The Registration Authority (RA) and the Financial Services Regulatory Authority (FSRA) of Abu Dhabi Global Market (ADGM) have completed investigations into serious regulatory breaches involving AC Holding Limited (AC Holding), its sole shareholder and director Christopher Flinos, and related entities operating under the name ‘HAYVN’.
The RA’s investigation determined that AC Holding exceeded its ADGM Special Purpose Vehicle (SPV) commercial license by acting as an unlicensed investment company.
It processed transactions converting cryptocurrencies to fiat and vice versa and submitted four false annual accounts for the years 2019 to 2022.
Furthermore, Christopher Flinos was found to have engaged in fraudulent trading and assisted in falsifying hundreds of company documents to maintain unlicensed bank accounts.
The RA has imposed financial penalties totalling USD 3,615,000:
- US$15,000 against AC Holding for exceeding the scope of its license.
- US$300,000 for filing false annual accounts.
- US$3.3 million against Christopher Flinos for providing false information and engaging in fraudulent activities.
Additionally, Christopher Flinos has been disqualified from serving as a director of any ADGM-based company for 15 years due to his unfitness to hold such a position.
Hamad Sayah Al Mazrouei, CEO of ADGM Registration Authority, stated,

“Maintaining business integrity and safeguarding business confidence in ADGM are at the forefront of the Registration Authority’s objectives. Where non-compliance is identified, the Registration Authority will take effective, proportionate and dissuasive disciplinary action.”
The FSRA’s investigation revealed significant breaches and misconduct by the HAYVN group, which included allowing client transactions through accounts held by AC Holding, an unregulated entity, without the required protections.
The entities were involved in substantial unlicensed financial services activities between October 2018 and May 2024, with Christopher Flinos directing these operations.
In total, the FSRA has imposed financial penalties of US$8.85 million against the involved parties:
- US$3.6 million against Hayvn Cayman, the parent company.
- US$3 million against Hayvn ADGM, the licensed subsidiary.
- US$1.5 million against AC Holding, the unlicensed SPV.
- US$750,000 against Christopher Flinos.
The serious breaches identified included inadequate systems to manage operations, the creation of false documentation to mislead banking partners, and providing misleading information to the FSRA throughout the investigation.
Emmanuel Givanakis, CEO of the FSRA, emphasised,

“The FSRA will take robust and appropriate enforcement action against individuals and entities that violate our regulatory framework. Such misconduct will not be tolerated and warrants strong regulatory penalties.”
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