The Financial Services Regulatory Authority (FSRA) of Abu Dhabi Global Market has imposed financial penalties totalling USD 8.85 million on the "HAYVN" group of companies, a related special purpose vehicle, and the group's former chief executive, following an investigation into serious regulatory breaches and misconduct involving virtual asset activities.

The enforcement action, announced by the FSRA, resulted in three outcomes: the cancellation of Hayvn ADGM's Financial Services Permission (FSP); an indefinite prohibition on Christopher Flinos from performing any function in a financial services business in ADGM; and the USD 8.85 million in fines spread across four parties.

The penalty breakdown is as follows:

• USD 3.6 million against AC Holding Limited registered in the Cayman Islands ("Hayvn Cayman"), the parent company of the group operating under the name HAYVN, which provided financial services related to virtual assets.
• USD 3 million against AC Limited (Hayvn) ("Hayvn ADGM"), an ADGM-based subsidiary of Hayvn Cayman that the FSRA licensed and regulated to conduct specific financial services activities in relation to virtual assets.
• USD 1.5 million against AC Holding Limited ("AC Holding"), a special purpose vehicle registered with ADGM's Registration Authority and not licensed by the FSRA to carry out any form of financial services activity in ADGM. The FSRA notes this entity is unconnected to Hayvn Cayman and Hayvn ADGM.
• USD 750,000 against Christopher Flinos, the former Senior Executive Officer (SEO) of Hayvn ADGM, CEO of Hayvn Cayman, and sole owner and director of AC Holding.

What the Investigation Found

The FSRA identified five principal areas of breach and misconduct.

First, Hayvn ADGM exceeded the scope of its FSP by allowing client transactions to be routed through accounts held by AC Holding, the unregulated SPV, without appropriate protections in place. The firm failed to establish and maintain adequate systems and controls to manage its operations and risks, and failed to recognise and record all of its client relationships, breaching the FSRA's Anti-Money Laundering (AML) requirements.

Second, Hayvn Cayman and AC Holding carried out significant unlicensed financial services activity in relation to virtual assets in ADGM from around October 2018 to around May 2024. Hayvn Cayman routed client transactions converting virtual assets to fiat currency, and vice versa, through accounts held and controlled by AC Holding — an entity prohibited from conducting any form of financial services activity in ADGM. The FSRA found both carried out unlicensed payments and arranging services in relation to virtual asset activities in ADGM.

Third, Christopher Flinos played a central role in directing and controlling the unlicensed activity in ADGM. As SEO of Hayvn ADGM, CEO of Hayvn Cayman, and sole director of AC Holding, he was found to have been centrally involved in the breaches and misconduct. The FSRA found that Flinos lacked integrity and failed to take reasonable care to ensure Hayvn ADGM complied with applicable ADGM rules and regulations, for which he bore ultimate responsibility as SEO.

Fourth, Hayvn Cayman, AC Holding, and Flinos created and disseminated false and misleading information about the nature of the virtual asset transactions routed through AC Holding's accounts. This included the provision of over 200 false and misleading documents on AC Holding letterheads to AC Holding's banking partners to open and then maintain the operation of those accounts. Flinos directed the production of these documents, with the involvement of both Hayvn Cayman and AC Holding.

Fifth, Hayvn ADGM, Hayvn Cayman, and Flinos provided false and misleading information to the FSRA in response to requests for information, including about the nature and scope of the business operations of each entity and specifically AC Holding. The regulator found this undermined the integrity of the regulatory process.

The FSRA stated that, as part of its investigation, it took steps to ensure that no ADGM client assets or money were lost as a result of the relevant misconduct.

Regulator's Statement

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. In this case, the actions of the entities and individuals involved were particularly serious, as they conducted unauthorised Virtual Asset activities through an unregulated entity based in ADGM. Furthermore, Christopher Flinos was found to have provided false and misleading information and statements during the investigation. Such misconduct will not be tolerated and warrants strong regulatory penalties which send a strong message of deterrence."

Givanakis added: "To address this serious misconduct, the licence of Hayvn ADGM 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 FSRA acknowledged and thanked ADGM's Registration Authority and the Cayman Islands Monetary Authority (CIMA) for their cooperation during the investigation.

Practical Consequences for Practitioners

The decision signals how the FSRA will treat group structures that mix licensed ADGM entities with offshore parents and unlicensed onshore SPVs. Firms should take three points away. Routing client transactions through unlicensed affiliated vehicles — even those nominally registered with the Registration Authority — constitutes unlicensed financial services activity carrying multi-million-dollar exposure for both the operating entity and its parent. Senior executives face personal liability: the FSRA held the SEO individually responsible, fining Flinos USD 750,000 and banning him indefinitely. Perhaps most significantly, providing inaccurate information to the regulator during an investigation is treated as independent misconduct that undermines the regulatory process itself — here compounded by over 200 false documents issued to banks. The final notices issued to all four parties on 3 April 2025 are available on the ADGM website and merit close reading for the FSRA's reasoning on scope-of-licence breaches, AML failures, and individual accountability.