InvestNot yet confirmed elsewhere1 publisher2 min readPublished
FCA bans and fines over £35.5m visa workaround land on named Dolfin executives
A scheme that sold the appearance of investor visa qualification has cost three named individuals their standing in UK finance, and one of them is still contesting it.
The Investor · Invest desk
What happened
- Between 2016 and 2019 most clients of the Dolfin scheme paid a £400,000 fee rather than investing the £2m of their own money the UK investor visa rules required.
- The FCA says the arrangement got at least 99 people investor visas and produced at least £35.5m in fees for Dolfin-connected businesses and the immigration agents that introduced clients.
- Ex-chief executive Denisz Nagy was fined £324,800 and ex-finance director Sanjay Maraj £122,000, both banned, each figure struck after a 30% settlement discount.
- Co-founder Roman Joukovski has a Decision Notice imposing a ban but has referred it to the Upper Tribunal, so the findings stand as provisional and the ban is not in force.
- Dolfin itself entered special administration in June 2021 and the insolvency processes are still running.
Why it matters
- cost The money recovered from individuals amounts to roughly 1.3% of the fees the scheme generated, and the settlement discounts removed £191,500 from that.
- exposure The clients are losing the thing they bought, with the Home Office refusing leave to remain and indefinite leave to remain, while the fee income has long since dispersed to introducers and a...
- precedent A finding that a co-founder acted as an unapproved shadow director and an unnotified controller tells anyone structuring influence off the register that absence from it is not a defence.
- contradiction Ninety-nine clients at the stated fee would come to £39.6m, above the £35.5m the FCA counts, so either the fee was not uniform across clients or the published total is a floor and the real take...
The number that never appears in the penalty column is £198m. Ninety-nine visa holders, each required to put £2m of their own money into UK companies, is what the route was supposed to deliver [20]. Most of them instead bought the appearance of that commitment for £400,000, a fifth of the required amount, leaving £1.6m a head uncommitted [6][21].
None of that is the FCA's rulebook. Visa qualification is the Home Office's test, and the Tier 1 investor route has been closed to new entrants since 17 February 2022 [13]. What gave the regulator a hook was conduct. It found the scheme deliberately designed to create the false impression that the visa requirement had been met [6], that Nagy and Joukovski led its creation and operation while Maraj took charge of the financial side once it was running [8], and that Nagy and Maraj concealed its true nature from both the FCA and the Home Office [8]. All three were found to lack integrity and not to be fit and proper to work in financial services [9]. "Integrity is not optional in financial services," said Therese Chambers, the FCA's joint executive director of enforcement and market oversight [10].
That is the reach worth noting. A firm whose commercial function is to attest to somebody else's qualification sits squarely inside the perimeter when the attestation is false, and so does a person directing that firm without ever appearing on the register.
The pace is the other lesson. The FCA stopped Dolfin from carrying on any regulated activities on 12 March 2021, citing a range of concerns that included the visa funding scheme [11]. The individual outcomes were published in August 2026 [15], five years and five months after the firm was switched off [22]. Anyone weighing whether a gatekeeping role carries personal exposure should read that gap as a long tail rather than an absence.
The route this scheme worked around no longer exists [13], so the action protects no live policy. It prices the behaviour retrospectively, and the audience for that price is everyone currently running a firm that signs off on someone else's compliance.
What to watch
- The Upper Tribunal's ruling on Joukovski's reference, which decides whether the third prohibition takes effect at all.
Clarity's read
What the record supports and how the coverage leans. The claims behind it follow.
Reality
- Evidence82
- Adoption74
- Hype gap+14
- Incentives68
- Confidence76
Claim ledger
Ranked by verification strength, evidence, and original report placement.
- [1]
The FCA has issued Dolfin co-founder Roman Joukovski with a Decision Notice imposing a prohibition order. He has referred it to the Upper Tribunal, so the findings are provisional and the proposed action has no effect pending the Tribunal's determination.
- [2]
The FCA found that Joukovski deliberately concealed from the regulator his involvement with Dolfin and his role in the scheme, acted as a shadow director of Dolfin without FCA approval, and was a controller of the firm without informing the regulator.
- [3]
The FCA fined former Dolfin chief executive Denisz Nagy £324,800 and prohibited him from performing any function in relation to regulated activities.
- [4]
The FCA fined former Dolfin finance director Sanjay Maraj £122,000 and prohibited him from performing any function in relation to regulated activities.
- [5]
Both Nagy and Maraj agreed to settle and received 30% discounts; without the discount the penalties would have been £464,000 and £174,300 respectively.
- [6]
Between 2016 and 2019, most clients using the scheme paid a fee of £400,000 instead of investing £2m of their own money in UK companies as required under Home Office investor visa rules. The FCA found the scheme was deliberately designed to create the false impression that the visa requirements had been met.
- [7]
The scheme enabled at least 99 individuals to obtain investor visas and generated at least £35.5m in fees for Dolfin-connected businesses and the immigration agents that introduced clients.
- [8]
The FCA found that Nagy and Joukovski played leading roles in creating and operating the scheme, that Maraj was responsible for the financial aspects once it was set up, and that Nagy and Maraj deliberately concealed its true nature from the FCA and the Home Office.
- [9]
The FCA found that all three individuals lack integrity and are not fit and proper to work in financial services.
- [10]
Therese Chambers, joint executive director of enforcement and market oversight at the FCA, said: 'Integrity is not optional in financial services.'
- [11]
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.
- [12]
Dolfin entered special administration in June 2021 and the insolvency processes remain ongoing.
- [13]
The Home Office closed the Tier 1 investor visa route of entry to the UK from 17 February 2022.
- [14]
The Home Office has acted against many of the clients that used the scheme by refusing their applications for leave to remain and indefinite leave to remain in the UK.
- [16]
The two settled fines total £446,800.
- [17]
Before the 30% settlement discounts the two fines would have totalled £638,300, so the discounts removed £191,500.
- [18]
The £446,800 of fines equals about 1.3% of the at least £35.5m in fees the scheme generated.
- [19]
At the £400,000 fee, 99 visas would produce £39.6m, which is £4.1m more than the at least £35.5m the FCA counts.
- [20]
The investment the rules would have required from 99 visa holders totals £198m.
- [21]
The £400,000 fee is 20% of the £2m investment requirement, leaving £1.6m per client uncommitted.
- [22]
The individual enforcement outcomes came five years and five months after the FCA restricted Dolfin's regulated activities.
Sources
1 independent publisher whose own reporting we read for this story.
- crowdfundinsider.comFCA bans trio behind £35.5m scheme designed to bypass visa rules
1 article · August 26, 2026
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