This is an enforcement action by a US state regulator against a licensed money services business for violations of money transmission and AML regulations under Florida law.
Enforcement - Payments Institution (75%)The violations include failure to maintain AML programs and file Currency Transaction Reports, which are core anti-money laundering compliance obligations relevant to payments institutions.
The Final Order explicitly identifies multiple AML/CTF violations including failure to develop and maintain an effective Anti-Money Laundering Program under 31 CFR 1022.210, failure to file Currency Transaction Reports timely, and failure to maintain customer files — all core AML/CTF compliance obligations.
Enforcement - Financial Penalty (92%)The OFR's enforcement action resulted in license surrender and 20-year prohibitions on reapplication and control person roles, constituting a formal enforcement action with permanent license revocation consequences.
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
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 -153 STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re: CASH SERVICES INC Case Number: 118110 D/B/A CASH BLVD, WENDY MOSER, and TOM MOSER, 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. \71¾ DONE and ORDERED this day of March, 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 to Cash Services Inc d/b/a Cash Blvd, Wendy Moser, and Tom Moser by electronic mail at inc4259@gmail.com on this ~ y of March, 2026. ncial Regulation ost Of c ox 8050 ee, FL 32314-8050 Email: Agency.Clerk@flofr.gov Tel: (850) 410-9889 2 EXHIBIT A STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION In Re: CASH SERVICES INC D/B/A CASH BLVD, Case Number: 118110 WENDY MOSER, and TOM MOSER, Respondents. STIPULATION AND CONSENT AGREEMENT The State of Florida, Office of Financial Regulation ("Office"), and CASH SERVICES INC D/B/A CASH BLVD, WENDY MOSER, and TOM MOSER (together as "Respondents"), in consideration of the mutual promises herein, recite, stipulate, and agree as follows: 1. Back~round. At all times material hereto, CASH SERVICES INC d/b/a CASH BL VD, is and has been a money services business in the State of Florida, having been issued license number FT30800150. At all times material, Wendy Moser is and has been Vice-President and 50% owner of Cash Services. At all times material, Thomas Moser is and has been President and 50% owner of Cash Services. The Office conducted an examination (No. 109832) of Respondents' business records and operations to ascertain compliance with chapter 560, Florida Statutes, for the period of January 1, 2020 through December 31, 2021. In lieu of continuing formal proceedings, the parties are 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 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 neither admit nor deny but consent to the Office making the following findings: a) Respondents failed to timely enter required information into the check cashing database ("CCDB"), or entered inaccurate information, in violation of section 560.310(2)( d), Florida Statutes, and Rule 69V- 560. 704(5), Florida Administrative Code; b) Respondents failed to timely and accurately file Currency Transaction Reports ("CTR"), as required by rule, in violation of section 560.123(3)( c) , Florida Statutes; c) Respondents failed to maintain complete corporate customer files, in violation of section 560.310(2)(a), Florida Statutes, and Rule 69V- 560.704(4 )( d), Florida Administrative Code; d) Respondents failed to include an attestation by the compliance officer in each customer file that it was reviewed and updated annually, in violation of section 560.310(2)(a), Florida Statutes, and Rule 69V-560.704(4)(e), Florida Administrative Code; e) Respondents failed to include required information in their deferred presentment transaction agreements, in violation of section 560.404(3), Florida Statutes, and Rule 69V-560.904(1)(a), Florida Administrative Code; f) Respondents failed to include required information in their deferred presentment installment transaction agreements, in violation of section Page 2 of 11 560.404(3), Florida Statutes, and Rule 69V-560.904(1 )(b ), Florida Administrative Code; g) Respondents failed to maintain a copy of each transaction agreement between the DPP and the drawer that met the requirements of Rule 69V- 560.904, Florida Administrative Code, in violation of Rule 69V- 560. 707(1 )(b ), Florida Administrative Code, and thereby section 560.l 14(1)(a), Florida Statutes; h) Respondents failed to properly terminate all deferred presentment transactions, in violation of Rule 69V-560.903(1 ), Florida Administrative Code, and thereby section 560.114(1)(a), Florida Statutes; i) Respondents failed to accurately record information in the DPP Database, in violation of Rule 69V-560.908(4), Florida Administrative Code, and thereby section 560.114(l)(a), Florida Statutes; j) Respondents failed to maintain copies of a signed receipt for each transaction redeemed in cash that included the date, time, transaction number, and amount, in violation of section 560.405(3), Florida Statutes, and Rule 69V-560. 707(1 )(k), Florida Administrative Code; k) Respondents violated Rule 69V-560. 707(1 )( e ), Florida Administrative Code, and thereby section 560.114(l)(a), Florida Statutes, by failing to maintain required records relating to all returned personal checks; and, 1) Respondents violated 31 C.F .R. section 1022.210, and thereby section 560.l 14(l)(y), Florida Statutes, by failing to develop, implement, and maintain an effective Anti-Money Laundering Program. Page 3 of 11 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. SURRENDER OF MONEY SERVICES BUSINESS LICENSE. Respondents agree to voluntarily surrender money services business license FT30800150 upon the issuance of the Final Order adopting and incorporating this Stipulation and Consent Agreement. The license termination will be effectuated by the Office and any and all rights and privileges pertaining to the money services business licensee shall terminate commencing on the date the Final Order adopting and incorporating this Stipulation and Consent Agreement is docketed by the Office. b. FUTURE APPLICATION. Respondents shall not engage in any activity pursuant to chapter 560, Florida Statutes, which requires a license from the Office unless properly licensed. Respondent, WENDY MOSER, shall not apply for any license pursuant to chapter 560, Florida Statutes, for a period of twenty (20) years from the date of entry of the Final Order adopting this Stipulation and Consent Agreement. Respondent, TOM MOSER shall not apply for any license pursuant to chapter 560, Florida Statutes, for a period of twenty (20) years from the date of entry of the Final Order adopting this Stipulation and Consent Agreement. Respondent, CASH SERVICES INC d/b/a CASH BLVD, shall not apply for any license pursuant to chapter 560, Florida Statutes, for a period of twenty (20) years from the date of entry of the Final Order adopting this Stipulation and Consent Agreement. Additionally, Respondent, WENDY MOSER Page 4 of 11 is prohibited from acting as a control person of a company licensed by the Office, or required to be licensed by the Office, for a period of twenty (20) years. Respondent, TOM MOSER is prohibited from acting as a control person of a company licensed by the Office, or required to be licensed by the Office, for a period of twenty (20) years. Any application will be evaluated in the usual statutorily established manner. The facts surrounding this Stipulation may be fully considered in any future licensing requests. 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 Page 5 of 11 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 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 Comply. 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. 9. Attorney'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. Page 6 of 11 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 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 pageJ Page 7 of 11 IJatc: January 29th 2026 -•-·-·· ·- . .. . ....•. --· (Signature) Name.': Wendy Mos~r Title: Vice-President and 50% Own~ Wendy Moser. as Vice-President and 50% Owner of Cash Services Inc d/h/a Cash Blvd, BEFORE ME by means of \f:Jphysical presence or '.] onlinc notarization, has sworn (or affirmed) that he or she has read and understands the foregoing agreement and voluntarily signed the same. SWORN TO AND SUBSCRIBED before me 1bi~ay of JOJ\~. 2026. (lrv Notary Public ANGELA ORTEGA Check the appropriate box: Commission ~ HH 496649 Expires June 25, 2028 (g"' Personally known D OR Produced lde1Hification D Type of identification produced Driver's License D Passport D Other ____ (Do not include ID number) Pagc8 of 11 rn '\SH St,:Ut\H:ES INl' dth/ll CASH Ht.VI>: Date: January29tb 2026 (~ignamrcl )fame: Tom Moser Title: President an_g ~0°✓o Owner ot--i State 1.)f -, , d (;{ l(J(!1 County of ~ '-f Tom Moser, as President and 50% Owner of Cash Services Inc d/b/a Cash Blvd, BEFORE ME by means of C:r physical presence or online notarization, has sworn (o r affirmed) that he or she has read and understands the foregoing agreement and voluntarily signed the same. SWORN TO AND SUBSCRIBED before me this~f+...day of Tunu.o-rL , 2026. ~ne~ ~ Notary Public ANGELAORTEGA Check the appropriate box: Commlssion # HH 496649 Expires June 25, 2028 Personally known ~ D OR Produced Identification D Type of identification produced Driver's License D Passport 0 Other (Do not include ID number) Page 9 of II January _?9th 2026 "i,m1c. Wendy Mos~r State ·t:k_,(1..Ciu_ l)f .Ll\.C ·\'-I (. 'nunty of-8 \\'~nuy \1oscr. BEFORE ME by means of er"physical presence or on line notarization, hal.\ sworn tor affinned} that he or she has read and understands the foregoing agreement and voluntarily signed the same. SWOR!'i TO Al'iD SUBSCRIBED before me thid'{J'-day of~{Cl('l.,~ , 2026. (1N~ Notary Public Check the appropriate box: E:Y Personally known ANGELA ORTEGA D Commission# HH 496649 OR Produced Identification Expires June 25, 202.8 O Type I identification produced Driver's License 0 Passport D Other (Do not include 10 number) Pa11~ 10 uf 11 J ' I Jah ; January 29th 2026 (lH ( / Q ~tatr \)f ~--, ~;A Lu Ch J_ Count) or fom !-.fo:-('r. BEFOIU: 1\tE hy means of ~1ysical prcscm:c or 011linc notarization, ha!, ~worn 1or ..iHinncd) that he or she has read and understands the foregoing agreement and voluntarily signed the same. SWORN TO A~D SUBSCRIBED before me thi~day of ~an1,;({)'.A'Lf' , 2026. (lf\k/-!-0 ~ Notary Public Check the appropriate hllX: U1 Personally known D AN~EI.AORTEGA OR Produced 1dcntitication Commission# HH 496649 0 C:..;il!'es June 25, 2028 Type of identification produced Driver's License □ Passport □ Othl'I (Do not include ID number) OFFICE Of FINANCIAL REGULATION d ~ C.~k 3/17/2026 Date: Gregory (.<>ah.Director D1\'i,ion of< ·onsumc!r Finance l'a~dl I ti