The Financial Conduct Authority has banned and fined three former senior figures at Dolfin Financial (UK) Ltd after finding they ran a scheme that let at least 99 people obtain UK investor visas by paying £400,000 in fees rather than the £2 million investment the Home Office required.
A £35.5 million fee scheme is at the centre of the FCA’s enforcement action against three former figures at Dolfin Financial (UK) Ltd. The regulator found that between 2016 and 2019, most clients using the arrangement paid £400,000 — one fifth of the £2 million investment legally required under Home Office Tier 1 (Investor) visa rules — to obtain residency visas they would not otherwise have qualified for.
The FCA has banned former chief executive Denisz Nagy, former finance director Sanjay Maraj, and businessman Roman Joukovski from working in regulated financial services. Nagy has been fined £324,800 and Maraj £122,000. The regulator concluded that Nagy and Joukovski played leading roles in creating and operating the scheme, while Maraj handled its financial aspects once it was established. All three, the FCA found, deliberately concealed the true nature of the arrangement — Nagy and Maraj from both the FCA and the Home Office, and Joukovski from the regulator alone.
The FCA determined that Roman Joukovski acted as a shadow director of Dolfin without FCA approval and as a controller of the firm without notifying the regulator. The scheme, the figures show, was deliberately structured to create a false impression that Home Office visa requirements had been met.
Dolfin’s collapse was already underway before this enforcement action. The FCA imposed formal restrictions on the firm on 12 March 2021, stopping it from carrying on regulated activities or accepting new client money. Dolfin then entered special administration, and the Financial Services Compensation Scheme has indicated it may be able to compensate eligible clients for losses relating to protected investment business.
The Tier 1 (Investor) route — sometimes called the “golden visa” — was closed to all new applicants on 17 February 2022, with the Home Office citing security concerns and issues identified in a legacy review of the scheme.
Any Kent residents who held investments in custody with Dolfin, or who used the firm’s Tier 1 visa services, may face questions about their immigration status or investment losses. Kent-based solicitors, accountants, or financial advisers who referred clients to Dolfin may also want to review their professional exposure the FCA’s findings. No publicly available evidence suggests the scheme was based in Kent or targeted Kent-specific investments — any local impact is indirect.
Key information
- Former Dolfin clients with affected investments should contact the special administrators or the FSCS directly for information on compensation and asset recovery
- Anyone with questions about their Tier 1 (Investor) visa status following the FCA’s findings should seek independent immigration legal advice
- The Tier 1 (Investor) visa route closed to new applicants on 17 February 2022; existing holders retain rights to extend or seek settlement within defined deadlines
Source: @TheFCA