FCA Fines Former Dolfin Executives £446,800 Over £35.5m Visa Scheme

• Three former senior figures at Dolfin Financial have been fined or banned by the UK Financial Conduct Authority after a scheme that helped clients bypass investor visa requirements generated at least £35.5 million in fees.

The Financial Conduct Authority, FCA, has fined two former senior executives of Dolfin Financial UK Limited a combined £446,800 and banned all three individuals from working in UK financial services over a scheme designed to circumvent the country’s investor visa rules.

Former CEO Denisz Nagy was fined £324,800, while former Finance Director Sanjay Maraj was fined £122,000. Both have been prohibited from performing regulated functions. Dolfin co-founder Roman Joukovski has also been banned, although his case has been referred to the Upper Tribunal and the FCA’s findings against him remain provisional pending that process.

The FCA found that between 2016 and 2019, the scheme allowed clients to pay about £400,000 rather than invest the required £2 million in UK companies under the then Tier 1 investor visa rules.

According to the regulator, the arrangement was designed to create the appearance that clients had met the investment requirement when they had not. At least 99 individuals obtained investor visas through the scheme, generating at least £35.5 million in fees for businesses connected to Dolfin and immigration agents involved in bringing clients into the arrangement.

The enforcement action also raises questions about senior management oversight. The FCA said Nagy and Maraj deliberately concealed the scheme’s true nature from both the regulator and the Home Office. It also found that Joukovski acted as a shadow director and controller without the required FCA approval or notification.

The case follows earlier regulatory concerns about Dolfin’s financial crime controls. In 2021, the FCA restricted the firm’s regulated activities and said it had serious concerns about its Tier 1 visa business and financial crime controls. Dolfin subsequently entered special administration.

Compliance takeaway: The case is a reminder that regulatory risk is not confined to obvious financial crime. A legitimate financial business can become exposed when senior executives design structures intended to defeat another regulatory regime, particularly where information is withheld from regulators.