Former CEO and Finance Director Fined Over Investor Visa Operation
The Financial Conduct Authority has banned two former senior executives of Dolfin Financial and decided to ban its co-founder after finding that the wealth manager operated a scheme that allowed clients to obtain UK investor visas without putting up the required £2 million of their own money.
Former chief executive Denisz Nagy was fined £324,800 and former finance director Sanjay Maraj £122,000. Both have also been prohibited from performing any function connected with regulated financial activities.
The FCA has separately issued a prohibition decision against Dolfin co-founder Roman Joukovski. Joukovski has referred his Decision Notice to the Upper Tribunal, meaning the findings against him remain provisional and the proposed ban will not take effect unless and until the tribunal determines the case.
The case centres on Dolfin’s Tier 1 Investor visa business between 2016 and 2019.
Under the visa rules in force at the time, applicants generally had to have at least £2 million of their own money under their control and invest qualifying funds in the UK. The FCA found that most people using Dolfin’s arrangement instead paid £400,000.
The regulator said the structure was deliberately designed to create the appearance that clients had satisfied the £2 million investment requirement.
At least 99 people obtained investor visas through the scheme, according to the FCA. It generated at least £35.5 million in fees for businesses connected to Dolfin and immigration agents that introduced clients.
Earlier FCA supervisory documents provide more detail about how the arrangement worked.
In its 2021 supervisory notice against Dolfin, the regulator described a structure in which clients could contribute £400,000 while the remaining £1.6 million was supplied through financing involving Dolfin-connected companies in offshore jurisdictions. The combined £2 million would then appear in the client’s account and be used to purchase securities linked to Dolfin-connected businesses.
The FCA said its fund-flow analysis found that the issuers of those securities did not receive most of the proceeds. Much of the money was instead recycled through connected companies to other investor-visa clients, leaving what the regulator described as no genuine investment in UK trading businesses in the most common version of the arrangement.
Dolfin’s own descriptions of the financing included several versions. A service referred to as “Gold” involved a client contributing £400,000 and receiving financing for the other £1.6 million. Another, known as “Jade,” involved depositing £2 million before £1.6 million was returned roughly a week later. Other structures involved different contribution and financing levels.
The FCA’s latest enforcement findings assign different responsibilities to the three former senior figures.
It found that Nagy and Joukovski played leading roles in creating and running the scheme, while Maraj handled its financial elements once it had been established. The regulator also found Nagy and Maraj deliberately concealed the true nature of the business from both the FCA and the Home Office.
In Joukovski’s case, the FCA alleges that he concealed his involvement with Dolfin and the visa operation. It also alleges that he acted as a shadow director without regulatory approval and controlled the firm without notifying the FCA. Those findings are among the matters that remain subject to the Upper Tribunal process.
Nagy and Maraj settled their cases and received 30% reductions in their financial penalties. Without the settlement discounts, Nagy’s fine would have been £464,000 and Maraj’s £174,300.
The enforcement action follows a regulatory process stretching back several years.
The FCA first identified serious concerns over Dolfin’s Tier 1 Investor visa activities and conflicts of interest during supervisory work in 2019. Voluntary restrictions were imposed that December, followed by an enforcement investigation and a skilled-person review of areas including financial crime controls and governance.
In March 2021, the FCA stopped Dolfin from carrying out regulated activities, citing concerns that included its investor visa business and weaknesses in financial crime controls. Dolfin entered special administration three months later, and the insolvency process remains ongoing.
The Tier 1 Investor route itself was closed to new applicants in February 2022. The Home Office said at the time that the route had been vulnerable to exploitation, including by people seeking to transfer illicit wealth and through complex investment arrangements intended to get around genuine investment requirements.
The FCA said the Home Office has subsequently refused applications for further or indefinite leave to remain from many clients who used the Dolfin arrangement.
Therese Chambers, the FCA’s joint executive director of enforcement and market oversight, said the individuals had undermined the purpose of rules intended to attract genuine UK investment and then tried to conceal how the arrangement operated.
Why the Dolfin Case Goes Beyond a Visa Rules Breach
The most important aspect of the Dolfin case is not simply that clients could apparently obtain something requiring £2 million by effectively paying £400,000.
It is where the arrangement sat.
Dolfin was an FCA-authorised wealth manager. The investment accounts, securities and financial transactions involved in the visa process therefore carried the appearance of activity taking place inside the regulated financial system.
That matters because investor visa programmes depended partly on financial institutions acting as gatekeepers. Immigration officials could set the requirement that an applicant invest their own money, but banks, brokers and wealth managers sat much closer to the actual source, movement and investment of those funds.
A structure that made £400,000 appear economically equivalent to a £2 million investment did more than reduce the cost of a visa. According to the FCA’s findings, it defeated the economic purpose behind the threshold.
The £2 million requirement was supposed to produce capital investment in Britain. If most of that figure existed only because funds were temporarily financed, circulated through connected entities or returned to the client, the headline investment number could look compliant while producing something very different economically.
That helps explain why integrity is central to the FCA’s case.
Traditional financial enforcement often focuses on direct customer losses, market manipulation or failures to safeguard client assets. Here, the alleged misconduct used financial infrastructure to affect another government system: immigration.
It shows how regulated firms can become enforcement choke points for rules that technically sit outside financial regulation.
The long timeline is also noteworthy. Dolfin’s visa business operated between 2016 and 2019. The FCA restricted the firm in 2021. The company entered special administration that same year, yet individual enforcement outcomes have arrived in 2026.
That delay highlights the complexity of cases involving interconnected companies, offshore entities, immigration documentation and reconstructed fund flows. It also means punishment can arrive long after the underlying business has disappeared.
There is another distinction worth keeping clear. The regulatory outcomes are final for Nagy and Maraj because they settled their cases. Joukovski’s is not. His Upper Tribunal reference gives him the opportunity to challenge the FCA’s account and proposed prohibition before it can take effect.
The wider policy question has already moved on. Britain abolished the Tier 1 Investor route for new applicants in 2022, citing longstanding concerns about illicit finance and abuse. Existing holders have continued to pass through extension and settlement processes under legacy rules.
The Dolfin case therefore arrives too late to change the visa programme that enabled the business.
Its impact is instead on the regulated firms that act as intermediaries whenever government policy depends on financial transactions being genuine. A regulated account statement can show that money moved. It cannot by itself prove that the economic substance behind that movement was what regulators or another government department intended.
That distinction — between a transaction that looks compliant and one that genuinely meets the purpose of the rule — is what makes the Dolfin case more important than the £35.5 million headline.
“`