UAE based HAYVN which is a digital asset focused financial institution, providing trading, asset Management, custody, and payments previously regulated and active in Abu Dhabi, has fallen under a great wall of scrutiny and a black cloud both with regards of the activities of its previous CEO as well its current status as a regulated entity in the UAE.

In less than a week, Hayvn not only announced the so called resignation of its CEO Christopher Flinos and the request to make its status inactive in Abu Dhabi ADGM ( Abu Dhabi Global Market), but it also insinuated that the CEO had carried out a huge misconduct. In an email statement made by the PR agency of Hayvn, Fully Vested, to UNLOCK Blockchain, the agency noted, “The CEO stepped down from the management of the business, following a request from the Board of Directors due to the CEO’s conduct.”

Sources close to LaraontheBlock have noted that there has been speculation moving around with regards to possible embezzlement. This is further reconfirmed by the fact that Christopher Flinos is nowhere to be found. His phone is off, he does not respond to LinkedIn or other messages, and he himself has not made any statement to clear his name or explain his actions and that of the board of Hayvn.

LaraontheBlock reached out to the FSRA (Financial Services and Regulatory Authority) at ADGM with two questions. The first question, as a regulatory authority what actions have or will be taken towards Hayvn given the current cloud of speculation around it and the activities of its prior CEO?

The second question, can ADGM confirm that institutional clients in the UAE have not been effected financially or otherwise from the actions taken by the prior CEO and Hayvn as a crypto custodian and if effected will there be restitution?

The response which came from FSRA attributed to Mr. Emmanuel Givanakis. CEO of the Financial Services Regulatory Authority at ADGM stated, “As the financial regulator of ADGM, the Financial Services Regulatory Authority (FSRA) is bound by the highest levels of confidentiality and therefore is not positioned to discuss individual firms. The FSRA is committed to supervising all regulated entities so they maintain high standards to address risks related to their activities. ADGM stands as a transparent jurisdiction and has relevant public information on registered and licensed entities by its independent regulatory authorities in ADGM available on the public register.”

As per its license, AC Limited (Hayvn) is not permitted to deal with Retail Clients and is restricted to USD 1 million in total assets (Fiat and Accepted Virtual Assets) for a maximum of 100 clients.

When the same questions were posed to Ahmed W Ismail Co-Founder, Board Member & Operating Committee Member of HAYVN, he replied with this statement, “I can confirm that there has been a change of management at HAYVN. The CEO stepped down from the management of the business, following a request from the Board of Directors. Client funds are safe and there will be no disruption to the service of any clients. We continue to be a globally regulated business through our entities in Australia, Cayman and Lithuania.”

Hayvn was granted a license in ADGM in December 2021, allowing it to offer deals for investments, and virtual asset custody. In October 2023 Hayvn announced that had processed over 22 000 cryptocurrency transactions to date in 2023.

While back in August 2023 Swedish and UAE based Gayo aviation, a luxury travel company that offers aircraft management, consulting services, aircraft purchase and sales and flight deck services announced they were now offering crypto payments utilizing UAE HAYVN Pay.

In May Hayvn also announced that it had recorded returns of 19 percent increase on its crypto index fund since its launch in January 2023. The index fund  included the top 20 digital assets by market capitalization with a maximum weighting of 10% for any asset to increase diversification. It is a broad based index strategy with monthly rebalancing.

In short Hayvn was busy partnering and launching products.  It partnered with WooCommernce to offer a plug-in allowing merchants to create an additional revenue stream by accepting cryptocurrency payments from customers globally. It also partnered with crypto hardware manufacturer, Ledger to provide safe and robust off-ramping rails to users of Ledger’s Ledger Live service, as well as strategic partnership with Akurateco, a cutting-edge white-label payment software vendor operating worldwide to broaden crypto payments, and finally the most recent partnership with Malta based Apcopay, a Single Layer – Payments Orchestration Platform which they noted was crucial to HAYVN Pay’s global expansion strategy, providing an alternative payment avenue for businesses.

This flurry of activity while to many looks like reflections of growth and expansion could also have been a cover up for activities that led to the current situation Hayvn is in today.

Could the rushed technology upgrade implemented just before Flinos’s resignation which created widespread disruptions for Hayvn Pay Clients been part and one of the issues realted to the misconduct of the CEO?

These questions and many more should become clearer as the Abu Dhabi Global Market regulator investigates, and as Hayvn’s new leadership takes form.

Regulatory arm of Financial Free zone ADGM tells registered companies in ADGM that they have to adhere to the AML ( Anti money laundering) TFS ( targeted Financial sanctions) legislations and policies of the UAE Federal government. What this means is that even if companies have registered in ADGM as offshore or freezone entities they will still be legally bound to the UAE AML/TFS legislations which also include virtual assets.

The FSRA announced these  revisions that clarify the requirements that previously appeared in the AML Rulebook, reflecting the federal regulatory framework the UAE has put in place to combat money-laundering, the financing of terrorism and proliferation financing and ensure compliance with targeted financial sanctions. In particular, minor drafting changes have been made to the provisions relating to wire transfers in order to provide greater clarity that the FATF “Travel Rule” applies to Virtual Assets.

The revisions will be relevant to all firms subject to the provisions in the AML Rulebook, including authorized firms in the financial services sector and Designated Non-Financial Businesses and Professions.

The amended AML Rulebook, as per FSRA ( Financial Services and Regulatory Authority) of ADGM asserts that “ The AML Rulebook is made in recognition of the application of the Federal AML Legislation in the Abu Dhabi Global Market (“ADGM”) of the Federal AML Legislation. Nothing in the AML Rulebook affects the operation of Federal AML Legislation.”

A Relevant Person’s Governing Body is responsible for establishing, maintaining and monitoring the Relevant Person’s AML/TFS policies, procedures, systems and controls and compliance with applicable AML legislationthe AML Rulebook, the Financial Services and Markets Regulations 2015 (“FSMR”), and all applicable Federal AML Legislation.

The FSRA in its amended rule book clearly states, “ Federal AML Legislation applies in the ADGM.”

According to FSRA,  the definition of Federal AML Legislation is broad. It includes all federal legislation as may be in force relating to money laundering, terrorist financing, proliferation financing, the financing of unlawful organizations and sanctions compliance including Targeted Financial Sanctions. Particular pieces of legislation to be aware of include:

(a) Federal Law No. (7) of 2014 regarding Combatting Terrorism Offences;

(b) Federal Decree Law No. (20) of 2018 on Anti-Money Laundering, Combatting the Financing of Terrorism and Financing of Illegal Organisations;

Cabinet Decision No. (10) of 2019 concerning the Implementing Regulation of Decree Law No. (20) of 2018;

(d) Cabinet Decision No. (74) of 2020 concerning the Terrorism Lists Regulation and Implementation of UN Security Council Resolutions on the Suppression and Combatting of Terrorism, Terrorist Financing, Countering the Proliferation of Weapons of Mass Destruction and its Financing and Relevant Resolutions.

In addition FSRA has made it clear that it will hold the governing body and senior management of a registered entity as responsible for compliance with AML rulebook.

FSRA adds, that the Regulator expects the RBA (Risk Based Approach) to determine the breadth and depth of the Customer Due Diligence (“CDD”).

The same regulations apply when it comes to Sanctions. These UNSC obligations Targeted Financial Sanctions (“TFS”) are Sanctions issued by the UNSC or the U.A.E. involving asset freezing and other financial prohibitions targeted at individuals, entities or groups with the aim of combatting terrorism and terrorist financing, and countering the proliferation of WMD.

This also applies for FATF.

In a recent twist of events, and while the United States gears towards its presidential elections, a new political action Committee (PAC) called Fairshake and its network which includes names such as CoinBase, Kraken and Ripple, have announced that they will be reporting $78 million raised and in the bank at the end of the 2023 to support leaders who support US crypto and Blockchain innovation and responsible regulation in 2024 elections.

Fairshake is dedicated to advancing leaders who are poised to champion innovation and navigate the complexities of responsible regulation in the digital age.

It has already garnered support from Andreessen Horowitz,  Ark, Brian Armstrong, Blockchain Capital, Wences Casares, Circle, CoinBase, Ron Conway, Cumberland, Framework Ventures, Hunter Horsley, Jump Crypto, Kraken, Lightspark, Messari, Multicoin Capital, Paradigm, Potter Ventures, Ripple, Fred Wilson, Cameron Winklevoss and Tyler Winklevoss.

Interestingly Binance and other prominent players are still not on this list.

In a reccent Coinbase blog post the company noted, “The US’s current crypto regulatory standards are sub-par, ultimately driving innovation and financial freedom offshore. Given the stakes, crypto’s superpower of grassroots support will now be amplified through significant spending. Fairshake Super PAC and its affiliates representing the nation’s crypto community, have raised over $78 million – and counting – from 20 companies and leading industry voices to support bipartisan, crypto-forward candidates in 2024. That’s over $78 million to support the 52 million Americans who own digital assets and want a fair shake at the American Dream.”

Fairshake and its affiliates remain steadfast in their mission to support leaders who champion the interests of progressive innovation, including blockchain technology and the crypto industry, through independent advertising efforts.

In the  press release, Fairshake stated,”  In order for the blockchain economy to realize its full potential, a clear regulatory and legal framework for success is needed. The crypto community continues to advance initiatives to promote stability, tech innovation, and growth of the blockchain economy in the U.S., positioning it as a hub for blockchain technology development and adoption.”

Fairshake is a federal independent expenditure-only committee (super PAC) registered with the FEC and supports candidates solely through its independent activities. Protect Progress and Defend American Jobs are also federal super PACs registered with the FEC and are affiliated with Fairshake.

So could we soon be seeing a US president that will foster the crypto blockchain ecosystem in the United States?

On its launch day, UAE based Changer, a crypto custodian is waiving custody fees for its premium wallet clients. Changer is providing individuals globally with a reliable, convenient, and accessible wallet to safeguard and manage their digital assets.

This comes after Changer received its license from the Financial Services Regulatory Authority (FSRA) of Abu Dhabi Global Market (ADGM) allowing it to safe custody provisions, technology governance, and other system controls.

Changer’s launch of custody services for the safe storage of virtual assets comes in line with an increasing demand for independent custody and fund administration of digital assets from asset managers and asset owners, as this market continues to evolve.

Changer’s premium wallet and offerings are unique to the market being the only regionally built, independent custody provider. Changer’s premium wallet brings to the market a transparent, subscription-style monthly service for users based on the assets held under custody.

As Changer ramps up its operations, it is currently waiving custody fees for early adopters, which is planned to come into effect in Q1 2024.

Cryptocurrency investors from all over the world can easily open an account via the user-friendly Changer mobile application that can be downloaded from the App Store, Google Play Store, or Huawei App Gallery, and once verified, can use it to store their digital assets.

Changer is planning to introduce additional services in early Q1 2024 which will allow its users to convert their virtual assets into fiat currencies and hold those in escrow (client-money account) arrangements with a strategic bank partner which is yet to be disclosed.

Nadeem Ladki, Senior Executive Officer of Changer, commented on the launch: “We are happy to witness the successful and global launch of Changer.ae, as the region’s first locally built, independent virtual asset custody provider catering to individuals. For widespread adoption of digital assets, users need a safe, trusted counterpart; and we are committed to investing in the infrastructure and abiding by the regulations necessary to provide that peace of mind to our global users to be a leader in this space. We are proud to launch Changer.ae in the UAE, as the Nation has a well-balanced approach to digital asset adoption and financial regulation, thus making it a great market for our premium crypto custodian service platform. The UAE is a key driver of innovation and economic growth, encouraging more investors to enter the market, accelerate growth, enable collaboration, and continue to shape the future of finance”.

UAE Executive Office of Anti-Money Laundering and Counter Terrorism Financing (EO AML/CTF) and the Financial Monitoring Agency of the Republic of Kazakhstan (FMA) signed a Memorandum of Understanding (MOU)  to enhance bilateral cooperation in the combatting of financial crimes with focus on virtual assets, public-private partnership (PPP), education and capacity building, and asset recovery.

Knowledge sharing will cover virtual assets, with both parties committed to improving regional and local understanding of the risks associated with ML/TF/PF related to virtual assets. It will also include public-private partnership initiatives with the counterparties agreeing to collaborate on the establishment of rules to exchange strategic and operational information between the public and private sectors to prevent and combat money laundering and terrorism financing risks.

Hamid AlZaabi, Director General of the EO AML/CTF, remarked that the signing of the MoU formalizes the commitment made by both countries to protect the integrity of the global financial system. “Effective strategic engagement and cooperation with international counterparties is essential in the fight against financial crime and is central to the UAE’s strategy. The signing of this Memorandum with the FMA in Kazakhstan is significant and comes at a time when the EO AML/CTF is working to strengthen its collaboration efforts with international partners over the long-term. We have decided to focus on four key areas to ensure that our coordination is targeted, allowing us to make a real impact in addressing the most pressing issues in AML/CFT today.”

Zhanat Elimanov, Chairman of the FMA, welcomed to MoU, and said, “This year the relationship between our countries in the AML/CFT field has reached a new level. We have managed to establish an effective exchange of strategic and operational information. This has contributed to the successful investigation of major cases on money laundering committed in our country. We are inspired by UAE’s achievements in implementing IT solutions in AML activities. With great respect, we will adopt this experience”.

Circle Internet Financial (Circle), a leading global digital financial technology firm, and UAE based Fuze, MENA’s pioneering digital assets infrastructure provider, to expand adoption of USDC stablecoin in MENA region, after signing MOU (Memorandum of Understanding). Circle, the issuer of the US-dollar backed stablecoin USDC, will work with Fuze to expand the adoption of USDC amongst new customers in the region, such as banks, fintechs, traditional enterprises and Web3 firms.

The scope of the agreement covers the Middle East, Africa and Turkey, paving the way for the expanded use of USDC in these regions and the piloting of new use cases relevant to these markets.

Miriam Kiwan VP, Partnerships & Business Development, MENA for Circle said, “This collaboration marks a significant milestone in our efforts to enhance financial inclusion and drive the adoption of full-reserve payment stablecoins across MENA. By joining forces with Fuze, we aim to expand the accessibility and usage of USDC, while fostering closer integration between regional and global finance. We look forward to a successful partnership that propels financial innovation and creates new opportunities for individuals and businesses in these dynamic markets.”

Fuze Co-Founder and CEO Mohammed Ali Yusuf (Mo Ali Yusuf) said, “Circle and Fuze share a common vision to create more efficient financial services and deliver digital assets infrastructure that builds a more connected, inclusive economy. We look forward to fostering a close working relationship with the Circle team and are excited about developing the future of finance together.”

Fuze, which was co-founded by Mo Ali Yusuf (CEO), Arpit Mehta (COO) and Srijan Shetty (CTO), has made rapid strides towards building digital assets infrastructure across the region. This includes securing robust regulation and licensing and receiving the largest seed funding round for a digital assets start-up in MENA history. Fuze continues to accelerate its product implementation and growth, in close collaboration with local and regional regulators.

A week prior Fuze signed an MOU with UAE Al Fardan exchange to offer digital asset services to their clients.

UAE based Finschia Foundation, an independent non-profit organization, based in Abu Dhabi, UAE, established in March 2023 to expand public blockchain and Web3 technologies, and NEOPIN, DeFi multichain platform have partnered to provide decentralized exchange services.

Finschia and NEOPIN will collaborate to develop the Finschia Network Swap (hereinafter referred to as FNSwap). NEOPIN is currently developing FNSwap, which will be the first Automated Market Maker (AMM) Decentralized Exchange in the Finschia ecosystem.

NEOPIN has been building blockchain expertise and technology since 2017, participating as a node validator for various global blockchains, including Ethereum, Tron, Cardano, and Cosmos. In 2022, the company launched the CeDeFi protocol NEOPIN to provide a secure and convenient environment for using the DeFi protocol.

This year, the company was selected as an innovation program company by the Abu Dhabi Investment Office (ADIO) in the UAE to attract direct and indirect investment, and is working with the Abu Dhabi Global Market (ADGM), a special financial zone in the UAE, to create the world’s first DeFi regulation as a public-private partnership.

As per the news, FNSwap is envisioned as a community-first, community-owned centered and fair platform, offering various range of DeFi products and incentives. These include token swapping, earning fees and rewards by depositing tokens into through token deposits in pools, gaining incentives incentive acquisition through token staking, and token transfers with EVM-based chains via bridge.

FNSwap is set to launch in the near future, providing users with a stable and convenient platform to access DEX services within the Finschia ecosystem.  Later it will be expanded by creating an environment where various Finschia dApp services can easily list tokens and users can trade conveniently.

According to the news, the Foundation will continuously provide necessary technical support and integration for the development of a diverse array of ‘money legos’, starting with supporting the basic token swap services. This support aims to facilitate the onboarding of DeFi services, propelling the platform towards becoming the №1 DeFi platform in Asia.

The Saudi Islamic Development Bank Institute (IsDBI) is working to patent a Blockchain system for smart stabilization for CBDCs and digital assets after receiving a positive evaluation for its Blockchain smart stabilization system patent. The World Intellectual Property Organization (WIPO) is looking into the patentability of the system.

WIPO has acknowledged the Stabilization System as a novel, inventive, and industrially applicable solution. WIPO also noted its significant potential for international patent recognition.

The Blockchain smart stabilization system will work to enhance the stability of organized asset markets without compromising efficiency. The system will effectively manage the gap between supply and demand to mitigate price volatility while upholding the market-equilibrating role of this gap.

As such Dr. Sami Al-Suwailem, Acting Director General of IsDBI, expressed his appreciation towards the team’s dedication and hard work, stating, “This recognition from WIPO not only validates our commitment to innovation but also positions IsDBI at the forefront of bolstering the financial stability of the digital and crypto-based economy.”

The Blockchain system for smart stabalization will be utilized in financial assets, digital currencies ad CBDCs using Blockchain technology.

The Blockchain system is self-financed, with no need for substantial capital to achieve its objectives. A prototype is under way after IsDBI signed an agreement with Settlemint. Saudi IsDBI bank started working on this project with Blockchain solution provider Settlemint in May 2023.

UAE Fuze, digital assets infrastructure provider, which recently received a license from Dubai’s regulator, has signed an MOU with UAE Fardan Exchange to allow the exchange to offer digital asset products such as buying, selling and transfer

The MOU was signed by both Hassan Al Fardan, CEO of Al Fardan Exchange and Ali Mo Yusuf, the Founder and CEO of Fuze Finance.

The decision to delve into the digital assets domain comes as more clients request digital finance solutions allowing them to buy, sell and transfer digital assets in an easy, safe and use friendly way.

According to Hassan Al Fardan, CEO of Al Fardan Exchange, “ We are committed to innovation as digital transformation becomes more embedded and through this cooperation with Fuze Finance we look forward to offering innovative fintech solutions continuing to offer financial services that are secure, easy, and in line with the future.”

Mo Ali Yusuf, Co-Founder and CEO of Fuze added, “Exchange services are central to the financial sector in the UAE, and Fardan has longstanding history in this field, surpassing 50 years. Al Fardan offers its services to millions of citizens and residents in the UAE and we are proud to be able to develop digital asset solutions for the clients of AL Fardan.”

Prior to this, Fuze partnered with Abu Dhabi headquartered Wio Bank to empower its customers with virtual assets trading services.

LaraontheBlock interviewed the CEO of recently UAE licensed crypto exchange M2, Stefan Kimmel who had a lot to say on the future plans of M2, their product growth, partnerships, acquisition appetite, Bitcoin ETFs and license plans.

Why Abu Dhabi

According to Kimmel, launching a fully regulated, transparent clean startup from Abu Dhabi ADGM ( Abu Dhabi Global Market) was because the FSRA ( Financial Services and Regulatory Authority) in ADGM is one of the oldest most respected and esteemed regulatory authorities when it comes to virtual assets and crypto. FSRA as Kimmel explains has been around for five years and has a comprehensive solid framework. He stated, “ After all that has happened in crypto over the past few years, everyone is looking for a safe protected transparent exchange, and this is what we are offering from ADGM.”

M2 Strong liquidity

Another strong feature that M2 has is its strong liquidity which is essential for the success of any crypto exchange. As Kimmel explains, “ Liquidity is super important for successful crypto exchanges, and this is why we have partnered with global leading market makers, have tight spreads, and in terms of depth of key markets we are right up there with all the top players. Liquidity is key for good trading experience for investors and that is why we are connected with the largest global market makers and have deep liquidity especially on large crypto asset pairs.”

M2 investors

Speaking on M2 investors and whether the company will be seeking further investment, Kimmel replies that M2 is not seeking to raise capital any time soon. According to Kimmel, M2 is lucky to have an equity investment of $300 million which will give them a long run rate. According to Kimmel, “Our strategic key investor is Phoenix Group but we also have investment from several Abu Dhabi family offices.”

However for those who have asked or been interested in investing in M2, Kimmel states they have the option of investing in Phoenix Group which is now trading publicly on the ADX exchange in Abu Dhabi or they can buy the M2 MMX token on the M2 exchange and Uniswap.”

Noteworthy is that while Phoenix Group is a strategic investor in M2 it also partners with M2 on Bitcoin mining and Hashrate mining.

Acquisition appetite

As for M2’s acquisition appetite, Kimmel admits that if they find well regulated transparent crypto exchanges in countries of interest they would seek to acquire them. On whether M2 would be interested in Binance, he replies, “First Binance is not up for sale, and secondly we are on the lookout for fully regulated exchanges, as we want to be regulated, transparent and clean in everything we do. So we would have to choose an exchange that is in the same direction.”

The U.S. market

At the moment M2 is not interested in the U.S. market given the unclear regulatory situation. Kimmel states, “We will be staying outside of the USA unfortunately, given its current regulatory state. There are no rules we can apply or abide by currently in the USA only enforcement.”

However M2 is very keen on Europe given that Europe has come out with its MICA regulations for crypto service providers. He states, “Our next intention after receiving several regulatory licenses from ADGM and a license from the Bahamas is to acquire a license in Europe and we have filed for one in Spain.”

After Spain, M2 plans to apply for a license in the United Kingdom.

Bitcoin Earn Yield Product

The first product launched by M2 was Bitcoin Earn product. The product was launched in partnership with Phoenix crypto mining group and offers yields that reach up to 10.5%.

The pair designed a product that utilizes Bitcoin mining to offer genuine returns for investors. Most investment platforms that offer yield returns on crypto provide it through one of two routes. M2 are generating returns predominantly with Bitcoin mining, which underpins the M2 Earn product

Kimmel admits that the appetite for the M2 Bitcoin Earn product has been fantastic. He states, “This has been one of the most debated topics inside the M2 because a large share of deposits goes to the Bitcoin Earn product. 10.5% is amazing given that it is hard to earn decent returns on Bitcoin.”

According to Kimmel it is not that difficult to offer 10.5% returns because as he notes, “Given that we are partially owned by Phoenix Group, we reinvest in Bitcoin mining which offers higher returns than 10%, the other two angles is on platform lending which is over collateralized and fully on platform, and a small percentage goes into Proprietary Trading (Prop Trading) market making and basic arbitrage, but no big exposures, as we are not trying to take on risks.”

According to Kimmel even if the crypto markets are not doing well since the investment is in Bitcoin and the interest return is in Bitcoin, then there is no FX market exposure.

Future product offerings partnerships

Kimmel is excited about the future of M2 after going live and ensuring that the processes in place are scalable and robust. Next up are more product offerings, partnerships, and maybe an ETF.

Kimmel explained, “In Q1 of 2024 we will be coming out with a crypto payment card. We will also be offering fiat on and off ramp with one of the banks in the UAE. In addition we have partnerships coming up with big retail names in the country to reach a bigger customer base.”

When asked about the potential of a Bitcoin ETF product, Kimmel confesses that this is absolutely on the radar. He says, “We are already having initial exploratory discussions on it.”

Outlook on crypto exchanges and DeFi

In terms of the bigger global situation when it comes to crypto exchanges, competition and DeFi, Kimmel believes that given that today there are around 600 crypto exchanges globally, we will definitely see some closing down because of the regulatory requirements, others being bought because the market cannot accommodate so many crypto exchanges. He explains, “ We will not only see consolidations in the UAE as crypto exchanges struggle to meet tighter regulatory environment, but there will also be eliminations as market gravitate towards the stronger players.”

In terms of centralized crypto exchanges versus decentralized using DeFi, Kimmel believes that for mass adoption to take place, centralized exchanges are a must. Kimmel, “As we drive for mass adoption the vast majority will struggle with decentralized user experiences, such as managing wallets, on and off ramp, which is hard, in addition we also have governments and regulators who struggle in DeFi, where it is anonymous and users as well may not subscribe to that ethos. For institutional adoption this can only happen in centralized platforms.”