The UK Financial Conduct Authority announced action on 26 August against three former senior figures at Dolfin Financial (UK) Limited over a financing arrangement used by Tier 1 investor visa clients between 2016 and 2019. The FCA says at least 99 individuals obtained investor visas through the arrangement and that Dolfin-connected businesses and immigration agents generated at least £35.5 million in fees.
The procedural distinction is essential. Former chief executive Denisz Nagy and former finance director Sanjay Maraj settled with the FCA. They were fined £324,800 and £122,000 respectively and are prohibited from regulated financial-services work. A prohibition Decision Notice was issued to co-founder Roman Joukovski, but he referred it to the Upper Tribunal. Findings concerning him remain provisional and the proposed prohibition has no effect pending the Tribunal’s decision.
How the FCA describes the arrangement
The Final Notices describe a multi-step structure for some clients seeking Tier 1 investor visas. Most paid a fee of roughly £400,000 rather than investing at least £2 million of their own funds as the immigration rules then required. The FCA concluded that the transactions were artificial, lacked genuine commercial rationale when viewed as a whole and created a false or misleading impression that the requirements had been met.
The regulator estimates at least £35.5 million of gross fee revenue, including about £10.3 million paid to introducing immigration agents and an estimated £25.2 million of net profit. Those are FCA estimates from available records; they should not be rewritten as a court finding of criminal proceeds or client investment losses.
The FCA found Nagy central to the design and oversight and Maraj responsible for financial aspects after implementation. Their Final Notices are effective. Both received a 30% Stage 1 settlement discount; without it, the penalties would have been £464,000 and £174,300.
Why the third case must be reported separately
The FCA alleges that Joukovski played a leading role, concealed his connection with Dolfin and the scheme, and acted as an unapproved shadow director and controller. These are findings in a Decision Notice, not a final determination after Tribunal review.
Joukovski and the FCA will present their cases to the Upper Tribunal. Until it publishes a decision, reporting should attribute the allegations to the FCA, not state that he has been finally banned or criminally convicted.
From the 2021 restrictions to personal accountability
The FCA restricted nearly all of Dolfin’s regulated activities in March 2021 amid concerns that included the visa funding arrangement, client-asset controls and financial-crime systems. The firm later entered special administration in June 2021; insolvency proceedings remain ongoing.
The 2026 notices show that a firm’s closure does not end scrutiny of senior managers. For firms offering brokerage, custody, currencies, derivatives and cross-border wealth services, controllers, related-party transactions, introducer commissions and regulatory disclosures can remain part of the accountability trail for years.
TraderVote view
The release is a useful test of precise regulatory reporting: it combines effective Final Notices, settlement-discounted penalties and a contested Decision Notice. Collapsing them into a claim that “three people have been finally punished” would erase a material legal distinction.
For financial institutions, KYC forms alone are not a sufficient control. Cross-border structures involving affiliates, introducers and security issuers require auditable evidence of commercial substance, conflicts management, the customer-money path, regulatory disclosure and senior approval. For clients, a licence does not by itself validate every structure offered under a regulated firm’s name.
Sources
Financial Conduct Authority, “FCA bans trio behind £35.5m scheme designed to bypass visa rules”, 26 August 2026: https://www.fca.org.uk/news/press-releases/fca-bans-trio-bypass-visa-rules
FCA Final Notice for Denisz Andras Nagy, 25 August 2026: https://www.fca.org.uk/publication/final-notices/denisz-andras-nagy-2026.pdf
FCA Final Notice for Sanjay Maraj, 25 August 2026: https://www.fca.org.uk/publication/final-notices/sanjay-maraj-2026.pdf
FCA Decision Notice for Roman Joukovski, 25 August 2026; referred to the Upper Tribunal: https://www.fca.org.uk/publication/decision-notices/roman-joukovski-2026.pdf
FCA, “Restrictions placed on Dolfin Financial (UK) Ltd”, 12 March 2021: https://www.fca.org.uk/news/news-stories/restrictions-placed-dolfin-financial-uk-ltd
Written independently by Hengyuan from verifiable FCA material available through 26 August 2026. Findings concerning Mr Joukovski remain subject to the Upper Tribunal. This article is not investment or legal advice.
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