The Hayvn digital asset saga ends with $8.85 million in fines

The Hayvn digital asset saga ends with $8.85 million in fines

The saga that has engrossed UAE based HAYVN, a digital asset focused financial institution, providing trading, asset Management, custody, and payments previously regulated in ADGM UAE, has ended after more than a year with fines of over $8 million.

The saga which started in December 2023, when Hayvn 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), insinuated that the CEO had carried out a huge misconduct, has come to a conclusion with the The Financial Services Regulatory Authority (“FSRA”) regulatory arm of ADGM taking enforcement action following an investigation into serious regulatory breaches and misconduct related to the Hayvn Group of Companies, which operated under the name ‘HAYVN’, its former CEO, Christopher Flinos and related entities. 

In February 2024, Deus X Capital, a $1 billion family office agreed to buy out HAYVN and appointed Richard Crook as new CEO. Deus X Capital purchased the business brand, technology, clients and staff from other HAYVN shareholders.

Today, and as per ADGM FSRA press release, the FSRA’s investigation found serious breaches and misconduct concerning the operations of three related party companies and Christopher Flinos.  As part of its investigation, the FSRA took steps to ensure that no ADGM client assets or money were lost as a result of the relevant misconduct.  

The enforcement action has resulted in the cancellation of Hayvn ADGM’s Financial Services Permission (“FSP”), the prohibition of Christopher Flinos indefinitely from performing any function in a financial services business in ADGM, as well as financial penalties totalling $8.85 million being imposed across the four parties involved.  Details of the total fines imposed are as follows:

  • USD 3.6 million against AC Holding Limited registered in the Cayman Islands (“Hayvn Cayman”), the parent company of a group of entities operating under the name ‘HAYVN’ that provided financial services related to Virtual Assets.
  • USD 3 million against AC Limited (Hayvn) (“Hayvn ADGM”), an ADGM-based subsidiary of Hayvn Cayman, licensed and regulated by the FSRA 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 (“SPV”) registered with the Registration Authority (“RA”) of ADGM and not licensed by the FSRA to carry out any form of financial services activity in ADGM; unconnected to Hayvn Cayman and Hayvn ADGM.
  • USD 750,000 against Christopher Flinos, the former Senior Executive Officer (“SEO”) of Hayvn ADGM, Chief Executive Officer (“CEO”) of Hayvn Cayman, sole owner and director of AC Holding.

The misconduct and breaches were related to Hayvn ADGM exceeding the scope of its FSP by allowing client transactions to be routed through accounts held by AC Holding, the unregulated SPV entity registered in ADGM, without any appropriate protections being in place.  It failed to establish and maintain adequate systems and controls to manage its operations and risks, as well as to recognize and record all of its client relationships, breaching the FSRA’s Anti-Money Laundering (“AML”) requirements.

The company Hayvn Cayman and AC Holding also 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 arranging services in relation to Virtual Asset activities in ADGM.

 Christopher Flinos played 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 was found to have been centrally involved in the breaches and misconduct. 

The report notes that 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.

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.

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. 

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 of ADGM acknowledges and thanks ADGM’s Registration Authority and the Cayman Islands Monetary Authority (“CIMA”) for their cooperation during its investigation in relation to this matter.

Dubai Virtual asset regulator, VARA fines seven UAE VASPs

Dubai Virtual asset regulator, VARA fines seven UAE VASPs

The Virtual Assets Regulatory Authority (VARA) as part of its enforcement program has fined as well as issued cease and desist orders 7 VASP entities for operating without a license and for breaching marketing regulations. The fines reach up to $27,000 depending on severity of violation.

VARA has asked the public to avoid engaging with unlicensed VASP firms because this exposes them to significant financial and reputational risk.

The VARA message, clearly stated, “Only firms licensed by VARA are authorized to provide virtual asset services in/from Dubai, and the Authority remains steadfast in its commitment to protect consumers and investors, and to preserve market integrity. ”

The Regulatory Affairs and Enforcement at VARA also noted, “Our priority is to ensure that Dubai’s virtual assets ecosystem remains secure for consumers and investors while being a progressive environment for compliant entities. Market enforcement actions send a reinforcing message: VARA will not tolerate any attempts to operate without appropriate licenses, nor will we allow unauthorized marketing of virtual asset activities. Our marketing regulations further emphasize Dubai’s commitment to ensuring transparency and always protecting stakeholder interests.” 

The 7 un-named VASP has been asked to cease their activities and stop marketing or advertising their virtual asset services.


Fines issued in this round range from AED 50,000 ($13,000) to AED 100,000 ($27,000) per entity, depending on the nature and severity of the specific instance of such violation.

Few weeks prior the regulator published its marketing regulations which covers not only Dubai but the entire UAE and GCC region.

As Binance blocks thousands of crypto transactions in UAE, it faces fines of $4.38 million in Canada

As Binance blocks thousands of crypto transactions in UAE, it faces fines of $4.38 million in Canada

Binance is and has blocked tens of thousands of suspicious cryptocurrency transactions in the UAE with many brokers and exchanges using Binance because of its significant liquidity pool, yet the crypto exchange is still facing regulatory scrutiny with Canada’s regulator recently fining Binance for non-compliance with the laws related to money laundering and terrorist financing.

This comes as Meera Judge, the Dubai-based director of regulatory licensing and policy at Binance speaking to Lara on the Block noted that while Binance is doing all it can to ensure utmost compliance, when it comes to exchanges working with Binance is up to them to ensure their own compliance.

By the end of February Binance had registered 178 million registered users, with $3 billion in net inflows between November 2023 and February 2024.

Lara on the Block asked Judge these questions after an interview with her appeared in AGBI magazine where she unveiled that Binance has blocked tens of thousands of suspicious crypto transaction in the UAE.

Judge told Lara on the Block, “Binance continues to go above and beyond industry standards to detect bad actors through proactive measures and collaboration with private and public entities. Binance takes any use of its platform to facilitate “illicit” activity very seriously. It has invested substantial resources in talent and tools to reduce this exposure even further, making Binance an industry leader in this respect.”

She adds, “We have worked hard to build a robust compliance program that incorporates anti-money laundering principles and tools used by financial institutions to detect and address suspicious activity. We proactively block users from sanctioned regions and do this through KYC and a variety of KYC/AML tools and vendors including, but not limited to, Jumio, Onfido, WorldCheck, Elliptic, and CipherTrace.

As Judge explains, their due diligence process includes screening users against extensive database via Refinitiv World-Check that contains major sanctions and terrorism lists. She adds, “This is done on an ongoing basis to ensure that we keep bad actors out of our platform.”

Binance is utilizing a team of 500 compliance officials worldwide, with 100 of them dedicated to transaction monitoring.

Judge believes that Binance’s operational stability is critical to the stability of the broader market, stating that Binance is the largest exchange in the world and is considered a systemically important financial infrastructure.

This however according to Judge doesn’t mean that Binance is responsible for the compliance of other crypto exchanges. She tells Lara on the Block, “Binance’s liquidity pool is significant, so many other broker-dealers and exchanges tend to use us, which is why we face additional scrutiny. Given that Binance’s liquidity pool is significant it is used by other broker-dealers and exchanges however it’s up to them to ensure their own compliance. Binance goes above and beyond industry standards, and we encourage others in the industry to endeavor to do the same.”

Binance has over the past years increased its efforts towards compliance especially as it works to gain regulatory status in several countries. It recently was awarded a regulatory license in the UAE. Earlier this year, Binance noted that it increased year-over-year spending on compliance from $158 million to $213 million, purchasing a raft of new software systems to block and report suspicious transactions. Binance also decided to bring back executive Steve Christie as its deputy chief compliance officer.

Despite all this, On Thursday May 9th 2024, Canada’s financial crime watchdog levied a fine equivalent to $4.38 million against Binance for compliance failings. The Financial Transactions and Reports Analysis Centre of Canada imposed an administrative penalty on Binance for non-compliance with the laws related to money laundering and terrorist financing.

The regulator, known as Fintrac, found administrative violations including a failure to register as a foreign money-services business and allegedly failing to report large virtual currency transactions of C$10,000 or more in the course of a single transaction, along with the prescribed information.

In 2023, Binance pleaded guilty to violating U.S. anti-money-laundering requirements and agreed to pay a $4.3 billion fine. The exchange also faces civil charges in a SEC lawsuit.

So while Binance has been trying to do so much to increase its compliance, and while Binance now holds a regulated license in the UAE blocking hundreds of thousands of suspicious crypto transactions, and as it announces its registration with the Indian Financial Intelligence Unit after the region banned the platform and over nine others in December 2023, it is still facing the heat in other countries across the globe.

Updated on May 13th 2024 with feedback from Binance

Eighteen Dubai based virtual asset providers fined by Dubai’s regulator

Eighteen Dubai based virtual asset providers fined by Dubai’s regulator

In a market notice issued November 17th 2023, the Dubai Virtual Assets Regulatory Authority (VARA), confirmed that the deadline for VA sector to engage in the regulatory license elapsed today and that eighteen virtual asset service providers commercially licensed on mainland under Dubai’s Department of Economy and Tourism (DET) have thus far, been issued fines for failing to comply with VARA’s directives and regulatory guidance.

A VARA spokesperson declined to name the eighteen entities in question.

As per the notice, in line with VARA’s commitment to protect consumers, maintain market integrity, and manage security of the Virtual Economy being enabled in and from Dubai, these enforcement actions are a pre-requisite to remedy compliance breaches and assure global markets that VARA’s regime can be trusted to have consistency and resilience in deployment.

The Dubai virtual asset regulator stated that this would be an ongoing process, with additional fines, enforcement actions, and closure of unlicensed VASPs expected. VASPs have until year end to address any regulatory gaps.

Entities seeking to continue to offer virtual asset services in Dubai are urged to contact VARA immediately to avoid further penalties. Consumers are advised to check the VARA website for advice on approved VASPs in Dubai. For further information, please contact VARA via our website or via

This comes a day after CEO Henson Orser stepped down, and 10 days after VARA issued a notice asking all VASPs to finalize their license registrations and requirements.

But there have also been positive news in the VASP licensing arena, with entities such as Fuze Finance receiving a license as well as HexTrust and BackBack in the past 10 days.

OPNX token exchange fails to pay fines of over $2 million to Dubai’s virtual asset regulator

OPNX token exchange fails to pay fines of over $2 million to Dubai’s virtual asset regulator

Further to Virtual Assets Regulatory Authority’s (VARA) previous notices dated 12 April 2023 and 27 April 2023 regarding the conduct of Open Technology Markets Ltd. known as OPNX and opnx.com, VARA has issued the following fines against OPNX including a $2,722,548 equivalent to AED 10,000,000 against OPNX for a Market Offence under Regulation VIII.A.3 of the Virtual Assets and Related Activities Regulations 2023 (Regulations)

As per VARA, this fine was issued on 2 May 2023 and remains unpaid at the time of publication of this notice. 

The VARA notice includes  $54,000 equivalent to AED 200,000 against each of the following 4 persons: OPNX founders Kyle Davies, Su Zhu and Mark Lamb and OPNX CEO Leslie Lamb.

The fines are for violations of Administrative Order No. 01/22 Relating to Regulation of Marketing, Advertising and Promotions Related to Virtual Assets, The fines were issued on 2 May 2023 and have been fully paid by the individuals in question.

All fines noted above were referred to VARA’s Grievance Committee [the Committee formed in accordance with Article 22 of Law No. (4) of 2022 Regulating Virtual Assets in the Emirate of Dubai] in accordance with due governance requirements. The Committee reviewed the referral of the grievance and determined that the enforcement actions taken be upheld in their entirety.

To date, the AED 10MM fine issued against Open Technology Markets Ltd remains unpaid, and VARA shall determine consequential actions warranted against OPNX, which may include further fines, penalties, and/or taking any actions necessary to recover payment in addition to possibly referring the matter to any law enforcement agency(ies) or competent courts.

Central Bank of Egypt to fine crypto violators $516,000

Central Bank of Egypt to fine crypto violators $516,000

The central bank of Egypt has once again reiterated its warning against dealing in any types of cryptocurrencies, saying that crypto is risky, highly volatile, and is used in financial crimes and e-piracy.

In the Egypt independent article, the Central Bank of Egypt will fine anyone who violates the Law No 194 of 2020 which prohibits issuing, trading, promoting cryptocurrencies, operating crypto exchanges or any other related activities. The Central Bank will fine violators up to $516,000 ( 10 million LE) or face imprisonment.

The CBE statement reads, “Whoever violates this shall be imprisoned, and fined no less than one million pounds and no more than LE10 million ($516,340), or one of these two penalties.”

The Egyptian central bank issued a similar warning about cryptocurrencies in January 2018, specifically naming Bitcoin. At that time the Central Bank had noted, “Cryptocurrencies are not backed by any tangible assets and are not supervised by any regulators worldwide, and consequently, they lack the official governmental guarantee and support enjoyed by the other official currencies issued by central banks.”

Yet Egypt has one of the highest crypto usages across Africa and Middle East. In January 2022, TripleA published a report which noted that Morocco topped the Arab countries in terms of crypto ownership, followed by Egypt, then UAE and KSA.

The report stated that in 2021 global crypto ownership was estimated at an average of 3.9 percent, 300 million crypto users and 18,000 businesses already accepting crypto payments.

In addition as per the report there are 32 million crypto users in Africa, 160 million in Asia, 38 million in Europe, and 28 million in North America, while Latin America has 24 million users.

Morocco was reported as having 878,168 crypto owners which was 2.38 percent of the population. It was followed by Egypt which had 1, 791,185 million crypto owners at 1.75 percent of the population.