FCA Bans Three Former Dolfin Financial Executives Over £35.5M Visa Scheme

The UK Financial Conduct Authority has banned three former senior figures at Dolfin Financial (UK) Limited from working in financial services, after finding they ran a scheme that helped clients bypass UK investor visa rules and generated at least £35.5 million in fees. Former chief executive Denisz Nagy was fined £324,800 and former finance director Sanjay Maraj £122,000 on August 26, 2026, while co-founder Roman Joukovski has referred his case to the Upper Tribunal.

Between 2016 and 2019, most clients using the scheme paid a fee of £400,000 instead of investing £2 million of their own money in UK companies, as the Home Office investor visa rules required. The FCA found the arrangement was deliberately built to create the false impression that the visa conditions had been met. It enabled at least 99 individuals to obtain investor visas, with the fees flowing to Dolfin-connected businesses and the immigration agents who introduced the clients.

What Each Individual Did, According to the Regulator

The FCA found that Nagy and Joukovski played leading roles in creating and operating the scheme, while Maraj was responsible for its financial aspects once it was running. Nagy and Maraj also deliberately concealed the scheme’s true nature from both the FCA and the Home Office.

Joukovski’s case goes further into governance territory. The regulator found he concealed his involvement with Dolfin and his role in the scheme, acted as a shadow director of the firm without FCA approval, and operated as a controller of the firm without informing the regulator. Unlike the other two, he did not settle: he received a Decision Notice imposing a prohibition order and has referred the matter to the Upper Tribunal, where both sides will present their cases. The findings against him are provisional until the tribunal rules, and the proposed prohibition has no effect in the meantime.

“Integrity is not optional in financial services,” said Therese Chambers, joint executive director of enforcement and market oversight at the FCA. “These individuals ran a scheme designed to get around the UK’s investor visa rules, undermining their purpose of attracting genuine investment into the UK. They then sought to hide how it operated.”

The Numbers Behind the Case

• £35.5 million in fees generated for Dolfin-connected businesses and introducing immigration agents
• At least 99 investor visas obtained through the scheme
• £400,000 fee paid by most clients, against a required £2 million personal investment
• £324,800 fine for Denisz Nagy, reduced from £464,000 under a 30% settlement discount
• £122,000 fine for Sanjay Maraj, reduced from £174,300 under the same discount

All three individuals were found to lack integrity and to be unfit to work in financial services. Nagy and Maraj each agreed to settle, earning the 30% reduction the FCA applies to early resolutions, and both are prohibited from performing any function in relation to regulated activities.

A Firm That Was Already Gone

The enforcement lands five years after the regulator moved against the firm itself. On March 12, 2021, the FCA imposed restrictions preventing Dolfin from carrying on any regulated activities, citing a range of regulatory concerns that included the investor visa funding scheme. Dolfin entered special administration in June 2021, and the insolvency processes remain ongoing.

The action follows the same pattern Securities.io documented last week when the regulator banned former SVS Securities chief executive Demetrios Hadjigeorgiou and fined him £56,400: senior-manager accountability pursued years after the underlying conduct, with settlement discounts shaping the final penalty figures.

The visa route at the center of the case no longer exists. The Home Office closed the Tier 1 investor visa to new applicants from February 17, 2022, and the government’s own guidance now confirms that only existing holders can apply to extend or settle. The Home Office has also acted against many of the clients who used the Dolfin scheme, refusing their applications for leave to remain and indefinite leave to remain in the UK — meaning the consequences of the 2016–2019 arrangement are still working through individual immigration files in 2026.

What Remains to Be Decided

Two threads stay open. Joukovski’s Upper Tribunal reference will determine whether the provisional findings against him stand, with the tribunal’s decision to be made public on its website. And Dolfin’s special administration, running since June 2021, continues to wind through the insolvency process with the firm’s former leadership now formally barred from the industry it operated in.