FCA Bans Three Dolfin Financial Executives for Investor Visa Scheme

The Financial Conduct Authority (FCA) has permanently banned three former senior executives of Dolfin Financial (UK) Limited after determining they operated a scheme to circumvent UK investor visa rules. The scheme, active between 2016 and 2019, enabled at least 99 individuals to acquire visas by paying fees significantly below Home Office investment requirements. Denisz Nagy and Sanjay Maraj also received substantial fines and prohibitions, while Roman Joukovski has been served a prohibition order.

FCA details £35.5m investor visa bypass scheme

The FCA found that the Dolfin Financial visa scheme allowed clients to obtain UK investor visas by paying a fee of £400,000—rather than investing the mandated £2 million in UK companies, as set out in the Home Office Tier 1 investor visa requirements. This mechanism was deliberately structured to create a false impression that clients met legal thresholds, enabling at least 99 individuals to secure visas through the scheme. Across these transactions, the operation generated a minimum of £35.5 million in fees for Dolfin-linked entities and the immigration agents who introduced clients.

Focus on FCA prohibition and financial penalties

The FCA has imposed the following enforcement actions:

• Denisz Nagy, former chief executive, fined £324,800 and permanently banned from any regulated financial function; his penalty reflects a 30% settlement discount.
• Sanjay Maraj, former finance director, fined £122,000 and permanently banned from regulated activities, also with a 30% settlement discount.
• Roman Joukovski, co-founder, issued a Decision Notice imposing a prohibition order; he is challenging this decision before the Upper Tribunal.

According to the FCA, Mr Nagy and Mr Joukovski were instrumental in devising and running the investor visa scheme, while Mr Maraj oversaw the financial operations after its establishment. Both Mr Nagy and Mr Maraj deliberately concealed the scheme's true nature from the FCA and the Home Office, and Mr Joukovski hid both his association with Dolfin and role in the scheme. The FCA further established that Mr Joukovski acted as a shadow director without FCA approval and exercised control of the firm without regulator notification.

Dolfin Financial’s regulatory status and broader impact

In March 2021, the FCA prohibited Dolfin Financial (UK) Limited from carrying on any regulated activity due to a range of serious regulatory concerns, including those related to the visa funding scheme. Dolfin entered special administration in June 2021; insolvency proceedings continue. The FCA’s enforcement decisions reflect its commitment to maintaining integrity in UK financial markets, as reinforced by Therese Chambers, the FCA’s joint executive director of enforcement and market oversight:

"Integrity is not optional in financial services. These individuals ran a scheme designed to get around the UK's investor visa rules, undermining their purpose of attracting genuine investment into the UK. They then sought to hide how it operated. We will continue to act against those who lack integrity and undermine trust in UK financial services." — Therese Chambers, FCA

The regulator found all three former executives lacked the integrity and fitness required for work in financial services.

Home Office investor visa context and enforcement actions

The Home Office’s Tier 1 investor visa route, the framework these actions relate to, was closed from 17 February 2022. The Home Office has since refused visa applications or extensions for numerous clients who benefited from the Dolfin scheme. Many affected applications for leave to remain and indefinite leave to remain in the UK were declined on this basis.

The FCA’s action in this case follows broader concerns about investor visa abuses and recent regulatory scrutiny over marketing and delivery of financial products to international clients, reinforcing the UK’s market expectations for compliance and transparency.

Concluding points on FCA integrity enforcement

This enforcement action against Dolfin Financial’s executives signals the FCA’s stance on schemes that undermine regulatory frameworks, especially those concerning cross-border capital movement and immigration. The matter remains under review for Mr Joukovski, who has referred his prohibition to the Upper Tribunal. Dolfin’s insolvency and the Home Office enforcement actions against its clients illustrate the breadth of official response to breaches of investor visa requirements and financial services regulation.