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Rupali Exchange, Inc., a licensed money transmitter,
 has entered into a Settlement Agreement with the Superintendent of Banks which includes the payment of a $15,000 fine.

State of New York Banking Department
New York, New York

In the Matter of  


A Transmitter of Money Licensed Pursuant
To Article XIII-B of the New York 
Banking Law 


WHEREAS, Rupali Exchange, Inc. (“Rupali” or the “Licensee”), with corporate headquarters at 37-13 74th Street, Jackson Heights, New York 11372, was granted a license on August 12, 2002 to engage in business as a money transmitter pursuant to Article XIII-B of the New York Banking Law (the “Banking Law”) by the Superintendent of Banks (the “Superintendent”) of the New York State Banking Department (the “Banking Department”); and

WHEREAS, in recognition of their common goals to ensure compliance with applicable federal and state laws, rules and regulations by the Licensee, and to manage financial, operational, legal, reputational and compliance risk of the Licensee, the Banking Department and the Licensee have mutually agreed to enter into this Settlement Agreement (“Agreement”);

WHEREAS, the Banking Department examination as of March 31, 2003 revealed that Rupali had failed to adopt and implement an anti-money laundering compliance program, as required by 31 U.S.C. Section 5318 (h) & 31 C.F.R. Part 103.125; 

WHEREAS, as a result of the findings of such examination, Licensee has voluntarily ceased operations: and

WHEREAS, the Superintendent and the Licensee mutually agree to resolve the issue noted during the examination on the basis of the terms and conditions set forth herein, which include the payment by Licensee of a fine in the amount of $15,000.00, in lieu of litigating it in a hearing seeking revocation of Rupali’s license.


  1. Fully understanding the terms and conditions of this Agreement, Rupali knowingly and voluntarily waives (1) its right to a hearing on the violation cited above, and (2) any and all rights of appeal relating to this matter. 

  2. Rupali will take all necessary steps to assure that it is in compliance, and remains in compliance, with all applicable laws, rules and regulations.

  3. Rupali agrees to submit monthly reports to the Banking Department covering compliance with the Bank Secrecy Act.

  4. Rupali agrees to an audit of its anti-money laundering program, performed by an outside audit firm acceptable to the Department, within six (6) months of the date of this agreement and submit a copy of the audit to the Banking Department within 15 days from the completion of said audit.

  5. Rupali agrees to pay a fine in the amount of $15,000.00 to the Superintendent, and further, that it will not restart its operations until, such fine has been paid.  Payment shall be made by electronic transfer, in immediately available funds, pursuant to transfer instructions received from the Banking Department. Failure to make timely payment shall result in the commencement of a hearing to revoke the Licensee’s license. 

  6. All communications regarding this Settlement Agreement shall be sent to:

Paul J. Fazio
Deputy Superintendent of Banks
Licensed Financial Services Division
New York State Banking Department
One State Street
New York, New York 10004

Shaikh Islam, President
Rupali Exchange, Inc.
37-133 74th Street
Jackson Heights, New York 10118

  1. The provisions of this Agreement shall not bar, estop or otherwise prevent the Superintendent, or any state or federal agency or department, from taking any other action affecting the Licensee, any of its current or former officers, directors, employees, or insiders, or their successors or assigns with respect to any matter relating to this Agreement.

  2. No extension or waiver of the terms of this Agreement shall be binding on the Banking Department unless it is in writing and signed by the Superintendent. 

  3. Each provision of this Agreement shall remain effective and enforceable until stayed, modified, terminated or suspended in writing by the Superintendent.

  4. The effective date of this Agreement is the date on which it is executed by the Superintendent or her Deputy.

  5. The provisions of this Agreement are not confidential.

Agreed to and Accepted: 

Dated:            ____________________.  By: ___________________________
Paul J. Fazio
Deputy Superintendent of Banks 
New York State Banking Department  
Dated:            ____________________.

By: ___________________________
Shaikh Islam
Rupali Exchange, Inc.

Department of Financial Services


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