In re Athena Bitcoin, Inc.: Consent Order ($10,000)

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Research, not advice. Part of the Bitcoin research archive (October 2026). Claims labelled unverified, contested or fringe are reported, not endorsed; statuses of bills and rules are as of the date checked. Government, court and patent records are public domain; the research notes are CC BY 4.0.

OCR text (macOS Vision) of 2025-05-15-Nevada-FID-Athena-Bitcoin-consent-order.pdf — machine-read from a scanned PDF; check the PDF for exact wording.
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Docusign Envelope ID: 15C2C2AC-3E16-4931-87E8-0569341C6A71
3300 W. Sahara Avenue, Suite 250
Las Vegas, Nevada 89102
(702) 486-4120
STATE OF NEVADA
DEPARTMENT OF BUSINESS AND INDUSTRY
FINANCIAL INSTITUTIONS DIVISION
In Re:
Athena Bitcoin, Inc.
CONSENT ORDER
Respondent.
The Commissioner of the Financial Institutions Division for the State of Nevada, with
the agreement of Athena Bitcoin, Inc. (hereafter, "Respondent"), through its Chief Operating
Officer and Director, Carlos Carreño ("COO"), and the Financial Institutions Division of the
State of Nevada, Department of Business and Industry, (hereafter, "Division"), find, agrees,
and orders as follows:
JURISDICTION
Respondent stipulates and agrees that it was at all relevant times, operating the
business of a money transmitter in the State of Nevada, as governed by Nevada Revised
Statutes ("NRS") Chapter 671 and Administrative Code ("NAC") Chapter 671 without having
first obtained a license, as alleged in the Administrative Complaint. Respondent further
agrees that it is subject to NRS Chapter 671, NAC Chapter 671, and the jurisdiction of the
Division.
SUMMARY OF FACTS
Respondent is registered under the laws of the State of Nevada, and its
resident agent, Incorp Services, Inc., is located at 9107 West Russell Road Suite 100,
Las Vegas, Nevada 89148.
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Docusign Envelope ID: 15C2C2AC-3E16-4931-87E8-0569341C6A71
2.
Respondent has its principal place of business where it operates the business of
a money transmitter at the following location: 1 SE 3rd Avenue, Suite 2740, Miami, Florida
33131.
3.
Respondent submitted an Application for Licensure as a Money Transmitter
through the Nationwide Multistate Licensing System and Registry ("NMLS") on December 1,
2023.
4.
During a review of the application, the website for the applicant was reviewed
and the applicant's website listed several bitcoin kiosk locations in the state of Nevada.
5.
On April 25, 2024, the Division contacted the Respondent by email to discuss
the unlicensed activity. After further discussions between the Division and Respondent on
April 26, 2024, the Respondent agreed to immediately cease operating from the Nevada
kiosks until the license was approved.
Based upon the findings of the investigation and to avoid further administrative
action, the parties have agreed to resolve this matter.
The Consent Order shall memorialize the corrective action, which the
Respondent shall take, to resolve any concerns by the Division related to the aforementioned
investigation and as detailed in the Administrative Complaint.
VIOLATIONS OF LAW
8.
During the course of the Division's investigation, it was discovered that
Respondent had engaged in unlicensed activity under NRS Chapter 671 by conducting the
business of a money transmitter in the State of Nevada while having filed for, but without
having first obtained, a license with the Division.
CONSENT ORDER
9.
The Division was prepared to present its case to the assigned ALJ based upon
an Administrative Complaint filed by the Division. However, Respondent expressed its intent
to comply with NRS Chapter 671 and NAC Chapter 671 and its desire to cooperate with the
/I
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Docusign Envelope ID: 15C2C2AC-3E16-4931-87E8-0569341C6A71
Division and to avoid the time and expense involved in a formal administrative enforcement
2 | hearing.
10.
Pursuant to NRS 233B.121(5), the Division and Respondent agrees to the
following terms and conditions:
11.
Respondent admits to the facts and infractions of law as alleged in the
Administrative Complaint.
12.
Respondent further admits and acknowledges that any and all money
transmission activity by Respondent was done, while having applied for, but without having
first obtained a license from the Division, and Respondent is therefore liable for this
unlicensed activity.
13.
In recognition of the importance of full compliance and in the spirit of resolution,
Respondent agrees to the following:
a. Submit payment in the amount of $10,000 to the Division as an administrative
fine pursuant to NRS 671.485, without admitting willful misconduct, but to bring
closure to this matter; and
b. Continue refraining from engaging in any conduct that contravenes NRS and
NAC Chapters 671, and to ensure that its business operations remain in
alignment with all applicable statutory and regulatory requirements.
14.
The Division agrees not to pursue any other or greater remedies or fines in
connection with Respondent's alleged conduct referenced herein solely as it relates to the
Administrative Complaint. However, Respondent acknowledges, agrees to, and understand
that any further violation(s) of NRS Chapter 671 and/or NAC Chapter 671 such as described
and cited herein may be deemed violations), and shall subject Respondent to additional
administrative fines and costs as well as remedies available pursuant to NRS 671.485, NRS
671.495, and any other applicable section of NRS Chapter 671.
15.
Respondent and the Division agree that by entering into this Consent Order, the
Division does not concede any defense or mitigation Respondent may assert. Respondent
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Docusign Envelope ID: 15C2C2AC-3E16-4931-87E8-0569341C6A71
further agrees and understand that by entering into this Consent Order, Respondent is
waiving its right to a hearing at which Respondent may present evidence in its defense, its
right to a written decision on the merits of the Administrative Complaint and/or rehearing,
appeal and/or judicial review, and all other rights which may be accorded by the Nevada
Administrative Procedure Act, the Nevada Money Transmitter statutes and accompanying
regulations, and the federal and state constitutions.
16.
Respondent understand that this Consent Order may be subject to public
records laws.
17.
Respondent fully understands that it has the right to be represented by legal
counsel in this matter at its own expense. Each party shall bear its own attorney's fees and
costs. Neither this Consent Order nor any statements made concerning this Consent Order
may be discussed or introduced into evidence at any hearing on the Administrative Complaint
if the Division must ultimately present its case based on the Administrative Complaint in this
matter.
18.
In consideration of execution of this Consent Order, the Respondent and COO
in his official capacity, its/his successors, heirs, assigns, and the like, hereby releases,
remises, and forever discharges the State of Nevada, the Department of Business and
Industry, and the Division and each of their respective members, agents, employees and
counsel in their individual and representative capacities, from any and all manner of actions,
causes of action, suits, debts, judgments, executions, claims, and demands whatsoever,
know and unknow, in law or equity, that the Reponsdent ever had, now has, may have, or
claim to have, against any or all of the persons or entities named in this section, arising out of
or by reason of the Division's investigation, this disciplinary action, and all other matters
relating thereto.
19.
Respondent hereby indemnifies and holds harmless the State of Nevada, the
Department of Business and Industry, the Division, and each of their respective members,
agents employees, and counsel in the individual and representative capacities against any
and all claims, suits, and actions brought against said personal and/or entities by reason of
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Docusign Envelope ID: 15C2C2AC-3E16-4931-87E8-0569341C6A71
the Division's investigations, this disciplinary action and all other matters relating thereto, and
against any and all expenses, damages, and costs, including court costs and attorney fees,
which may be sustained by the personal and/or entities name in this section as a result of
said claims, suits, and actions.
20.
If Respondent fails to comply with any terms of this Consent Order, Respondent
shall be subject to disciplinary action for violation of the Consent Order, NRS Chapter 671,
and NAC Chapter 671 as stated in the Administrative Complaint, which may result in further
disciplinary action. Respondent has signed and dated this Consent Order only after reading
9 and understanding all terms herein.
In WITNESS WHEREOF, we have each executed this Consent Order as of the date
set forth below.
SO ORDERED this_/4 day of May, 2025.
STATE OF NEVADA
DEPARTMENT OF BUSINESS AND INDUSTRY
FINANCIAL INSTITUTIONS DIVISION
Lane
CONSENTED TO this
andy O'Laughlir
Commissioner
day of May, 2025.
Athena Bitcoin, Inc.
Carlos Carreño
Carlos Carreño, Chief Operating Officer
Approved as to form:
AARON D. FORD
Attorney General
Is Louis V. Csoka
Louis Csoka
Michael Detmer
Deputy Attorney General
Attorney for the Division
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Docusign Envelope ID: 15C2C2AC-3E16-4931-87E8-0569341C6A71
CERTIFICATE OF SERVICE
I certify that I am an employee of the State of Nevada, Department of Business and
Industry, Financial Institutions Division, and that on the St4 of May 2025, I deposited in
the U.S. mail, postage prepaid, via First Class Mail and Certified Return Receipt Requested, a
true and correct copy of the foregoing CONSENT ORDER, addressed as follows:
Athena Bitcoin, Inc.
Attn: Samuel Nazzaro
1 SE 3r° Avenue, Suite 2740
Miami, Florida 33131
Certified Mail: 7014 2870 0001 8499 2631
Athena Bitcoin, Inc.
c/o Incorp Services, Inc.
9107 West Russell Road Suite 100
Las Vegas, Nevada 89148
Certified Mail: 7014 2870 0001 8499 2648
DATED this 15+yday of May 2025.
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