Abu Dhabi – The Abu Dhabi Global Market’s (ADGM) Financial Services Regulatory Authority (FSRA) has imposed a combined penalty of $12.46 million on the Hayvn Group, its affiliated entities, and former CEO Christopher Flinos, following findings of serious regulatory misconduct and breaches.
The enforcement action includes the revocation of Hayvn ADGM’s Financial Services Permission (FSP) and a lifetime ban on Flinos from performing any function in any financial services business within the ADGM jurisdiction.
The investigation revealed that unauthorised virtual asset services were carried out through an unregulated special purpose vehicle (SPV), and that Flinos had deliberately misled regulators during the inquiry process.
“This case involved significant misconduct,” said Emmanuel Givanakis, CEO of the FSRA. “The firms and individuals knowingly violated regulatory rules, and such behavior undermines market integrity. We will take decisive enforcement action where warranted.”
Breakdown of Penalties:
FSRA fines totaling $8.85 million were imposed as follows:
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$3.6 million – AC Holding Ltd. (Hayvn Cayman), registered in the Cayman Islands and parent entity of the Hayvn Group, for conducting unlicensed virtual asset financial services.
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$3 million – AC Limited (Hayvn), the ADGM-regulated subsidiary, for exceeding the scope of its license and failing compliance measures.
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$1.5 million – AC Holding Ltd. (SPV registered in ADGM), unlicensed but used to channel client transactions.
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$750,000 – Christopher Flinos, the group’s former senior executive, for providing false and misleading information and overseeing unauthorized financial activities.
Additional Sanctions from ADGM Registration Authority
In a parallel investigation, the ADGM Registration Authority (RA) levied further fines totaling $3.61 million.
This included:
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$3.3 million against Flinos, for submitting false information, engaging in fraudulent schemes, and falsifying corporate documents.
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The RA also cited serious breaches related to the misuse of the unregulated SPV (AC Holding) to execute client-related transactions.
Regulatory Failures and AML Violations
The FSRA concluded that Hayvn ADGM not only operated beyond its licensed permissions, but also failed to implement adequate risk controls, maintain proper records, and comply with anti-money laundering (AML) regulations.
Between October 2018 and May 2024, Hayvn Cayman and AC Holding were involved in unlicensed financial services activity, routing virtual asset-to-fiat conversions through unauthorized accounts. These operations occurred without safeguards or client protection protocols, directly breaching FSRA’s financial conduct standards.
“The regulatory response reflects the gravity of the misconduct and our commitment to maintaining the integrity of ADGM’s financial ecosystem,” Givanakis added.
The enforcement sends a strong message to firms operating within the UAE’s financial free zones: non-compliance, lack of transparency, and regulatory evasion will face strict and public consequences.
