Context
The FCA has decided to ban three former senior figures at Dolfin Financial (UK) Limited (Dolfin) after finding they ran a scheme that helped clients bypass UK visa rules.
Key points to note and next actions
- Former chief executive Denisz Nagy has been fined £324,800 and former finance director Sanjay Maraj £122,000 for their roles in the scheme. Both have been banned from working in financial services.
- The FCA has also decided to ban Dolfin co-founder, Roman Joukovski, from working in financial services.
- Mr Joukovski has referred his Decision Notice to the Upper Tribunal where he and the FCA will present their cases. Any findings in Mr Joukovski’s Decision Notice are therefore provisional and reflect the FCA’s belief as to what occurred and how it considers his behaviour should be characterised. The proposed action outlined in Mr Joukovski’s Decision Notice will have no effect pending the determination of the reference by the Tribunal whose decision will be made public on its website.
- 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 the 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.
- 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.
- 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.