Introduction Of Abu Dhabi
The Abu Dhabi Global Market (ADGM) has levied more than $12 million in fines and imposed an indefinite ban on Christopher Flinos, the former CEO of Hayvn Group, following what regulators described as “serious regulatory breaches and misconduct.” Abu Dhabi
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The Financial Services Regulatory Authority (FSRA) of ADGM announced the enforcement action on Monday, citing extensive violations involving three related entities—Hayvn ADGM, Hayvn Cayman, and AC Holding Limited—and their former senior executive. Abu Dhabi
Key Findings from the FSRA Investigation
According to the FSRA, its investigation uncovered unauthorized virtual asset activities and systemic misconduct conducted through an unregulated entity based in ADGM. Though no client assets or funds were lost, the breaches were deemed severe enough to warrant significant penalties.
Hayvn ADGM’s financial services license was revoked, and Flinos has been permanently prohibited from carrying out any functions within a financial services business in ADGM. The total fines across all parties amounted to $8.85 million. Abu Dhabi
Breakdown of the penalties includes:
- AC Holding Limited (Cayman Islands): $3.6 million
- AC Limited (Hayvn ADGM): $3 million
- AC Holding Limited (again, under separate actions): $1.5 million
- Christopher Flinos: $750,000
Regulatory Commentary
“The actions of the entities and individuals involved were particularly serious,” said Emmanuel Givanakis, CEO of the FSRA. “They conducted unlicensed virtual asset activities through an unregulated entity, and Mr. Flinos provided false and misleading statements during the investigation. Such misconduct will not be tolerated.”
He emphasized that the firm’s license was canceled, and strong penalties were imposed to deter similar behavior.
Additional Sanctions by the Registration Authority
Separately, the ADGM Registration Authority (RA) conducted its own investigation into AC Holding Limited and Flinos. It concluded that the company operated well beyond its permitted scope as a Special Purpose Vehicle (SPV). AC Holding was found offering unlicensed financial services, processing cryptocurrency transactions, and submitting four years’ worth of falsified financial statements (2019–2022).
Flinos was also found to have engaged in fraudulent trading, helped falsify hundreds of company documents, and misled both investors and banks. As a result, the RA imposed an additional $3.615 million in penalties—$3.3 million of which were directly against Flinos.
“Maintaining integrity and investor confidence is critical to our mission,” said Hamad Sayah Al Mazrouei, CEO of the ADGM Registration Authority. “We will not hesitate to take firm action against individuals who pose a risk to the market.”
Why These Penalties Were Imposed
The core of the misconduct centered on unlicensed and misleading virtual asset services. Hayvn ADGM allowed client transactions to pass through AC Holding—an unregulated SPV—without implementing adequate controls or protections. This violated ADGM’s anti-money laundering rules and financial regulations.
From late 2018 to mid-2024, both Hayvn Cayman and AC Holding facilitated cryptocurrency-to-fiat transactions without proper licensing. In many cases, clients were unaware of how their transactions were being handled. These operations were orchestrated under Flinos’s direction, who held senior leadership roles across all three entities.
Investigators revealed that over 200 false documents were created and used to mislead banking partners—actions attributed directly to Flinos and his companies.
The FSRA concluded that Flinos “lacked integrity and failed to take reasonable care to ensure compliance,” stating he was at the heart of the misconduct.
