Coinme Inc. Consent Order for Uniform Money Services Act Violations

Last updated 12/24/25 ORDER SUMMARY Consumer Services Division Case Number C-25-4009 Consent Orders resolve issues in investigations. In these, co mpanies and individuals work with us to agree to terms that resolve the alleged issues in the investigation. Name Coinme Inc., NMLS #1185542 Order Number C-25-4009-25-CO01 Date issued December 23, 2025 What does this Consent Order require? x The Temporary Order to Cease a nd Desist (TCD) entered on Nove mber 25, 2025, is stayed until DFI determines to lift the stay or withdraw the TCD. x Respondent must cease and desist fro m engaging in all violations of the Act, rules, and applicable federal laws and regulations. x Respondent will continue to promptly remed iat e all matters identified in a 2025 multistate examination, and will pr ovide at least mont hly updates to DFI on its r emediation work. x Within 14 days of entry of this Consent Order, Respondent must place all virtual currencies held on behalf of Washington customers into segregated accounts fo r the benefit of Washington customers only. Within 30 days of entry of this Consent Order, for tran sactions at Washington kiosks that remain outstanding, Respondent must transfer cash or cash eq uivalents equal to all assets deposited into a segregated account. Need more information? You can contact the Consumer Services Division, Enforcement unit at (360) 902-8703 or csenforcecomplaints@dfi.wa.gov. Please remember that we cannot pr ovide financial or legal advice to members o f the public. We also cannot release con f idential in f ormation.

CONSENT OR DER C-25- 400 9-25- CO 01 CO INM E, INC. 1 DEPARTME NT OF FINANCIAL INSTITUT IONS Divis ion of C onsum er S erv ices PO Box 41200 Olymp ia, WA 98504-1200 (360) 902-8 703 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 STATE OF WASHINGTON DEPARTMENT OF FINANCIAL INSTITUTIONS DIVISION OF CONSUMER SERVICES IN THE MATTER OF DETERMINING Whether there has been a violation of the Uniform Money Services Act of Washington by: COINME, INC., N MLS #1185542, Respondent. No.: C-25-4009-25-CO01 CONSENT ORDER INTRODUCTION The Director of the Department of Financia l Institutions (Director), through designee Ali Higgs, Division of Consumer Services Director, an d Coinme, Inc. (Respondent), finding that certain issues raised in the above-captioned matter may be economically and efficiently settled, agree to the entry of this Consent Order. This Consent Order is entered pursuant to chap ter 19.230 of the Revised Code of Washington (RCW), and RCW 34.05.060 of the Administrative Procedure Act, bas ed on the following: AGREEMENT AND ORDER The Department of Financial Institutions, Di vision of Consumer Serv ices (Department) and Respondent have agreed upon a basis for staying t he Temporary Ord er to Cease and Desist No. C-25- 4009-25-TD01 (TCD), entered November 25, 202 5 (copy attached hereto). Pursuant to chapter 19.230 RCW, the Uniform Money Services Act (Act), and RCW 34.05.06 0 of the Administrative Procedure Act, Respondent hereby ag rees to the Department’s ent ry of this Consent Order. The Department and Respondent do not intend this Consent Order to resolve the issues identified in the Statement of Charges No. C-25-4009-25-SC01 (SC01), including any issues that are the same or similar to issues identified in the TCD. Accordingly, all factual and leg al i ssues identified in SC01 may be litigated and appealed in an adjudicative p roceeding regarding SC01, notwithstanding this Consent Order. In addition, Respondent does not waive any claims, defenses, or argume nts by

CONSENT OR DER C-25- 400 9-25- CO 01 CO INM E, INC. 2 DEPARTME NT OF FINANCIAL INSTITUT IONS Divis ion of C onsum er S erv ices PO Box 41200 Olymp ia, WA 98504-1200 (360) 902-8 703 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 agreeing to this Consent Order, and the Department and Respondent ackno wledge and agree that an y and all claims and defenses available to Respondent as of the date this Consent Order is ent ered will remain available to Respondent in the event the T CD is not withdrawn or the stay issued herein is lifted or a new, distinct TCD issued. Based upon the foregoing: A. Jurisdiction. It is AGREED that the Department has jurisdiction over the subject matter of the activities discussed herein. B. Stay of TCD. It is AGREED that the Temporary Order to Ceas e and Desist No. C-25- 4009-25-TD01 (TCD), entered November 25, 202 5, is stayed (the “Stay”) until the Department determines to withdraw the TCD or lift the Stay. In the event that the D epartment determines to lift the Stay, Coinme shall be given 7 days’ notice of the Department ’s intent to do so. C. Waiver of Hearing During Stay. It is AGREED that Respondent has been informed of the right to a hearing before an administrative la w judge. During the pendency of the Stay, Respondent waives its right to a hearing and any and all administrative an d judicial review of the Temporary Order to Ceas e and Desist No. C-25-4009-25-TD01 (TCD) or of the resolution reached herein. Accordingly, Respondent, by the signature s of its representatives below, withdraws its appeal to the Office of Administrative Hearings as to the TCD during the pendenc y of the Stay. It is FURTHER AGREED that, if the Department lifts the stay on the TCD or issues a new TCD, Respondent will be given an opportunity to appeal as provided for in the Act. D. Compliance and Remediation. It is AGREED and ORDERED that Respondent shall cease and desist from engaging in all violations of the Act, rules, and applicable f ederal laws and regulations. It is FURTHER AGREED and ORDERED that Respondent shall henceforth comply with the Act, and all related rules. It is FURTHER AGREED and ORDERED that Respondent will continue existing efforts to promptly remediate al l matters identified in the multistate examination

CONSENT OR DER C-25- 400 9-25- CO 01 CO INM E, INC. 3 DEPARTME NT OF FINANCIAL INSTITUT IONS Divis ion of C onsum er S erv ices PO Box 41200 Olymp ia, WA 98504-1200 (360) 902-8 703 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 commencing June 2, 2025. It is FURTHER AGREED and ORDERED that Respondent will keep the Department updated on its remediation work at lea st on a monthly basis, unless agreed otherwise by the Department in writing. E. Safeguarding Washington Custome r Assets. It is AGREED and ORDERED that, within 14 days of entry of this Consent Order, Respondent shall place and h old all virtual currencies custodied on behalf of Respondent’s Washington customers, both as of the date of this Consent Order and on an ongoing basis, in one or more secure an d segregated ac counts for Washington customers. Respondent shall structure the accounts to be held for the benefit of Washington customers only, such that Respondent continues to have no claim to the assets. Notwithstanding the foregoing, Responden t may custody a portion of the virtual currencies h eld on behalf of Washington customers in one or more fulfillment accounts, but only to the extent necessary to fa cilitate anticipated customer withdrawals off Respondent’s platform. It is FURTHER AGREED and O RDERED that, within 30 days of the entry of this Consent Order, Respondent shall transfer to a secure, segregated, and unencumbered account an amount of cash or cash equivalents equal to all assets deposited by person s in connection with a transaction at a Washington kiosk that remains outstanding. F. Complete Cooperation with the Department. It is AGREED that, upon written request by the Department, Respondent and all of its agents shall provide the Department truthful and complete sworn statements outlining their activitie s with respect to Res pondent and any and all persons involved or in any way associat ed with Respondent, including but not limited to owners, employees, independent contractors, agents, businesses and persons with whom Respondent dealt, communicated, or otherwise related. Th e “sworn statements” may take th e form of affidavits, declarations, or deposition testimony, at the Department’s discretion. In addition to providing sworn statements, it is AGREED that, upon written request by the Department, Respondent shall cooperat e fully, truthfully, and completely with the Department and provide any and all information known to

CONSENT OR DER C-25- 400 9-25- CO 01 CO INM E, INC. 4 DEPARTME NT OF FINANCIAL INSTITUT IONS Divis ion of C onsum er S erv ices PO Box 41200 Olymp ia, WA 98504-1200 (360) 902-8 703 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 them relating in any manner to Respondent and any and all persons involved or in any way associated with Respondent, including but not limited to owners, employees, independent contractors, agents, businesses and persons with whom Respondent dealt, communicated, or otherwise r elated. It is further AGREED that, upon written request by th e Department, Respondent shall provide any and all documents, writings or materials, or objects or things of any kind in their possession or under their care, custody, or control t hat they are authorized to possess, obtain, or distribute relating directly or indirectly to all areas of inquiry and investigation. It is further AGREED that Respondent’s representatives shall, if called, testify fully, trut hfully, and completely at any and all proceedings related to any Departme nt investigation or enforcem ent action or both related to any and all persons involved or in any way associated with any respondents named ther ein. A failure of Respondent or its agents to cooperate fully, truthfully, and completely is a breach of this Consent Order. Nothing in this Paragraph F shall be construed as requiring Respondent or its agents to waive any rights or privileges, including the attorney -client privilege or work-produ ct doctrine, or to otherwise require Respondent or its agents to violate applicable law. G. Non-Compliance with Order. It is AGREED that Respondent understa nds that failure to abide by the terms and conditions of this Consen t Order may result in further legal a ction by the Director. In the event of such legal action, Respondent may be responsible to reimburse the Director for the cost incurred in pursuing such action, incl uding but not limited to, attorney fees. H. Expiration. It is AGREED that, unless otherwise agreed by the parties in writing, this Consent Order shall expire upon the earlier o f either a lift of the Stay or the withdrawal of the TCD. I. Voluntarily Entered. It is AGREED that Respondent has voluntarily enter ed into this Consent Order, which is effective when signed by the Director’s designee. Respondent’s voluntary agreement to the entry of this Consent Order sha ll not constitute an admission as to any of the allegations in this Consent Order, the TCD, or SC01.

CONSENT OR DER C-25- 400 9-25- CO 01 CO INM E, INC. 5 DEPARTME NT OF FINANCIAL INSTITUT IONS Divis ion of C onsum er S erv ices PO Box 41200 Olymp ia, WA 98504-1 200 (360) 902-8 703 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 J. Completely Read, Un derstood, and Agreed. It is AGREED that Respondent’s representatives hav e read this Consent Order in its entirety and fully unders tand and agree to all of the same. K. Authority to Execu te Order. It is AGREED that the undersigned authoriz ed representative has repr esented and warranted that they have the full pow er and right to execute this Consent Order on behalf of Respondent. L. Counterparts. This Consent Order may be execut ed in any number of cou nterparts, including by facsimile or e-mail of a .pdf or similar file, ea ch of which shall be deemed to be an original, but all of which, ta ken together, shall con stitute one and the same Consent Order. RESPONDENT: Coinme, Inc., by: __________ __ __ ______________________________ Neil Bergquist Date CEO and President APPROVED FOR ENT RY, by: __________ ___ ________ _______________________________ Joseph P. Cutler Date Perkins Coie LLP, Attorney for Respondent DO NOT WRIT E BELO W THI S LINE THIS ORDER ENTERED THIS ______ DAY OF ___________, 2025. __________ _ _ __________ ALI HI GGS, D ire cto r Division of Consumer Services Department of Fina ncial Institutions    

CONSENT OR DER C-25- 400 9-25- CO 01 CO INM E, INC. 6 DEPARTME NT OF FINANCIAL INSTITUT IONS Divis ion of C onsum er S erv ices PO Box 41200 Olymp ia, WA 98504-1 200 (360) 902-8 703 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Presented by: __________ _ __ DREW STILLMAN Financial Legal Examiner Supervisor Approved by: __________ _ _ KENDALL FREED Enforcement Chief

Last updated 12/1/25 ORDER SUMMARY Consumer Services Division Case Number C-25-4009 Temporary Orders to Cease and Desist require individuals or companies to temporarily stop doing things, usually things that could harm or have harmed consumers. The individual or company has the right to contest the Order at an administrative hearing. If the individual or company does not contest the temporary order, it will become permanent when DFI issues a Final Order. Name Coinme, Inc., NMLS #1185542 Order Number C-25-4009-25-TD01 Date issued November 25, 2025 What does this Temporary Order to Cease and Desist require? x CoinMe must immediately stop conducting money transmitter business for customers in Washington and cannot resume business for Washington consumers without prior approval from DFI. x Cease and desist all violations of the UMSA. x Cease and desist accounting for Washington Cu stomers’ unredeemed vouchers as breakage income. x Place and hold all assets deposi ted by or obligated to Respondent’s Washington Customers, including assets related to unr edeemed vouchers, in secure and segregated accounts, one account for each individual Washington Customer. x Pay restitution to all Washington State cu stomers who purchased virtual currency with Respondent and have not redeemed vouchers from their purchase. x Provide to the Department a list of all customers. x Provide to the Department proof of all rest itution and escheatment paid by Respondent. x Provide the Department with monthly permissible investment reports, in the form required by the Department from December 2020 through November 2025. x Implement a system of controls, policies, and trai ning to prevent future violations of the Act, including those identified in this Order. x Cooperate with the Department and provide full access to in formation and records at the request of the Department. Need more information? You can contact the Consumer Services Divisi on, Enforcement unit at (360) 902-8703 or csenforcecomplaints@dfi.wa.gov. Please remember that we cannot pr ovide financial or legal advice to members of the public. We also cannot rel ease confidential information.

TEMP ORARY ORDER TO CEASE AND DESIST C-25- 400 9-25- TD 01 CO INM E, INC. 1 DEPARTME NT OF FINANCIAL INSTITUT IONS Divis ion of C onsum er S erv ices 150 I srael Rd SW PO Box 41200 Olymp ia, WA 98504-1200 (360) 902-8 703 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 STATE OF WASHINGTON DEPARTMENT OF FINANCIAL INSTITUTIONS CONSUMER SERVICES DIVISION IN THE MATTER OF DETERMINING Whether there has been a violation of the Uniform Money Services Act of Washington by: COINME, INC., NMLS #1185542, Respondent. NO. C-25-4009-25-TD0 1 TEMPORARY ORDER TO CEASE AND DESIST THE STATE OF WASHI NGTON TO: Coinme, I nc. COME S NOW the Direct or of the Washington State Departmen t of Financia l I nstitution s, by and through his de signee Ali Higgs, Di vision of Consu mer Services Direc tor, and finding that t he public is likely to be s ubstantially injured by delay in issuing a cease and desist order, e nters th is temp orary order to cease and desist pursuan t to chapter 19. 230 RCW, the Un iform Money Services Act (Ac t), based on the following find ings: I. FACTUAL FINDINGS 1.1 Respondent. Coinme, Inc. (Respondent) was licensed on or about April 23, 2014, by the Department of Financial Institutions Division of Consumer Services (Department) to condu ct business as a money transmitter. Respondent continues to be licensed by the Depa rtment as of the date of this Temporary Order to Cease and D esist (Order). 1.2 Unsafe and Unsound Practices. From approximately December 2020 to the date of this Order, as described i n the following paragraphs, Respondent engaged i n activity causing Respondent to become insolvent or created the lik elihood of material loss, insolvency, or dissipation of Respondent’s assets, or otherwise materially prejudiced the finan cial condition of the Respondent or

TEMP ORARY ORDER TO CEASE AND DESIST C-25- 400 9-25- TD 01 CO INM E, INC. 2 DEPARTME NT OF FINANCIAL INSTITUT IONS Divis ion of C onsum er S erv ices 150 I srael Rd SW PO Box 41200 Olymp ia, WA 98504-1200 (360) 902-8 703 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 the interests of its customers. 1.3 Unfair and Deceptive P ractices. Between about January 2023 and Dece mber 2024, Respondent inappropriately claimed consumers’ property as its own. When Respondent sold virtual currency to customers, R espondent used a system that required their custo mers to obtain vouchers at kiosks to be redeemed on Respondent’s website. A significant number of customers do not redeem their vouchers online in a timely manner. Respondent claimed the amounts owed to those customers as Respondent’s income. Respondent did not disclose material information to customers about how it recognizes customers’ pr operty as income if the vouchers were unrede emed after a certain time peri od, and Respondent did not properly escheat customer property to the State of Washington. For exampl e, Respondent recorded income from unred eemed vouchers fo r Wa shi ng to n a nd no n- Wa s hi n gto n cu sto m er s of $2,201,254 and $6,170,822 at year-end 2023 and 2024, respectively. 1.4 Inaccurate Receip ts. Between about June 10, 20 24, and October 23, 2024, Respondent provided its customers with receipts that listed a customer support phone number that was not active. 1.5 Failed to Maintain Tangible Ne t Worth. Each money transmitter is required to maintain a tangible net worth in an amount determ ined by the Director. From about 2020 to 2025, Respondent did not always maintain a tangible net worth in the amount req uired by the Director. For example, Respondent had a negative tangible net worth at yea r-end 2022, 2023, and 2024. Respondent’s financial condition showed continued deterior ation, representing a negative tangible net worth even after Respondent inappropriately claimed customer funds as income. 1.6 Failed to Maintain Perm issible Investment Record s. Respondent is required to maintain records for determining its compliance with the Act for at lea st five years, including monthly

TEMP ORARY ORDER TO CEASE AND DESIST C-25- 400 9-25- TD 01 CO INM E, INC. 3 DEPARTME NT OF FINANCIAL INSTITUT IONS Divis ion of C onsum er S erv ices 150 I srael Rd SW PO Box 41200 Olymp ia, WA 98504-1200 (360) 902-8 703 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 reports about permissible investments. Upon the Department’s request in 2025, Respondent provided records related to permissible investments in 2024 and 2025 that presented inconsistent information regarding its permissible investments and did not adequately show whether Respondent was in compliance with the Act. 1.7 Failed to Timely File Annual Repor t. Respondent’s 2022 annual report was due to the Department by July 1, 2023, but was filed on J uly 17, 2023. 1.8 Filed Inaccurate Repor ts. Respondent filed inaccurate reports with the Department. Respondent’s annual reports and quarterly Money Services Busin ess Call Reports (MSBCRs) for the years 2022 and 2023 cont ained inconsistencies. For example, Respondent reported total transaction volume of $14,903,369 in their 2022 annual report filing; however, Respon dent reported total volume of $15,510,288 in the 2022 MSBCRs. Similarly, Respondent reported total transaction volume of $22,213,309 in the 2023 annual report filing, but its 2023 MSBCRs show a total volume of $24,112,980. II. GROUNDS FOR ENTRY OF ORDER 2.1 Based upon the Factual Findings set forth in Section I, Respondent is in violation of RCW 19.230.340 for: directly or indirectly employing any scheme, device, or artifice to defraud or mislead any person; directly or indirectly engaging in any unfair or d eceptive act or p ractice toward any person; directly or indirectly obtaining property by fraud or misr epresentation; knowingly making, publishing, or disseminating any false, deceptive, or misleading information in the provision of money services; making or concurring in making any false entry, or omitti ng or concurring in omitting any material entry, in the books or accounts of the business; knowingly making or publishing to the director or director’s desi gnee, or concurring in making or publishing to the director or director's

TEMP ORARY ORDER TO CEASE AND DESIST C-25- 400 9-25- TD 01 CO INM E, INC. 4 DEPARTME NT OF FINANCIAL INSTITUT IONS Divis ion of C onsum er S erv ices 150 I srael Rd SW PO Box 41200 Olymp ia, WA 98504-1200 (360) 902-8 703 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 designee any written repo rt, exhibit, or statement of their affairs or pecuniary condition containing any material statement which is false, or omitting or concurring in omitting any statement required by law to be contained therein; and failing to make any r eport or statement lawfully required by the director or other public official; as well as for engaging in conduct which cr eates the likelihood of material loss, insolvency, or dissipation of Respondent’s assets, or otherwise materially prejudices the financial condition of Respondent or the interests of its customers. See RCW 19.230.010(29). 2.2 Based on the Factual Findings set forth in Section I above, Respondent is in violation of RCW 19.230.060 and WAC 208-690-060 for not maintaining a tangible ne t worth, calculated at ten thousand dollars for every one million dollars of total company-wide mone y transmission and payment instrument dollar volume over the previous twelve months. 2.3 Based on the Factual Findings set forth in Section I above, Respondent is in violation of RCW 19.230.170 for failing to properly maintain records. 2.4 Based on the Factual Findings set forth in Section I above, Respondent is in violation of RCW 19.230.110(1) and (2), WAC 208-690-090, and WAC 208-690-100 for failing to timely and accurately file annual rep orts. III. AUTHORITY TO ISSUE TEMPORARY ORDER TO CEASE A ND DESIST 3.1 Authority to Issue Temporary Order to Cease and Desist. Pursuant to RCW 19.230.260, the Director is authorized to issue a temporary orde r to cease and desist whenever the Director determines that a violation of the Act or of a rule adopted or an o rder issued under the Act by a licensee, authorized del egate, or other person su bject to the Act is likely to cause immediate and irreparable harm to the licensee, its customers, or the public as a result of the violation, or cause insolvency or significant dissipation of the assets of the licensee. The Dir ector may issue a temporary

TEMP ORARY ORDER TO CEASE AND DESIST C-25- 400 9-25- TD 01 CO INM E, INC. 5 DEPARTME NT OF FINANCIAL INSTITUT IONS Divis ion of C onsum er S erv ices 150 I srael Rd SW PO Box 41200 Olymp ia, WA 98504-1200 (360) 902-8 703 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 order to cease and desist requiring the license e, authorized delegate, or other person subject to the A ct to cease and desist from conducting business in Washington State or to c ease and desist from the violation or undertake affirmative actions as a re necessary to comply with th e Act, any rule adopted under the Act, or order issued by the Dire ctor under the Act. The orde r is effective upon servic e upon the licensee, authorized delegate, or other pe rson subject to the Act. IV. ORDER Based upon the above Factual Findings, Grounds for Entry of Ord er, and Authority to Issue Temporary Order to Ceas e and Desist, and pursuant to RCW 19.230.260, the Director determines Respondent’s conduct set forth in Section I above is likely to cause immediate and irrep arable harm to the licensee, its customers, or the public as a result of the violations, or is likely to cause insolvency or significant dissipation of the assets of the licensee. Therefore, the Directo r ORDER S that: 4.1 Respondent shall immediately cease and desist conducting money transmitter business with respect to customers in Washington State (“Washington Customers”) and shall not resume service to Washington Customers without the prior approval of the Dep artment. This does not prohibit Respondent from returning assets to Washington Customers. Existing Washington Customers may withdraw assets from Respondent’s platform to another platform or to ext ernal customers wallets and may convert their digital assets to fiat for withdrawal. 4.2 Respondent shall immediately undertake these affi rmative actions: A. Cease and desist a ll vio lations of t he Act. B. Cease and desist accounti ng for Washington Custo mers’ unredeemed vouch ers as breakage income.

TEMP ORARY ORDER TO CEASE AND DESIST C-25- 400 9-25- TD 01 CO INM E, INC. 6 DEPARTME NT OF FINANCIAL INSTITUT IONS Divis ion of C onsum er S erv ices 150 I srael Rd SW PO Box 41200 Olymp ia, WA 98504-1200 (360) 902-8 703 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 C. Place and hold all assets deposited by or obligated to Respondent’s Washin gton Customers, including assets related to unredeeme d vouchers, in secure and segregated accounts, one account for each individual Washington Customer. Respondent shall structure ea ch account to be held for the benefit of Washington Customers only, such that Respondent has no claim to the assets. D. Notify each of Respondent’s Washington Customers: i. That Respondent has ceased doing business in Washington other than to temporarily safeguard an d return assets to Washington Customers. ii. That any assets that Respondent controls that are obligated to a Washington Customer, Respondent controls on behalf of that Washington Customer. iii. That Respondent is moving (or has moved, as applicable) assets obligated to each Washington Customer into a segreg ated account for each Washingto n Customer. E. Pay restitution to all Was hington State cus tomers who purchase d virtua l curr ency with Responden t and hav e not redee med vouchers from t heir purchase. Alter natively, f or each of tho se customers, follow t he escheatment process requ ired by chap ter 63.30 RCW a s administered by the Washington De partment of Revenue. i. The amount of restitu tion made to each cus tomer shall equa l the greater of the amount each customer paid for the vir tual currency or the value of the vir tual currency the customer pa id for as of the date of this order. Alternatively, the amount escheated for eac h customer s hall equal the greater of the am ount each customer paid for the virtual currency or the value of the virtual currency the customer paid for as of the date of this order.

TEMP ORARY ORDER TO CEASE AND DESIST C-25- 400 9-25- TD 01 CO INM E, INC. 7 DEPARTME NT OF FINANCIAL INSTITUT IONS Divis ion of C onsum er S erv ices 150 I srael Rd SW PO Box 41200 Olymp ia, WA 98504-1200 (360) 902-8 703 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ii. Each payment ma de to customer s must be accompanied by a le tter explai ning why the payme nt is be ing made. F. Provide to t he Department a lis t of all custo mers su bject to this section. The list shall include the cus tomers’ names and con tact infor mation, the amoun t each c ustomer paid for the v irtual currency, the amou nt of virtual currency purchased, the date the virtual c urrenc y was purchased, an d the amount the virtual curren cy was worth as of the dat e of this order. G. Provide to t he Department proof of all res titution an d escheatme nt paid by Respondent pursuant to th is section. H. Provide the Depart ment with monthly per missib le investmen t reports, in the f orm required by the Departme nt (as found on the Depa rtment’s website at https://dfi.wa.go v/money- services/forms - the “Virtual Currency Permissible I nvestments Worksheet”; see also the “Samp le Virtual Currency PI Report”), from Decemb er 2020 throug h November 2025. I. Implement a system of control s, policies, and traini ng to preven t future viola tions of the Act, including t hose ident ified in th is Order. J. Cooperate with the Department and provide full access to information and records at the requ est of the Department. 4.3 This Order shall take effec t immediately and sha ll remain in effe ct unless set aside, limited, or suspended in writing by an authorized court. 4.4 If made permanent, this Order sh all remain in effect until Respondent fully complies with this Order and adeq uately re medies all violations of the Act, as determined by the Department and in the Department’s sole discretion.

TEMPORAR Y ORDER TO CEASE AND DESIST C-25- 400 9-25- TD 01 CO INM E, INC. 8 DEPARTME NT OF FINANCIAL INSTITUT IONS Divis ion of C onsum er S erv ices 150 I srael Rd SW PO Box 41200 Olymp ia, WA 98504-1200 (360) 902-8 703 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NOTICE PURSUANT TO CHA PTER 19.23 0 RCW, YOU ARE EN TITLED TO A HEARI NG TO DETERMINE WHETH ER THIS ORDER SHA LL BECOM E PERMAN ENT. I F YOU DESI RE A HEARING, THEN YOU MU ST RETURN THE ATTACHED APPLICA TION FOR ADJUDI CATI VE HEARING INCORPORATED HE REIN BY TH IS REFERENCE. FAILURE TO COMPLETE A ND RETURN THE APPLICATI ON FOR ADJUDICATIVE HEARING FORM SO THAT I T IS RECE IVED BY THE DEPARTMEN T OF FINANCI AL INSTITUTIONS WITHIN TWENTY (20) DAYS OF THE DATE THAT THIS ORDER WAS SERVED ON YOU WI LL CONSTITUTE A DEFAULT AND WILL RESULT IN THE LOSS OF YOUR RIGHT TO A HEARING. SERVICE ON YOU I S DEFINED AS POSTING IN THE U.S. MAIL, POSTAGE PREPAID, TO YOUR LAST KNOWN ADDRESS. BE ADVISED THAT DEFAULT WI LL RESULT I N THIS ORDER TO CEASE AND DESIST BECOMI NG PERMANENT ON THE TWENTY-FI RST (21ST) DAY FOLLOWING SERVICE OF THIS ORDER UPON YOU. DATED this 25th day of November, 2025. _ _ _______ __________ ________ _ ALI HIGGS, Director Division of Consumer Ser vices Department of Fina ncial Inst itutio ns Presented by: __ ________ DREW STILLMAN Financia l Leg al Exa min er Superv iso r Approved by: _ _____ KENDALL FREED, Enforcement Chief __ AL I HI GG G G G G G G G G G G S S S S S S S S S S S D