Compliance Radar

Who was sanctioned, and for what?

Fines, court rulings and incidents from Europe, North America, Latin America, Asia-Pacific and Middle East: 1,929 cases from 40 jurisdictions, each with an official source and checked against that source before publication. Filter by country, area of law and sector. Click a chart to drill down one level.

1case from 1 jurisdiction
€3.24mTotal of monetary amounts
€3.24mMedian per case with an amount

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When?

per quarter, by date of decision
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PeriodCasesTotal
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Q1 20240–
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Q2 20251€3.24m
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1 case

3 Apr 2025 AC Holding Limited (Cayman Islands, Hayvn-Muttergesellschaft)ADGM: 3.6m USD fine for Hayvn parent over payments routed through unregulated accounts United Arab EmiratesCapital markets and financial supervision €3.24m

The FSRA (Financial Services Regulatory Authority, the financial regulator of Abu Dhabi Global Market, ADGM) fined the Cayman Islands parent company of the Hayvn group 3,600,000 USD for being knowingly concerned in unauthorised regulated activities of an unregulated ADGM special purpose vehicle and in breaches of permission by its ADGM subsidiary. Around 3,023 transactions for 241 group clients ran through the bank accounts of that vehicle, with deposits of about 507 million USD and payments of about 558 million USD, although the vehicle held no permission and was not subject to the ADGM anti-money laundering rules. The regulator increased the fine by 20%, partly because the parent did not fully disclose its use of the accounts to the regulator and withheld half of the fees owed to the appointed skilled persons.

What organisations can take from it

A parent company is also liable when it knowingly routes client business through unregulated entities in a financial centre.

Relevance to training and awareness

Licensing within a group: no processing through unregulated entities

Authority / court
Financial Services Regulatory Authority (ADGM)
Area of law
Capital markets and financial supervision
Legal basis
Sections 16, 17 und 20 i. V. m. Section 220 sowie Section 232 FSMR 2015
Action
Fine
Status of proceedings
final
Sector
Financial services and insurance
Mitigating circumstances
Cooperation by the parent company and its audit and risk committee from mid-December 2023; the aggravating factors outweighed this.
Liability of senior managers
According to the Final Notice, the use of the accounts was not approved by the board but directed by the then CEO. Measures against individuals are not set out here.

Original amount 3,600,000 USD, converted at the ECB reference rate of 3 Apr 2025.

Checked against the official source on 3 Oct 2026 · Direct link

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