FCA Bans Two Over £35.5m Dolfin Visa Scheme, Third…
The UK Financial Conduct Authority has banned and fined two former Dolfin Financial executives after finding that a funding scheme helped at least 99 people obtain investor visas without putting £2 million of their own money into UK companies. The regulator’s enforcement announcement also sets out a proposed ban against Dolfin co-founder Roman Joukovski, although that action is suspended while he challenges the decision before the Upper Tribunal.
Former chief executive Denisz Nagy was fined £324,800 and former finance director Sanjay Maraj was fined £122,000. Final Notices dated 25 August prohibit both men from performing any function connected with regulated activities. The FCA concluded that they lacked integrity and were not fit and proper to work in financial services.
The scheme operated between 2016 and 2019 and generated at least £35.5 million in estimated gross fee revenue. That figure is neither an estimate of investor losses nor an amount the FCA says Dolfin itself retained. The individual notices estimate that £10.3 million was paid to immigration agents as commission and that £25.2 million remained as net profit distributed among connected people and companies.
How £400,000 Created the Appearance of a £2 Million Investment
The Home Office’s Tier 1 Investor route required applicants to invest at least £2 million of their own money in qualifying UK assets and maintain the investment during their leave. The assets had to remain under the applicant’s control, and management or transaction fees could not be deducted from the required investment.
Dolfin’s arrangement replaced that economic requirement with a series of pre-arranged transactions. According to the FCA’s Final Notice against Nagy, the most common version was called “Gold.” A client generally paid £400,000, while Dolfin-connected companies supplied funding to purchase securities with a nominal value of £2 million. The securities were issued by companies in which Dolfin or its directors had interests, were held for five years, and were then used by Dolfin to certify that the visa investment requirement had been met.
The FCA described the structure as artificial and said its linked transactions had no genuine commercial rationale when viewed as a whole. The arrangement gave the appearance that the applicant had made and controlled the qualifying investment even though the funding came from connected companies. Immigration agents introduced prospective clients and received commissions from the fees.
Where the £35.5 Million Went
The enforcement notices do not identify complete contemporaneous accounts for the scheme. The FCA therefore reconstructed the economics from available information and arrived at a minimum of £35.5 million in gross fee revenue received by Dolfin-connected companies. It estimates that introducing immigration agents received £10.3 million and that the remaining £25.2 million in profit was dispersed among connected individuals and corporate entities.
The regulator found that Nagy was central to the design, implementation and oversight of the business. He was Dolfin’s chief executive, a director and, for part of the period, its money laundering reporting officer. The FCA said he continued with the scheme despite internal concerns about legality, including concerns that culminated in three employees resigning.
Maraj was not found to have designed the arrangement. His Final Notice says he managed its financial operation after it was established, supervised payments and helped make representations indicating that clients had met the Immigration Rules. The FCA accepted that he benefited to a lesser extent than other connected individuals. Regulatory candour has also driven other individual cases, including the FCA’s £1 million penalty against H2O’s former deputy chief executive for misleading the regulator.
Two Final Bans and One Contested Decision
Nagy and Maraj settled their cases and each received a 30% reduction under the FCA’s settlement procedure. Nagy would otherwise have been fined £464,000, while Maraj’s penalty would have been £174,300. Their prohibition orders took effect with the Final Notices.
Joukovski’s position is legally different. The FCA has decided to prohibit him from financial services, but his Decision Notice has been referred to the Upper Tribunal. Its findings are provisional, the proposed ban has no effect during the reference, and the Tribunal may dismiss the challenge or return the matter to the FCA for reconsideration.
The FCA alleges that Joukovski co-founded and co-owned Dolfin, acted as a controller and shadow director without the required notification or approval, and was one of the main organisers of the visa funding scheme. It also alleges that companies he controlled were the scheme’s principal financial beneficiaries. Those allegations should not be presented as final findings unless and until the Tribunal resolves the case. FinanceFeeds has applied the same distinction in other contested cases, including the FCA’s proposed bans against two former insurance executives. A Decision Notice records the regulator’s case, while a Final Notice or Tribunal judgment determines the operative outcome.
The FCA First Restricted Dolfin in 2021
The enforcement action follows a regulatory process that began years earlier. The FCA identified concerns during supervisory work from July to November 2019, initially focusing on conflicts created when Dolfin distributed bonds issued by connected companies to investor visa clients. Voluntary restrictions imposed in December 2019 stopped Dolfin from accepting most new Tier 1 clients and distributing conflicted securities.
On 12 March 2021, the FCA stopped Dolfin from conducting virtually all regulated activity, citing the visa business, conflicts and financial crime controls. A new management team concluded that the firm could no longer trade, and special administrators were appointed on 30 June 2021. The insolvency process remains open.
The five-year interval between Dolfin’s closure and the individual outcomes shows how long document-heavy enforcement can take. The FCA has separately promised faster enforcement, but older cases continue to reach resolution. A recent settlement involving the former chief executive of SVS Securities similarly closed one branch of an investigation years after that firm entered special administration.
The Visa Route Closed, but Existing Cases Continued
The Home Office closed the Tier 1 Investor route to new applicants on 17 February 2022. The government said the route had produced limited economic benefit and had been vulnerable to illicit wealth and complex investment schemes designed to circumvent genuine investment requirements.
Closure did not end the consequences for people who had already used the route. The FCA notices say the Home Office refused applications for leave to remain and indefinite leave to remain from many clients connected with Dolfin’s scheme. Existing Tier 1 cases can continue through later immigration stages, which is why the Home Office response remained relevant after new applications stopped.
Therese Chambers, joint executive director of enforcement and market oversight at the FCA, said integrity was not optional in financial services and that the scheme had undermined the purpose of attracting genuine investment into the UK. The regulator has tied the case to concealment as well as product design: it found that Nagy and Maraj misled the FCA and government bodies, while its corresponding allegations against Joukovski remain for the Upper Tribunal to determine. The case sits within a broader enforcement push that produced 17 criminal convictions in the first year of the FCA’s current strategy, but the Dolfin outcome is regulatory rather than a criminal conviction.