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Abu Dhabi authorities impose $12.46 million fines on firms, ban CEO for 'breaches, misconduct'
Christopher Flinos has been prohibited indefinitely from performing any function in a financial services business in ADGM, as well as imposed $750,000 penalties on him
- PUBLISHED: Mon 14 Apr 2025, 12:54 PM
Heavy penalties were imposed on Hayvn Group of Companies, its former CEO Christopher Flinos, and related entities for 'serious regulatory breaches and misconduct', the Abu Dhabi Global Market (ADGM) announced on Monday.
The Financial Services Regulatory Authority (FSRA) of ADGM said its investigation found “serious breaches and misconduct concerning the operations of three related party companies and Christopher Flinos". It confirmed that “no ADGM client assets or money were lost as a result of the relevant misconduct".
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FSRA said it cancelled the licence of Hayvn ADGM’s Financial Services Permission (FSP), prohibited Flinos indefinitely from performing any function in a financial services business in ADGM, as well as imposed financial penalties of $8.85 million (Dh32.5 million) across the four parties involved.
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It imposed a $3.6 million fine against AC Holding Limited registered in the Cayman Islands, $3 million against AC Limited (Hayvn ADGM), $1.5 million against AC Holding Limited; and $750,000 against Christopher Flinos.
Emmanuel Givanakis, CEO of the FSRA, said they will take robust and appropriate enforcement action against individuals and entities that violate the 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, ” he said.
Givanakis added the licence of Hayvn ADGM has been cancelled and 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.
In addition, the Registration Authority (RA) of ADGM announced that its investigation into the Special Purpose Vehicle (SPV), AC Holding Limited (AC Holding), and its sole shareholder and director, Christopher Flinos found that AC Holding exceeded the scope of its ADGM SPV commercial license by purporting to be an investment company offering financial services for clients and processing wire transactions to convert cryptocurrencies into fiat currencies and vice versa. Moreover, AC Holding submitted four false annual accounts to the RA for the financial years 2019 to 2022.
The RA also found that Christopher Flinos engaged in fraudulent trading, where AC Holding facilitated (unlicensed) cryptocurrency conversion transactions and a number of parties were misled about the transactions. Christopher Flinos also facilitated the falsification and provision of hundreds of company documents to fraudulently maintain bank accounts.
As a result, the RA has imposed the following financial penalties totalling $3.615 million, including $3.3 million against Christopher Flinos for providing false information to the RA, engaging in various fraudulent schemes and the falsification of company documents in contravention of the ADGM Companies Regulations 2020.
“Maintaining business integrity and safeguarding business confidence in ADGM are at the forefront of the Registration Authority’s objectives. We remain committed to preventing and deterring conduct that may harm businesses, their clients and investors. Where non-compliance is identified, the Registration Authority will take effective, proportionate and dissuasive disciplinary action to protect ADGM participants. This includes banning individuals who lack fitness and propriety and pose an unacceptable risk to investors from holding leadership positions within companies in ADGM,” said Hamad Sayah Al Mazrouei, CEO of ADGM Registration Authority.
Why penalised
The FSRA of ADGM added that Hayvn ADGM was penalised because it exceeded the scope of its FSP by allowing client transactions to be routed through accounts held by AC Holding, the unregulated special purpose vehicle entity registered in ADGM, without any appropriate protections being in place. It also failed to establish and maintain adequate systems and controls to manage its operations and risks, as well as to recognise and record all of its client relationships, breaching the FSRA’s Anti-Money Laundering requirements.
Hayvn Cayman and AC Holding were penalised as they 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 related to the conversion of Virtual Assets to fiat currency and vice versa through the accounts held and controlled by AC Holding, the SPV that was not licensed by the FSRA and therefore prohibited from conducting any form of financial services activity in ADGM. As a result, both Hayvn Cayman and AC Holding were found to have carried out unlicensed payments and arranged services in relation to virtual asset activities in ADGM.
Moreover, Christopher Flinos was banned and fined for playing a central role in directing and controlling the unlicensed activity in ADGM and as SEO of Hayvn ADGM and CEO of Hayvn Cayman and as the sole director of AC Holding.
ADGM revealed that he was found to have been centrally involved in the breaches and misconduct. “Christopher Flinos lacked integrity and failed to take reasonable care to ensure that Hayvn ADGM operated in compliance with the applicable rules and regulations of ADGM, for which he was ultimately responsible as SEO.”
Moreover, the regulator elaborated that Hayvn Cayman, AC Holding and Christopher Flinos created and disseminated false and misleading information about the nature of the transactions related to virtual assets 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 these accounts. These documents were produced under the direction of Christopher Flinos with the involvement of both Hayvn Cayman and AC Holding.
ADGM said in the statement that Hayvn ADGM, Hayvn Cayman and Christopher Flinos provided false and misleading information to the FSRA in response to requests for information including the nature and scope of the business operations associated with each entity above and specifically AC Holding undermining the integrity of the regulatory process.
