FCA Bans Three Over £35.5m Scheme That Bypassed UK Investor Visa Rules

What the FCA found

On 26 August 2026 the Financial Conduct Authority announced it had decided to ban three former senior figures at Dolfin Financial (UK) Limited after finding they ran a scheme that helped clients bypass UK investor visa rules. The regulator said the scheme was deliberately designed to create the false impression that the visa requirements had been met. The findings relate to the period between 2016 and 2019, when the Tier 1 investor visa route was still open.

The FCA found that Mr Nagy and Mr Joukovski led the creation and operation of the scheme, while Mr Maraj handled the financial side. It also found that Mr Nagy and Mr Maraj concealed the true nature of the scheme from the FCA and the Home Office. Separately, the FCA found that Mr Joukovski acted as a shadow director and controller without approval. These are regulatory findings, not criminal convictions, and the findings against Mr Joukovski remain provisional because he has referred his Decision Notice to the Upper Tribunal.

How the £400,000 fee replaced a £2m investment

Under the Tier 1 investor visa rules, applicants were required to invest £2m of their own money in UK companies. The FCA found that between 2016 and 2019, most clients using the Dolfin scheme paid a fee of £400,000 instead of investing £2m of their own money. The regulator said the scheme was deliberately designed to create the false impression that the visa requirements had been met. In other words, the structure did not involve the client committing the full £2m of their own capital as the rules required.

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 who introduced clients. The FCA's findings suggest the fee was paid to intermediaries rather than being invested in UK companies. The Home Office has since acted against many clients who used the scheme by refusing their applications for leave to remain and indefinite leave to remain. The Home Office closed the Tier 1 investor visa route from 17 February 2022.

Who has been fined and banned, and what is still provisional

Former chief executive Denisz Nagy was fined £324,800 and former finance director Sanjay Maraj £122,000. Both are banned from financial services. Both settled and received a 30% discount; the penalties would otherwise have been £464,000 and £174,300 respectively. The FCA found that Mr Nagy and Mr Maraj concealed the true nature of the scheme from the FCA and the Home Office. These findings are final for Mr Nagy and Mr Maraj because they settled.

Co-founder Roman Joukovski has a Decision Notice imposing a ban. He has referred it to the Upper Tribunal, so the findings against him are provisional and the ban has no effect pending the Tribunal. The FCA found that Mr Joukovski acted as a shadow director and controller without approval, and that he and Mr Nagy led the creation and operation of the scheme. Because the matter is before the Tribunal, no final conclusions should be drawn about Mr Joukovski at this stage.

What the FCA said

Therese Chambers, joint executive director of enforcement and market oversight at the FCA, said integrity is not optional in financial services and the scheme undermined the purpose of attracting genuine investment into the UK. Her comments underline the regulator's position that the investor visa route was intended to bring real capital into UK companies, not to generate fees for intermediaries while creating a false impression of compliance.

The FCA's action is a regulatory enforcement outcome, not a criminal prosecution. The regulator has published its decision to ban the three former senior figures, and the fines reflect the seriousness with which it views the conduct. The FCA's findings also highlight the role of immigration agents who introduced clients to the scheme, as the fees generated went to Dolfin-connected businesses and those agents. The regulator has not announced criminal charges in this matter.

What happened to Dolfin and its clients

On 12 March 2021 the FCA restricted Dolfin from carrying on regulated activities. Dolfin entered special administration in June 2021 and the insolvency processes are ongoing. The restrictions and subsequent administration meant the firm could no longer operate as it had. The FCA's latest action concerns the conduct of former senior figures at the firm, rather than the firm itself, which is already in special administration.

The Home Office has acted against many clients who used the scheme by refusing their applications for leave to remain and indefinite leave to remain. The Home Office closed the Tier 1 investor visa route from 17 February 2022. For individuals who used the scheme, the immigration consequences may include refusals on grounds of deception, which can affect future applications. Appeals or administrative reviews have strict deadlines. Anyone affected should seek regulated immigration advice from an OISC-registered adviser or a solicitor.

What it means for people who used investment-based visa routes

Applicants are responsible for the accuracy of their immigration applications. A refusal on grounds of deception can affect future applications, and appeals or administrative reviews have strict deadlines. The FCA's findings indicate that the scheme was designed to create a false impression that visa requirements had been met, which may have implications for individuals who relied on it. The Home Office has already refused many applications for leave to remain and indefinite leave to remain from clients who used the scheme.

Anyone who used an investment-based visa route and is concerned about their position should seek regulated immigration advice. OISC-registered advisers and solicitors can provide advice on the specific circumstances of a case. The FCA's action does not itself determine any individual's immigration status, but the findings may be relevant to how the Home Office assesses applications. Deadlines for appeals or administrative reviews are strict, so early advice is important. This article does not provide individual immigration advice.

How to check an adviser or firm before you pay

Before paying for immigration or investment advice, check that the adviser or firm is regulated. For immigration advice, use the OISC register or check that the adviser is a solicitor regulated by a professional body. For financial services, check the FCA register to confirm a firm or individual is authorised. The FCA's action against former Dolfin senior figures shows the importance of dealing with regulated firms and understanding what a fee actually buys.

If a scheme promises visa compliance in exchange for a fee that is much lower than the required investment, that is a warning sign. The Tier 1 investor visa route required a £2m investment of the applicant's own money. The FCA found that most clients using the Dolfin scheme paid £400,000 instead. Checking the FCA register and the OISC register before paying can help avoid unregulated or unsuitable arrangements. Anyone with concerns about a firm should contact the FCA or the relevant regulator.

Related coverage on Kael Tripton: UK Investor Visa 2026: What Replaced Tier 1, UK Settlement and ILR Guide: Indefinite Leave to Remain, Indefinite Leave To Remain Travel Document: UK Visa Guide, UK Visa Refusal and Appeals: Your Options, Reapplying After a UK Visa Refusal 2026: How to Strengthen a Fresh Application.

Frequently asked questions

What did the FCA find about the Dolfin scheme?

The FCA found that between 2016 and 2019, a scheme run by former senior figures at Dolfin Financial (UK) Limited helped clients bypass UK investor visa rules. Most clients paid a £400,000 fee instead of investing £2m of their own money in UK companies as required. The FCA said the scheme was deliberately designed to create the false impression that visa requirements had been met. The scheme enabled at least 99 individuals to obtain investor visas and generated at least £35.5m in fees.

Who has been fined or banned by the FCA?

Former chief executive Denisz Nagy was fined £324,800 and former finance director Sanjay Maraj £122,000. Both are banned from financial services and both settled, receiving a 30% discount. Co-founder Roman Joukovski has a Decision Notice imposing a ban, but he has referred it to the Upper Tribunal, so the findings against him are provisional and the ban has no effect pending the Tribunal. These are regulatory findings, not criminal convictions.

What happened to Dolfin Financial (UK) Limited?

On 12 March 2021 the FCA restricted Dolfin from carrying on regulated activities. Dolfin entered special administration in June 2021 and the insolvency processes are ongoing. The FCA's latest action concerns former senior figures at the firm. The firm itself is in special administration, and the regulator's findings relate to the period between 2016 and 2019 when the scheme operated.

What does this mean for people who used the scheme?

The Home Office has acted against many clients who used the scheme by refusing their applications for leave to remain and indefinite leave to remain. Applicants are responsible for the accuracy of their immigration applications. A refusal on grounds of deception can affect future applications, and appeals or administrative reviews have strict deadlines. Anyone affected should seek regulated immigration advice from an OISC-registered adviser or a solicitor. This article does not provide individual immigration advice.

How can I check an adviser or firm before paying?

For immigration advice, check the OISC register or confirm the adviser is a solicitor regulated by a professional body. For financial services, check the FCA register to confirm a firm or individual is authorised. Be cautious if a scheme promises visa compliance for a fee much lower than the required investment. The Tier 1 investor visa route required a £2m investment of the applicant's own money. Checking the relevant registers before paying can help avoid unregulated arrangements.