emirates7 - The Financial Services Regulatory Authority (FSRA) of Abu Dhabi Global Market (ADGM) announced the implementation of enforcement actions following an investigation into serious regulatory violations and misconduct related to the Hayvn Group of Companies, operating under the name “HAYVN,” its former CEO Christopher Flinos, and related entities.
The investigation conducted by the FSRA, according to a press release issued today by the Authority, concluded that there were serious violations and misconduct in the operations of three affiliated companies and the performance of Christopher Flinos.
During the investigation, the FSRA took necessary steps to ensure that no ADGM client assets or funds were lost as a result of this misconduct. The enforcement actions included the cancellation of the Financial Services Permission (FSP) granted to “Hayvn ADGM,” the indefinite prohibition of Christopher Flinos from performing any function in financial services within ADGM, and the imposition of financial penalties totalling US$8.85 million on the four parties involved.
The fines imposed by the FSRA included US$3.6 million on AC Holding Limited, registered in the Cayman Islands under the name “Hayvn Cayman,” the parent company of a group of entities operating under the name “HAYVN” providing financial services related to virtual assets; and US$3 million on AC Limited (Hayvn ADGM), a subsidiary of Hayvn Cayman operating within ADGM, licenced and regulated by the FSRA to carry out specific financial services activities related to virtual assets; in addition to US$1.5 million on AC Holding Limited, a Special Purpose Vehicle (SPV) registered with the ADGM Registration Authority and not licenced by the FSRA to conduct any financial services in ADGM and not connected to Hayvn Cayman or Hayvn ADGM; and US$750,000 on Christopher Flinos, former CEO of Hayvn ADGM, CEO of Hayvn Cayman, and sole owner and director of AC Holding.
The FSRA investigation identified serious violations and misconduct, including Hayvn ADGM exceeding the scope of its Financial Services Permission by allowing client transactions to be conducted through accounts held by AC Holding, an unregulated SPV registered in ADGM, without any appropriate safeguards.
The company failed to establish and maintain adequate systems and controls to manage its operations and risks, as well as to identify and record all of its client relationships.
Hayvn Cayman and AC Holding carried out significant unlicenced financial services activities related to virtual assets in ADGM between October 2018 and May 2024, where Hayvn Cayman processed client transactions involving the conversion of virtual assets to fiat currency and vice versa through accounts held and managed by AC Holding, an unlicenced SPV, thereby being prohibited from carrying out any financial services activities within ADGM.
As a result, both Hayvn and AC Holding were found to have performed unlicenced payment and arranging services related to virtual asset activities in ADGM.
According to the press release, Christopher Flinos played a key role in directing and managing the unlicenced activity in ADGM and was found primarily responsible for the violations and misconduct as the Senior Executive Officer of Hayvn ADGM, CEO of Hayvn Cayman, and the sole owner and director of AC Holding. He lacked integrity and failed to exercise due care to ensure that Hayvn ADGM operated in accordance with the rules and regulations in ADGM, for which he was responsible as the Senior Executive Officer of the company.
According to the statement, Hayvn Cayman, AC Holding, and Christopher Flinos fabricated and published false and misleading information about the nature of the virtual asset transactions conducted through the accounts of AC Holding. This included the submission of more than 200 falsified and misleading documents using official letterhead of AC Holding to the company’s banking partners to open and maintain these accounts, issued under the supervision of Christopher Flinos with the participation of Hayvn Cayman and AC Holding.
Hayvn Cayman, AC Holding, and Christopher Flinos also provided false and misleading information to the FSRA in response to its inquiries regarding the nature and scope of the business operations of the entities mentioned above, particularly AC Holding, thereby undermining the integrity of the regulatory process.
Emmanuel Givanakis, CEO of the FSRA of ADGM, said, “The FSRA will take robust and appropriate enforcement action against individuals and entities that violate our regulatory framework. The actions of the entities and individuals in this case involved serious violations, including conducting unauthorised virtual asset activities through an unregulated entity within ADGM. Christopher Flinos was found to have provided false and misleading information during the investigation.”
He added, “To address this serious misconduct, Hayvn ADGM’s licence has been cancelled, significant fines have been imposed on the entities involved, and Christopher Flinos has been prohibited from holding any functions in relation to financial services in ADGM. The FSRA remains ever-vigilant and committed to holding entities and individuals accountable for their actions and ensuring the integrity of the financial system in ADGM.”
The investigation conducted by the FSRA, according to a press release issued today by the Authority, concluded that there were serious violations and misconduct in the operations of three affiliated companies and the performance of Christopher Flinos.
During the investigation, the FSRA took necessary steps to ensure that no ADGM client assets or funds were lost as a result of this misconduct. The enforcement actions included the cancellation of the Financial Services Permission (FSP) granted to “Hayvn ADGM,” the indefinite prohibition of Christopher Flinos from performing any function in financial services within ADGM, and the imposition of financial penalties totalling US$8.85 million on the four parties involved.
The fines imposed by the FSRA included US$3.6 million on AC Holding Limited, registered in the Cayman Islands under the name “Hayvn Cayman,” the parent company of a group of entities operating under the name “HAYVN” providing financial services related to virtual assets; and US$3 million on AC Limited (Hayvn ADGM), a subsidiary of Hayvn Cayman operating within ADGM, licenced and regulated by the FSRA to carry out specific financial services activities related to virtual assets; in addition to US$1.5 million on AC Holding Limited, a Special Purpose Vehicle (SPV) registered with the ADGM Registration Authority and not licenced by the FSRA to conduct any financial services in ADGM and not connected to Hayvn Cayman or Hayvn ADGM; and US$750,000 on Christopher Flinos, former CEO of Hayvn ADGM, CEO of Hayvn Cayman, and sole owner and director of AC Holding.
The FSRA investigation identified serious violations and misconduct, including Hayvn ADGM exceeding the scope of its Financial Services Permission by allowing client transactions to be conducted through accounts held by AC Holding, an unregulated SPV registered in ADGM, without any appropriate safeguards.
The company failed to establish and maintain adequate systems and controls to manage its operations and risks, as well as to identify and record all of its client relationships.
Hayvn Cayman and AC Holding carried out significant unlicenced financial services activities related to virtual assets in ADGM between October 2018 and May 2024, where Hayvn Cayman processed client transactions involving the conversion of virtual assets to fiat currency and vice versa through accounts held and managed by AC Holding, an unlicenced SPV, thereby being prohibited from carrying out any financial services activities within ADGM.
As a result, both Hayvn and AC Holding were found to have performed unlicenced payment and arranging services related to virtual asset activities in ADGM.
According to the press release, Christopher Flinos played a key role in directing and managing the unlicenced activity in ADGM and was found primarily responsible for the violations and misconduct as the Senior Executive Officer of Hayvn ADGM, CEO of Hayvn Cayman, and the sole owner and director of AC Holding. He lacked integrity and failed to exercise due care to ensure that Hayvn ADGM operated in accordance with the rules and regulations in ADGM, for which he was responsible as the Senior Executive Officer of the company.
According to the statement, Hayvn Cayman, AC Holding, and Christopher Flinos fabricated and published false and misleading information about the nature of the virtual asset transactions conducted through the accounts of AC Holding. This included the submission of more than 200 falsified and misleading documents using official letterhead of AC Holding to the company’s banking partners to open and maintain these accounts, issued under the supervision of Christopher Flinos with the participation of Hayvn Cayman and AC Holding.
Hayvn Cayman, AC Holding, and Christopher Flinos also provided false and misleading information to the FSRA in response to its inquiries regarding the nature and scope of the business operations of the entities mentioned above, particularly AC Holding, thereby undermining the integrity of the regulatory process.
Emmanuel Givanakis, CEO of the FSRA of ADGM, said, “The FSRA will take robust and appropriate enforcement action against individuals and entities that violate our regulatory framework. The actions of the entities and individuals in this case involved serious violations, including conducting unauthorised virtual asset activities through an unregulated entity within ADGM. Christopher Flinos was found to have provided false and misleading information during the investigation.”
He added, “To address this serious misconduct, Hayvn ADGM’s licence has been cancelled, significant fines have been imposed on the entities involved, and Christopher Flinos has been prohibited from holding any functions in relation to financial services in ADGM. The FSRA remains ever-vigilant and committed to holding entities and individuals accountable for their actions and ensuring the integrity of the financial system in ADGM.”