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Yesterday, the Financial Conduct Authority announced that it has banned three former senior figures at Dolfin Financial (UK) Limited, and fined two of them, after finding that they ran a scheme that helped clients bypass UK visa rules.

Former chief executive Denisz Nagy has been fined £324,800 ($442,970) and former finance director Sanjay Maraj £122,000 for their roles in the scheme. Both have been banned from working in financial services. 

The regulator said it also decided to ban Dolfin co-founder, Roman Joukovski, from working in financial services. 

Joukovski has referred his decision notice to the Upper Tribunal where he and the FCA will present their cases. Any findings in Joukovski’s decision notice are provisional and reflect the FCA’s belief as to what occurred and how it considers his behaviour should be characterised, it said. 

The offences relate to the use of what used to be called Tier 1 Investor visas, sometimes dubbed “golden visas,” designed to encourage HNW individuals to bring capital into the UK in return for access to a visa. The system was scrapped by the Johnson administration in 2022 following Russia’s invasion of Ukraine in late February. 

"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,” Therese Chambers, joint executive director of enforcement and market oversight at the FCA, said. “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."

Between 2016 and 2019, most clients using the scheme paid a fee of £400,000 instead of investing £2 million of their own money in UK companies, as required under the Home Office investor visa rules, the FCA said. The regulator said it found that the scheme was deliberately designed to create the false impression that the visa requirements had been met.  

The scheme enabled at least 99 individuals to obtain investor visas and generated at least £35.5 million 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 was responsible for the financial aspects once it was set up. Nagy and Maraj also deliberately concealed its true nature from the FCA and the Home Office.  

The FCA found that Joukovski deliberately concealed both his involvement with Dolfin and his role in the scheme from the regulator. It also found that Joukovski acted as a shadow director of Dolfin without FCA approval and was a controller of the firm without informing the regulator.  

On 12 March 2021 the FCA imposed restrictions on Dolfin to prevent it from carrying on any regulated activities, following a range of regulatory concerns, including its operation of the investor visa funding scheme.

Denisz Nagy has been fined £324,800 and prohibited from performing any function in relation to regulated activities. He agreed to settle and received a 30 per cent discount. Without the discount, the penalty would have been £464,000. 

Sanjay Maraj has been fined £122,000 and prohibited from performing any function in relation to regulated activities. He agreed to settle and received a 30 per cent discount. Without the discount, the penalty would have been £174,300.

Roman Joukovski, who has been issued with a Decision Notice imposing a prohibition order, has referred the matter to the Upper Tribunal.

The FCA found that all three individuals lack integrity and are not fit and proper to work in financial services.  

Dolfin entered special administration in June 2021, and the insolvency processes are ongoing.