In re Bitcoin Depot Operating LLC: Consent Order ($10,000)

Bitcoin Research — Law, Regulation, Markets & Origins (2026)

Kyc Aml

2026-03-11

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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 2026-03-11-Nevada-FID-Bitcoin-Depot-consent-order.pdf — machine-read from a scanned PDF; check the PDF for exact wording.
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Docusign Envelope ID: 8B00429D-F548-49EF-A778-566E1A15E0E6
3300 W. Sahara Avenue, Suite 250
Las Vegas, Nevada 89102
(702) 486-4120
STATE OF NEVADA
DEPARTMENT OF BUSINESS AND INDUSTRY
FINANCIAL INSTITUTIONS DIVISION
330 E College Parkway, Suite 10
arson City, Nevada 8970
(775) 684-2970
In Re:
Bitcoin Depot Operating LLC
CONSENT ORDER
Respondent.
The Commissioner (hereafter, "Commissioner") of the Financial Institutions Division for
the State of Nevada (hereafter, "Division") with the agreement and specific consent of Bitcoin
Depot Operating LLC (hereafter, "Respondent") and the Division (hereafter collectively
referred to as the "Parties"), find, agree, and order as follows:.
JURISDICTION
Respondent agrees that it is subject to Nevada Revised Statutes ("RS") Chapter 671,
Administrative Code ("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, Corporation Service Company, is located at 112 North Curry Street, Carson City,
Nevada 89703.
Respondent operates the business of a money transmitter and maintains
its street address at the following location: 8601 Dunwoody Place, Suite 308, Sandy
Springs, Georgia 30350.
Respondent obtained a license (MT11129) to engage in money
transmission activity from the Division on or about April 14, 2021.
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Docusign Envelope ID: 8B00429D-F548-49EF-A778-566E1A15E0E6
All licensees holding an active money transmitter license must submit an audited
financial statement for the preceding year within 90 days of their fiscal year end. NRS
671.285.
All licensees wishing to renew their annual license must meet all the initial
licensing qualifications of a new applicant, which includes audited financial statements for the
most recent fiscal year and for the immediately preceding two years demonstrating adequate
tangible net worth. NRS 671.050
6.
On or about January 17, 2025, Respondent was granted an extension to provide
its 2023 audited financial statements ("2023 Statement") and was permitted to renew its
license for the license period of January 1, 2025, to December 31, 2025, on the condition that
it paid the late report fee and submitted its 2023 report by the extension date of March 31,
2025.
7.
On or about January 20, 2026, the Division filed a "Administrative Complaint for
Disciplinary Action
and Appeal Rights" (Complaint") alleging Respondent violated the
provisions of NRS 671.285 by not submitting the 2023 Statement by the extension date
approved by the Commissioner.
As of the date of this Consent Order (Consent Order), Respondent has not
submitted the 2023 Statement.
Based upon the findings in this Consent Order and the Respondent's
cooperation with same, agreement of the Parties that this matter may be economically and
efficiently resolved by entry of this Consent Order. The Parties understand and agree that this
Consent Order must be approved by the Commissioner and be fully executed by the Parties
to become effective.
1//
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Docusign Envelope ID: 8B00429D-F548-49EF-A778-566E1A15E0E6
VIOLATIONS OF LAW
Respondent failed to submit the 2023 Statement, which is required under NRS Chapter
671, in violation of NRS 671.285.
CONSENT ORDER
The Division was prepared to present its case to the Commissioner or an
assigned Administrative Law Judge. However, Respondent expressed its intent to comply with
NRS Chapter 671 and NAC Chapter 671 and its desire to cooperate with the Division and to
avoid the time and expense involved in a formal administrative enforcement hearing.
Pursuant to NRS 671.465 and NRS 233B.121(5), this Consent Agreement
memorializes the terms mutually agreed upon by the Division and Respondent to fully and
finally resolve the matters alleged in the Complaint, and sets forth the specific corrective
actions Respondent has voluntarily agreed to undertake, which shall constitute Respondent's
sole obligations arising from or related to the matters set forth herein
A.
The Respondent's agreement to this Consent Order does not constitute an
admission that a violation of the provisions of this chapter or the regulations adopted or an
order issued by the Commissioner pursuant thereto has occurred.
B.
Respondent understands and agrees that, under the Consent Order, the
Division enters a finding of violation against Respondent for failing to timely submit the
Statement.
C.
Respondent therefore agrees to:
a. To pay a fine of $10,000 as an administrative penalty pursuant to NRS
671.485; and
b. refrain from any activity that violates NRS and NAC Chapters 671, and
otherwise operate its business in accordance with those Chapters.
D.
The Division agrees not to pursue any other or greater remedies or fines in
connection with Respondent's alleged conduct referenced herein, including a requirement to
provide the 2023 Statement. However, Respondent acknowledges,
agrees to, and
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Docusign Envelope ID: 8B00429D-F548-49EF-A778-566E1A15E0E6
understands that any further violation(s) of NRS Chapter 671 and/or NAC Chapter 671 such
as described and cited herein may be deemed violations(s), 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.
E.
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
agrees and understands that by entering into this Consent Order, Respondent is waiving its
rights to contest the allegations against it. These rights include representation by an attorney
at Respondent's own expense, the right to a hearing on any violations or allegations formally
filed and/or alleged, the right to confront and cross-examine witnesses called to testify against
Respondent, the right to present evidence on Respondent's own behalf, the right to have
witnesses testify on Respondent's behalf, the right to obtain any other type of formal judicial
review of these matters, and any other rights which may be accorded to Respondent pursuant
to provisions of Chapter 671 of the NRS, Chapter 671 of the NAC, Chapter 233B of the NRS,
and any other provisions of federal and state law. Respondent affirmatively waives all these
rights by entering into this Consent Order. If the Consent Order is rejected, or any portion
thereof, all such waivers shall be deemed withdrawn by Respondent.
F.
Respondent understands that this Consent Order may be subject to public
records laws.
G.
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 Complaint if the Division
24 | must ultimately present its case based on the Complaint in this matter.
H.
Respondent enters this Consent Order after being fully advised of Respondent's
rights and as to the consequences of this Consent Order. This Consent Order embodies the
entire agreement reached between the Division and Respondent. It may not be altered,
amended, or modified without the express written consent of the Parties, and all alterations,
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Docusign Envelope ID: 8B00429D-F548-49EF-A778-566E1A15E0E6
amendments and/or modifications must be in writing. The Parties stipulate and agree that this
Consent Order, if agreed upon and executed by the Parties, resolves all matters contained or
described in this Consent Order. The Division reserves its rights to pursue other disciplinary
actions for other violations discovered in any future investigations/audits of Respondent
outside the scope of this matter.
I.
In an effort to avoid the cost and uncertainty of a administrative hearing, the
Parties have agreed to settle this matter. For purposes of settling these matters, Respondent
acknowledges that the facts contained in the paragraphs in the above "Summary of Facts"
portion of the Consent Order, specifically as the same relate to the violations, are true and
correct. Without waiving any constitutional rights against self-incrimination, Respondent
further acknowledges that, if the Division filed and served a Formal Complaint and the matter
proceeded to an administrative hearing, the Facts could be found to constitute violation(s) of
NRS 671 and/or NAC 671, with discipline including the imposition of fines and fees, as well as
the possible suspension or revocation of its License. The Division acknowledges that
Respondent could assert certain defenses to any Complaint/allegations at said administrative
hearing which could affect its outcome.
J.
In consideration of execution of this Consent Order, the Respondent and its
owners, members, managers, successors, heirs, agents, 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 unknown, in law or equity, that the Respondent 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 this disciplinary action, and all other matters relating thereto
K.
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
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=
Docusign Envelope ID: 8B00429D-F548-49EF-A778-566E1A15E0E6
17 ||.
/I
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and all claims, suits, and actions brought against said personal and/or entities by reason of
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
L.
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,
8 and NAC Chapter 671 as stated in the Complaint, which may result in further disciplinary
action. Respondent has signed and dated this Consent Order only after reading and
understanding all terms herein.
M.
Respondent represents and warrants that the person signing on behalf of
Respondent has all the requisite power and authority to conduct its business and to execute,
deliver, and perform Respondent's obligations under this Consent Order and the legal power,
right and authority to make this Consent Order and to bind Respondent hereunder.
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Docusign Envelope ID: 8B00429D-F548-49EF-A778-566E1A15E0E6
In WITNESS WHEREOF, we have each executed this Consent Order as of the date
set forth below.
SO ORDERED is dayor. Moral 2028.
By:
STATE OF NEVADA
DEPARTMENT OF BUSINESS AND INDUSTRY
FINANCIAL INSTITUTIONS DIVISION
andy O'Laughlir
Sough
Commissioner
AGREED AND CONSENTED TO this 10
day of March
, 2026.
BITCOIN DEPOT OPERATING LLC
DocuSigned by:
C. Scott Buchanan
3/10/2026
By: Scoff Buchanan
Its: President and Chief Executive Officer
Approved as to form:
AARON D. FORD
Attorney General
Is Michael Demer
Michael Detmer
Chief Deputy Attorney Genera
Attorney for the Division
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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 Ith of March 2026, 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:
Bitcoin Depot Operating LLC
Attn: Edi Reber
8601 Dunwoody Place, Suite 308
Sandy Springs, Georgia 30350
Certified Mail: 7014 2870 0001 8499 4581
Bitcoin Depot Operating LLC
Attn: Edi Reber
2870 Peachtree Rd NW, #327
Atlanta, GA 30305
Certified Mail: 7014 2870 0001 8799 4598
Bitcoin Depot Operating LLC
c/o Corporation Service Company
112 North Curry Street
Carson City, Nevada 89703
Certified Mail: 7014 2870 0001 8499 4604
DATED this
1th day of March 2026.
By Lettie