FCA Bans Trio Over £35.5 Million Investor Visa Scheme
The UK Financial Conduct Authority has banned three former senior figures at Dolfin Financial (UK) Limited after finding that they operated a scheme designed to help clients circumvent the requirements of the UK’s former Tier 1 investor visa route.
In a decision announced on 26 August 2026, the FCA said former Dolfin chief executive Denisz Nagy has been fined £324,800 and former finance director Sanjay Maraj £122,000. Both have also been prohibited from working in financial services. The regulator has separately decided to ban Dolfin co-founder Roman Joukovski, although he has referred his Decision Notice to the Upper Tribunal, meaning the FCA’s findings against him remain provisional pending the Tribunal’s determination.
Scheme generated at least £35.5 million in fees
According to the FCA, the scheme operated between 2016 and 2019. Under the investor visa rules then in force, applicants were generally required to invest £2 million of their own money in qualifying UK investments. The FCA found that most clients using the Dolfin arrangement instead paid a fee of £400,000, while the structure was designed to create the false impression that the required £2 million investment condition had been met.
The regulator said at least 99 individuals obtained investor visas through the arrangement. Dolfin-connected businesses and the immigration agents that introduced clients generated at least £35.5 million in fees.
The FCA found that Nagy and Joukovski played leading roles in creating and operating the scheme, while Maraj was responsible for its financial aspects after it had been established. Nagy and Maraj were also found to have deliberately concealed the true nature of the arrangement from both the FCA and the Home Office.
Different procedural status for the three individuals
Nagy and Maraj settled their cases and received 30% discounts on their financial penalties. Without the discounts, their fines would have been £464,000 and £174,300 respectively. The FCA found that all three individuals lacked integrity and were not fit and proper to work in financial services.
Joukovski’s position is procedurally different. Because he has referred the matter to the Upper Tribunal, the findings in his Decision Notice are not final and the proposed prohibition will not take effect unless and until the Tribunal process permits it.
The FCA previously imposed restrictions on Dolfin in March 2021 over a range of regulatory concerns, including the investor visa funding scheme. Dolfin entered special administration in June 2021. The Home Office closed the Tier 1 investor visa route to new applicants in February 2022 and has since taken action against a number of clients who used the scheme.
The case highlights how financial-services structures can be used to manufacture the appearance that regulatory eligibility conditions have been satisfied, creating risks that extend beyond conventional investment conduct into broader financial-crime and integrity controls.
