FCA bans three Dolfin Financial figures behind £35.5m investor visa scheme

Action required: No. Worth reviewing if you run a wealth management or custody business or take referrals from immigration intermediaries.

The FCA has banned three former senior figures at Dolfin Financial (UK) Limited and fined two of them a combined £446,800 for running a scheme between 2016 and 2019 that helped at least 99 clients bypass UK investor visa requirements. Former chief executive Denisz Nagy has been fined £324,800 and former finance director Sanjay Maraj £122,000; both have been banned from working in financial services. Both settled with the FCA, each receiving a 30% discount on their penalties; without the discount, Nagy's fine would have been £464,000 and Maraj's £174,300. Co-founder Roman Joukovski has been banned but has referred his Decision Notice to the Upper Tribunal, so the findings against him remain provisional and the prohibition has no effect pending the Tribunal's determination.

The mechanics were straightforward. Under the Home Office's Tier 1 investor visa rules, applicants were required to invest £2m of their own money in UK companies. Instead, most clients using the Dolfin scheme paid a £400,000 fee. The arrangement was designed to create the false impression that the visa requirements had been met, generating at least £35.5m in fees for Dolfin-connected businesses and the immigration agents who introduced clients.

The FCA found that Nagy and Joukovski played leading roles in creating and operating the scheme, while Maraj handled the financial aspects once it was running. Nagy and Maraj also deliberately concealed the scheme's true nature from both the FCA and the Home Office. Joukovski's position is more layered: the FCA found he deliberately concealed his involvement with Dolfin from the regulator, acted as a shadow director of Dolfin, meaning someone who directs a firm's affairs without holding a formal board position, without FCA approval, and was a controller of the firm without notifying the regulator.

On 12 March 2021, the FCA imposed restrictions on Dolfin to prevent it from carrying on regulated activities. The firm entered special administration in June 2021, and insolvency processes remain ongoing. The Home Office closed the Tier 1 investor visa route from 17 February 2022 and has since refused applications for leave to remain and indefinite leave to remain from many of the clients who used the scheme.

Therese Chambers, joint executive director of enforcement and market oversight, said: "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."

This is not a routine fine for weak controls. The conduct here was deliberate: a structured arrangement to deceive a government immigration programme, with active concealment from the regulator. For wealth managers and custodians, the practical prompt is to examine fee structures on mandates involving immigration intermediaries and to consider whether the underlying purpose of a client arrangement is what it appears to be.

Sources

• FCA bans trio bypass visa rulesfca.org.uk