The FCA has decided to ban 3 former senior figures at Dolfin Financial (UK) Limited (Dolfin) after finding they ran a scheme that helped clients bypass UK visa rules.
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.
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.
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.
The FCA found that Mr Nagy and Mr Joukovski played leading roles in creating and operating the scheme, while Mr Maraj was responsible for the financial aspects once it was set up. Mr Nagy and Mr Maraj also deliberately concealed its true nature from the FCA and the Home Office.
The FCA found that Mr Joukovski deliberately concealed from the regulator both his involvement with Dolfin and his role in the scheme. It also found that Mr Joukovski acted as a shadow director of Dolfin without FCA approval and was a controller of the firm without informing the regulator.
Therese Chambers, joint executive director of enforcement and market oversight at the FCA, said:
‘Integrity is not optional in financial services. 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. We will continue to act against those who lack integrity and undermine trust in UK financial services.’
Notes to editors
- See the Final Notice for Mr Nagy (PDF).
- See the Final Notice for Mr Maraj (PDF).
- See the Decision Notice for Mr Joukovski (PDF).
- 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.
- Denisz Nagy has been fined £324,800 and prohibited from performing any function in relation to regulated activities. He agreed to settle and received a 30% discount. Without the discount, the penalty would have been £464,000.
- Sanjay Maraj has been fined £122,000 and prohibited from performing any function in relation to regulated activities. He agreed to settle and received a 30% discount. Without the discount, the penalty would have been £174,300.
- Roman Joukovski has been issued with a Decision Notice imposing a prohibition order. He has referred the matter to the Upper Tribunal.
- The FCA found that all 3 individuals lack integrity and are not fit and proper to work in financial services.
- Dolfin entered special administration in June 2021, and the insolvency processes remain ongoing.
- The Home Office closed the Tier 1 investor visa route of entry to the UK from 17 February 2022.
- The Home Office has acted against many of the clients that used the scheme by refusing their applications for leave to remain and indefinite leave to remain in the UK.