CONSENT ORDER

RAMAD PAY, INC.

WHEREAS, Ramad Pay, Inc. (“Ramad Pay”) is a Minnesota corporation with headquarters in Minneapolis, Minnesota, and an assigned identifier number 1139908 by the Nationwide Multistate Licensing System (“NMLS”).

WHEREAS, the States of Colorado and Texas (individually, a “Participating State,” and collectively, the “Participating States”) have each agreed, through their respective state money transmission regulatory agencies, to negotiate and enter into this Consent Order (hereinafter referred to as the “Order”).

WHEREAS, the Participating States are respective members of the Conference of State Bank Supervisors (“CSBS”) and the Money Transmitter Regulators Association (“MTRA”) and have agreed to address enforcement concerns with Ramad Pay in a collective and coordinated manner. The Participating States and Ramad Pay are collectively referred to herein as the “Parties.”

WHEREAS, Ramad Pay is licensed as a money transmitter under the respective laws of each Participating State.

WHEREAS, on or about May 26, 2025, the Participating States commenced a multi-state examination (the “Multi-State Examination”) of Ramad Pay in order to determine Ramad Pay’s compliance with applicable state and federal laws and regulations, financial condition, and the adequacy of policies and procedures and the control and supervision of the licensed money transmittal operations. The Multi-State Examination was conducted by the State Money Transmission Regulators from the Participating States pursuant to their respective statutory authorities and in accordance with the Protocol for Performing Multi-State Examinations, as well as the Nationwide Cooperative Agreement for MSB Supervision. The Report of Examination was issued by the Participating States to Ramad Pay on October 23, 2025 (the “Report of Examination”), and described and cited Federal and state-specific compliance violations and deficiencies including, but not limited to:

a. Participating in failures to timely file currency transaction reports (“CTRs”) as required by 31 C.F.R. § 1010.306 and failures to timely file reports of transportation of currency or monetary instruments (“CMIRs”) as required by 31 C.F.R. § 1010.340;

b. Issues relating to implementation of the Company’s Anti-Money Laundering/Countering the Financing of Terrorism (“AML/CFT”) program relating to monitoring domestic agents and ensuring adequate independent reviews; and

c. Issues relating to compliance with requirements for safeguarding consumer financial information in 16 C.F.R. part 314, including failure to adequately identify and manage devices and software systems.

WHEREAS, based on the findings in the Report of Examination, the Participating States engaged in direct discussions with Ramad Pay’s Board of Directors (the “Board”) and senior management to identify steps Ramad Pay should take to improve compliance and manage risk, and otherwise to ensure safe and sound operations as part of the Multi-State Examination resolution process.

WHEREAS, Ramad Pay does not admit any wrongdoing, allegations, or implications of fact, and does not admit any violations of applicable laws, regulations, or rules governing the conduct and operation of its money transmittal business.

WHEREAS, Ramad Pay acknowledges that the Participating States have and maintain jurisdiction over the underlying dispute.

WHEREAS, Ramad Pay represents that it has implemented, and will continue to maintain, procedures designed to ensure that Ramad Pay has complied with all regulatory requirements imposed by each individual Participating State.

WHEREAS, the Participating States have legal authority to initiate administrative actions based on the conduct described in the Report of Examination, and reserve all of their rights, duties, and authority to enforce all statutes, rules, and regulations under their respective jurisdictions against Ramad Pay regarding any money transmission activities and/or other activities.

WHEREAS, Ramad Pay hereby knowingly, willingly, voluntarily, and irrevocably consents to the execution of this Order pursuant to the authority vested in each Participating State and agrees that it understands all of the terms and conditions contained herein. Ramad Pay acknowledges that it has full knowledge of its rights to notice and a hearing pursuant to the laws of the respective Participating States. By voluntarily entering into this Order, Ramad Pay waives any right to notice and a hearing, and review of such hearing, and also herein waives all rights to any other judicial appeal concerning the terms, conditions, and related obligations set forth in this Order. Ramad Pay further acknowledges that it has consulted with independent legal counsel in connection with its waiver of rights and with the negotiation and execution of this Order.

WHEREAS, Ramad Pay represents that the person signing below is authorized to execute this Order and to legally bind Ramad Pay.

NOW, THEREFORE, it is by the Participating States listed below hereby ORDERED:

I. JURISDICTION

1. Pursuant to the licensing and supervision laws of the Participating States, the Participating States have jurisdiction over Ramad Pay as described herein and may enforce the terms of this Order thereon.

II. RISK AND COMPLIANCE PROGRAMS

1. Compliance Consultant: Within 90 days of the effective date of this Order, Ramad Pay will present evidence that it has engaged a qualified, independent, and unaffiliated third-party compliance consultant (“Compliance Consultant”) to augment its AML/CFT program. The scope of the Compliance Consultant’s engagement must include, but is not limited to: (1) a quarterly written review and verification of all corrective action required in response to the deficiencies identified in the Report of Examination and as required by this Order; (2) quarterly reviews of Ramad Pay’s SAR processes to ensure the timely detection, investigation and reporting of suspicious activity, with a particular focus on closed accounts; and (3) quarterly independent testing of transaction data to verify the effectiveness of Ramad Pay’s internal controls and data integrity systems. A copy of the engagement letter for the Compliance Consultant must be submitted with the response to this Order. The Compliance Consultant must submit a copy of any reports issued to Ramad Pay in connection with this engagement directly to the Participating States within 30 days of issuance of such reports. The engagement of the Compliance Consultant and quarterly reviews are required for a period of one year following the Effective Date of this Order, subject to each Participating State’s right to determine—in its sole discretion—that these requirements may be extended to a period of one additional year (i.e., for a total of no-more-than two years following the Effective Date of this Order).

2. Ramad Pay shall implement or continue to implement, as applicable, measures to comply with its obligations under this Order and will hereafter continue to comply with all regulatory requirements including establishing, implementing, and maintaining an updated AML/CFT compliance program commensurate with the financial services provided by Ramad Pay. The updated AML/CFT compliance program shall include, but not be limited to: ensuring compliance with all State and Federal laws and regulations applicable to a money transmission corporation having the size, complexity, and overall risk profile of Ramad Pay. Ramad Pay shall review these policies and procedures on a frequency commensurate with the company’s risk profile, but at least annually.

3. AML/CFT Monitoring. a. Within 90 days of the effective date of this Order, Ramad Pay will review and adjust its AML/CFT monitoring systems and procedures to detect suspicious activity in a timely manner and ensure adequate levels of personnel and resources are dedicated to manage the amount and complexity of case alerts to ensure timely filings of CTRs, CMIRs, suspicious activity reports, and other filings required by applicable regulations of the Financial Crimes Enforcement Network (FinCEN). b. Within 90 days of the effective date of this Order, Ramad Pay will strengthen its due diligence procedures to reduce exposure to AML/CFT risk.

4. Data Integrity: Within 90 days of the effective date of this Order, Ramad Pay shall institute a more robust program to ensure customer information is accurate, complete, valid, and properly reflected in regulatory reporting as required under the FinCEN regulations. This program shall implement controls to verify and collect customer account data, in accordance with the “Know Your Customer” guidelines and procedures detailed by FinCEN and its applicable AML/CFT regulations, as detailed in the Report of Examination.

5. Independent Review: Due to Ramad Pay’s failure to address past deficiencies identified in prior examinations, as well as in a prior independent review, Ramad Pay shall provide for an independent review of its AML/CFT program on a periodic basis, but at least annually, commensurate with the AML/CFT risk posed by its operations. This independent review shall adhere to the requirements set forth in 31 C.F.R. § 1022.210, and shall determine the strength of Ramad Pay’s AML/CFT program in comparison to those requirements.

6. Ramad Pay agrees to address all violations and take all required actions specified in the Report of Examination. Ramad Pay further agrees to address and implement all corrective actions described in the Report of Examination that are not specifically addressed by the provisions of this Order.

7. Ramad Pay shall furnish written progress reports to the Participating States on a quarterly basis for a period of one year, subject to each Participating State’s right to determine—in its sole discretion— that these requirements may be extended to a period of one additional year (i.e., for a total of no-more-than two years following the Effective Date of this Consent Order. Such reports shall be due by the 45th day following the end of the quarter, e.g., the report for the quarter ending March 31 is due on May 15. The progress reports shall detail the form, content, and manner of any actions taken to address each section of this Consent Order, and will describe, in detail, any other AML/CFT compliance initiatives instituted during the calendar quarter and the results thereof. Each progress report submitted to the Participating States pursuant to this section of the Consent Order will be reviewed and signed by a duly authorized senior officer of Ramad Pay.

III. ADMINISTRATIVE PENALTY

1. Ramad Pay shall pay an administrative penalty of two hundred thousand dollars ($200,000) to be evenly divided among the Participating States. Ramad Pay may pay this amount in four quarterly installments of $50,000 each, evenly divided among the Participating States, with such payments due on or before July 1, 2026, October 1, 2026, January 1, 2027, and April 1, 2027.

2. In the event that Ramad Pay fails to submit any administrative penalty set forth in this Order in the amounts specified herein and in accordance with the applicable deadlines, or if any transfer of any monetary amount required under this Order is voided by a Court Order, including a Bankruptcy Court Order, Ramad Pay agrees not to object to a Participating State submitting a claim, nor attempt to defend or defeat such authorized claim, for any unpaid amounts against any surety bond that Ramad Pay may maintain in such Participating State. Ramad Pay shall follow Internal Revenue Service requirements under 26 U.S.C. § 6050X and provide a W-9 tax form to the Participating States upon execution of this Consent Order.

IV. ENFORCEMENT

1. No Restriction on Existing Authority. This Order shall in no way preclude any Participating State from exercising its examination, investigative, or enforcement authority under the laws of the corresponding Participating State.

2. No Further Action. No further action will be taken by the Participating State against Ramad Pay, Ramad Pay’s agents or representatives, or Ramad Pay’s current and former parent corporations or other forms of legal entities, direct and indirect subsidiaries, brother or sister corporations or other forms of legal entities, divisions or affiliates, and the predecessors, successors, and assigns of any of them, as well as the current and former directors, officers, and employees (collectively, the “Released Parties”) for the conduct set forth in this Order, or in connection with the remediation set forth in this Order, provided that Ramad Pay demonstrates and provides evidence of reasonable good faith efforts to fully comply with the terms of the Order.

3. Enforceability of Order. Notwithstanding any other relief to the contrary, if Ramad Pay fails to comply with the terms and conditions of this Order, the Participating States may pursue any action allowed by law concerning the conduct and compliance violations stated in the Report of Examination, such action including, but not limited to, suspension or revocation of a license issued by the Participating State to Ramad Pay, imposition of a civil money penalty against Ramad Pay, or any other remedy allowed by law. The Parties agree that the failure of Ramad Pay to comply with any term or condition of this Order with respect to a particular State shall be treated as a violation of an Order of the State and may be enforced as such. Moreover, Ramad Pay acknowledges and agrees that this Order is only binding on the Participating States and not any other Local, State or Federal Agency, Department or Office.

V. GENERAL PROVISIONS

1. Effectiveness. This Order shall become effective upon execution by all of the named Participating States (the “Effective Date”).

2. Public Record. This Order shall become public upon the Effective Date.

3. Disclosure. Ramad Pay understands, agrees, and acknowledges that this Order is considered a disciplinary action, and it shall properly disclose this Order in NMLS.

4. Binding Nature. The terms of this Order shall be legally binding upon Ramad Pay’s officers, owners, directors, employees, heirs, successors, and assigns. The provisions of this Order shall remain effective and enforceable except to the extent that, and until such time as, any provisions of this Order shall have been modified, terminated, suspended, or set aside, in writing by mutual Order of the Participating States acting collectively or severally.

5. Standing and Choice of Law. That each Participating State has standing to enforce this Order in the judicial or administrative process otherwise authorized under the laws and regulations of the corresponding Participating State. Upon entry, this Order shall be deemed a final order of each respective Participating State unless adoption of a subsequent order is necessary under the laws of the corresponding Participating State. In the event of any disagreement between any Participating State and Ramad Pay regarding the enforceability or interpretation of this Order and compliance therewith, the courts or administrative agency authorized under the laws of the corresponding Participating State shall have exclusive jurisdiction over the dispute, and the laws of the Participating State shall govern the interpretation, construction, and enforceability of this Order.

6. Titles. The titles used to identify the paragraphs of this Order are for the convenience of reference only and do not control the interpretation of this Order.

7. Final Order. This Order is the final written expression and the complete and exclusive statement of all the agreements, conditions, promises, representations, and covenants between the Parties solely with respect to the subject matter hereof, and supersedes all prior or contemporaneous agreements, negotiations, representations, understandings, and discussions between and among the Parties, their respective representatives, and any other person or entity, with respect to the subject matter covered herein, excepting therefrom any proceeding or action if such proceeding or action is based upon facts not presently known to a Participating State or which were knowingly concealed from a Participating State by Ramad Pay. The Parties further acknowledge and agree that nothing contained in this Order shall operate to limit a Participating State’s ability to assist any other local, state, or federal agency, department, or office with any investigation or prosecution, whether administrative, civil or criminal, initiated by any such agency, department, or office against Ramad Pay or any other person based upon any of the activities alleged in these matters or otherwise.

8. Waiver. The waiver of any provision of this Order shall not operate to waive any other provision set forth herein, and any waiver, amendment, and/or change to the terms of this Order must be in writing signed by the Parties.

9. Severability. If any provision of this Order shall be found by any court of law to be void, voidable, invalid, or otherwise unenforceable, the remaining portions shall remain in full force and effect.

10. No Private Right of Action Created. This Order does not create any private rights or remedies against Ramad Pay (or any of its affiliates or subsidiaries), create any liability for Ramad Pay (or any of its affiliates or subsidiaries), or limit defenses of Ramad Pay (or any of its affiliates or subsidiaries) for any person or entity not a party to this Order.

11. Counterparts. This Order may be executed in separate counterparts, by facsimile, by scanned electronic document, or by electronic signature. A copy of the signed Order will be given the same effect as the originally signed Order.

12. Nothing in this Order shall relieve Ramad Pay of its obligation to comply with applicable state and federal law.