Hi ,

Switched up the format today. With the Hayvn enforcement news out of Abu Dhabi, I’ve picked out the three FCC slides I would want to see if I was EMEA/Middle East head.

Hope it’s useful, feel free to use or share.

See you next Wed, enjoy the long weekend.

Paul

🇦🇪 Abu Dhabi | ADGM’s FSRA

The Abu Dhabi financial regulatory authority (FSRA) issued their largest ever financial crime related fine yesterday - $12.45m for the VASP Hayvn (including all its related entities and CEO).

I’ve scoured the Abu Dhabi Enforcement Actions page to find all their issued AML Fines (from start, ie 2022, to now).

Essentially the Havyn AML fine has blown everything out of the water (see below).

However, at the same time there has been an increasing oversight from the FSRA since its first fine in August 2022 for Wise (see in what areas in slide 2).

Why it matters: If you’re operating in Abu Dhabi or have growth plans in the area are you clear on the goAML registration reqs? Is your Head of EMEA/CEO aware of the personal liability they may face (as Hayvn’s CEO has just found out)?

In slide 3 I’ve set out my key learnings, would sum up with the three bullets your EMEA head defo needs to know:

• Your corporate structure doesn’t preclude Abu Dhabi AML liability

• Tone from the top really matters - need to promote a compliant culture

• If the FSRA warns you about something - listen and change your approach

Have a great long weekend.

Paul