gov Tel: (850) 410-9889 2 Exhibit A STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re: LAS TRES BANDERAS 3 INC, Case Number: 132192 D/B/A LAS TRES BANDERAS 4, LAS TRES BANDERAS 6, LAS TRES BANDERAS 7, PEDRO ESPA NA and HEIDY ESPANA, Respondents. STIPULATION AND CONSENT AGREEMENT The State of Florida, Office of Financial Regulation ("Office"), and LAS TRES BANDERAS 3 INC, D/B/A LAS TRES BANDERAS 4, LAS TRES BANDERAS 6, LAS TRES BANDERAS 7, PEDRO ESPANA and HEIDY ESPANA ("Respondents"), m consideration of the mutual promises herein, recite, stipulate, and agree as follows: 1. Background. At all material times, Las Tres Banderas 3 Inc, d/b/a Las Tres Banderas 4, Las Tres Banderas 6, and Las Tres Banderas 7, is and has been a Part ill Money Services Business in the State of Florida, having been issued license number FT340001030. At all times material, Pedro Espana is and has been the CEO, Compliance Officer, and Fifty Percent (50%) Owner of Las Tres Banderas 3 Inc, d/b/a Las Tres Banderas 4, Las Tres Banderas 6, and Las Tres Banderas 7. At all material times, Heidy Espana is and has been Fifty Percent (50%) Owner of Las Tres Banderas 3 Inc. d/b/a Las Tres Banderas 4, Las Tres Banderas 6, and Las Tres Banderas 7. The Office conducted an examination (No. 128145) to ascertain Respondents' compliance with chapter 560, Florida Statutes, for the period of January 1, 2023, through December 31, 2024. In lieu of initiating a formal proceeding, the parties resolve the matters at issue herein. 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 provide each customer with a toll-free telephone number for the purpose of contacting the money services business or, in lieu of a toll-free telephone number, the address and telephone number of the Office, in violation of section 560.128(1 ), Florida Statutes; b) Respondents failed to implement and maintain an accurate Anti-Money Laundering (AML) Program in accordance with 31 C.F.R. s. 1022.210(d)(l)(i) and as required by section 560.1235(2). c) Respondents failed to implement and maintain an Anti-Money Laundering (AML) Program by failing to conduct and maintain records of annual AML training and conduct effective independent reviews, in violation of 31 C.F. R. Chapter X, and thereby section 560.114(1)(y), Florida Statutes; d) Respondents failed to maintain records of acceptable personal identification presented by a conductor in violation of section 560.310(2)(b) , Florida Statutes and thereby Rule 69V-560. 704( 4)( c) , Florida Administrative Code; e) Respondents entered inaccurate information into the Check Cashing Data Base ("CCDB") and failed to timely enter required information into the CCDB, in 2 violation of section 560.310(2)( d), Florida Statutes and Rules 69V-560. 7042(1 )-(2) and 69V-560.704(5), Florida Administrative Code; t) Respondents failed to report changes in the bank information contained in their application within 30 days of the change, in violation of Rule 69V-560.201(2), Florida Administrative Code, thereby section 560.126(2), Florida Statutes; g) Respondents failed to accurately or timely file Currency Transaction Reports ("CTRs") and failed to file CTRs, in violation of section 560.123(3)( c ), Florida Statutes; h) Respondents failed to maintain a copy of the front and back of a payment instrument, in violation of Rule 69V-560.704(2)(a), Florida Administrative Code, and thereby section 560.114(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 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 future violations of chapter 560, Florida Statutes, and the rules promulgated thereunder, and comply with all the provisions of chapter 560, Florida Statutes, and the rules promulgated pursuant thereto. ,., .) b. ADMINISTRATIVE FINE. Respondents agree to pay the Office an administrative fine in the amount of Twenty-Eight Thousand Eight Hundred Seventy-Five Dollars ($28,875.00), 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 "Office of Financial Regulation". Such payment shall reference Case Number 132192 and sha11 be sent to the attention of Agency Clerk - c/o Debra H. Pierce, 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 fu11 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. 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. If 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: 4 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 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 Complv. 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. 5 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, modifications, or waivers oft he 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 LAS TRES BANDERAS 3 INC, d/b/a LAS 1RES BANDERAS 4, LAS TRES BANDERAS 6, d A.'i TRES BANDE:S 7: ~ ~~~-. o;J~ ~ Date: (Signature) Name: Pedro Espana Title: CEO. Compliance Officer and Fiflv percent (50%) Qwn~t State of-::Env:idq ~(a County of Pedro Espana, as CEO, Compliance Officer and Fifty percent (50%) Owner of Las Tres Banderas 3 Inc, d/b/a Las Tres Banderas 4, Las Tres Banderas 6, and Las Tres Banderas 7, BEFORE ME by means of !'.J,pb Ysical nresence or D online notarization, has sworn ( or affirmed) that he has read and understands the foregoing agreement and voluntarily signed the same. K,,~~-Ld SWORN TO AND SUBSCRIBED before me this__k_ day of ,2026. N~~ Check the appropriate box: D Personally known D OR Produced ldentification l2f' Type of identification produced Driver's License D Passport D Other (Do not include ID number) 7 PEDRO ESP ANA: ~~-~ Date: (Signature) Name: Pedro Espana Bn oda State of Cbc.evla County of Pedro Espana, BEFORE ME by means of@, phvsical uresence or O online notarization, hlis sworn (o r affirmed) that he has read and understands the foregoing agreement and voluntarily signed the same. tl-bw. _le_ SWORN TO AND SUBSCRIBED before me this day of ,2026. ~~1-- ...- ,,~~v"i'i;;,,: M,\RTH,\ !SABEi. CHAVES tf'(f- i..\~;-r:· Mut;:ry Public· Sl:~k ('f Flurida l1!~\c j(_,i ,~(r Coi1;m1~'.,ion II !l!! 277078 ~ \°':'i_c;,-~(1,.{ l~y Cumrn. [xp:n. .• ·, h·b 9 2026 Bonded through Nnliun.il Nolu, 1 y A11n. t Check the appropriate box: 0 Personally known D OR Produced Identification EJ Type of identification produced Driver's License D Passport 0 Other (Do not include ID number) 8 RAS 3 I 'C, d/b/a LAS TRES BANDERAS 4, LAS TRES BANDERAS 6, B DERA ' 7: O:z/Qi Date: /c2-01fl((; __ Title: Fifty percent (50%) Owner State of '"'fto (id,a o-;-rJbwl.a County Heidy Espana, Responsible Person and Fifty percent (50%) Owner of Las Tres Banderas 3 lnc, 4/b/a Las Tres Banderas 4, Las Tres Banderas 6, and Las Tres Banderas 7, BEFORE ME by means of~ physical preseocie or D online n9t_arization, has sworn ( or affirmed) th~t sh~ has read ~Il~ understands the foregoing agreement and voluntarily signed the same. Jo_ SebrU'.).(~ SWORN TO AND SUBSCRIBED before me this day of ,2026. i\~ ~Pubhc Check the appropriate box: D Personally known D OR Produced Identification 12( Type of identification produced Driver's License D Passport D Other (Do not include ID number) 9 Date: Name: Heidy Espana --:rw cl.a State of '(1 Ds~ki County of H~igy gsp~a, BEFORE ME by means <:>f Qi physical presence or D online notarization, h~ sworn (or affirmed) that she has read and understands the foregoing agreement and vohmtarily signed the same. 1Zb tJ io.._ nxt( SWORN TO AND SUBSCRIBED before me this day of ,2026. ~ Check the appropriate box: D Personally known D OR Produced Identification f1' Type of identification produced Driver's License 0 Passport 0 Other _______ (Do not include ID number) OFFICE OF FINANCIAL REGULATION f:!:ttti1.. £,;ctf,k 2/25/2026 Date: Division of Consumer Finance

SKM_C450i26022618300

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