Abu Dhabi Global Market’s (ADGM) Financial Services Regulatory Authority (FSRA) and Registration Authority (RA) have concluded separate enforcement actions against entities in the Hayvn Group and its founder Christopher Flinos, imposing combined penalties of $12.46 million, cancelling licences, and issuing long-term bans for regulatory misconduct and unauthorised virtual asset activity.
FSRA enforcement
The FSRA fined four parties a total of $8.85 million and revoked the Financial Services Permission (FSP) of AC Limited (Hayvn ADGM), following findings that Hayvn Cayman, Hayvn ADGM, and AC Holding conducted unauthorised virtual asset activities between 2018 and 2024. It also permanently banned Flinos from performing any financial services function in ADGM.
According to the FSRA, Hayvn ADGM exceeded its authorised permissions by directing client transactions through AC Holding, an unlicensed special purpose vehicle (SPV) registered in ADGM. The firm failed to implement adequate anti-money laundering (AML) systems and internal controls.
Hayvn Cayman and AC Holding routed virtual asset-to-fiat conversions through AC Holding accounts despite not being licensed by the FSRA. Flinos, in his roles as CEO of Hayvn Cayman, Senior Executive Officer of Hayvn ADGM, and sole director of AC Holding, was found to have directed the activity.
The FSRA said more than 200 false documents were generated under AC Holding letterhead to mislead banking institutions. Flinos and the three entities were also found to have provided misleading information to the FSRA during its investigation.
FSRA fines:
- $3.6 million – Hayvn Cayman
- $3 million – Hayvn ADGM
- $1.5 million – AC Holding
- $750,000 – Christopher Flinos
No client funds were reported lost. The FSRA’s enforcement was carried out in coordination with the ADGM Registration Authority and the Cayman Islands Monetary Authority.
RA enforcement
In a parallel action, ADGM’s Registration Authority concluded its investigation into AC Holding and Christopher Flinos, imposing additional penalties totalling $3.615 million for exceeding the scope of AC Holding’s commercial licence and submitting false financial accounts from 2019 to 2022.
The RA found that Flinos engaged in fraudulent trading by using AC Holding to conduct unauthorised crypto-to-fiat conversions and by submitting falsified company documents to maintain banking access. He was disqualified from serving as a director of any ADGM company for 15 years.
RA fines:
- $15,000 – AC Holding for licence breach
- $300,000 – AC Holding for false accounts
- $3.3 million – Christopher Flinos for fraudulent conduct
The FSRA and RA stated that these actions aim to protect ADGM’s regulatory framework and financial integrity.
