Abu Dhabi Global Market (ADGM) Financial Services Regulatory Authority (FSRA) has taken enforcement action following an investigation into serious regulatory breaches and misconduct linked to the HAYVN group, related entities and former CEO Christopher Flinos. The action cancels AC Limited’s Financial Services Permission in ADGM, prohibits Flinos indefinitely from performing any function in an ADGM financial services business, and imposes total financial penalties of USD 8.85 million. The penalties comprise USD 3.6 million on AC Holding Limited in the Cayman Islands (Hayvn Cayman), USD 3 million on AC Limited (Hayvn ADGM), USD 1.5 million on AC Holding Limited, an ADGM-registered special purpose vehicle not licensed by FSRA and described as unconnected to Hayvn Cayman and Hayvn ADGM, and USD 750,000 on Flinos. FSRA found Hayvn ADGM exceeded the scope of its permission by routing client transactions through accounts held by the unregulated SPV without appropriate protections, had inadequate systems and controls, and failed to recognise and record all client relationships in breach of Anti-Money Laundering requirements; it also found Hayvn Cayman and the SPV carried out significant unlicensed financial services activity in relation to Virtual Assets in ADGM from around October 2018 to around May 2024, including unlicensed payments and arranging services. The investigation further identified false and misleading information provided to banking partners, including over 200 misleading documents, and false or misleading information provided to FSRA, and FSRA noted cooperation from ADGM’s Registration Authority and the Cayman Islands Monetary Authority.

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