A £400,000 fee instead of a £2m investment: the FCA closes its Dolfin file

On 26 August 2026 the Financial Conduct Authority published its decisions against three former senior figures at Dolfin Financial (UK) Limited, a London wealth manager that ran what the regulator describes as a scheme to help clients bypass the UK’s investor visa rules.

Former chief executive Denisz Nagy was fined £324,800 and former finance director Sanjay Maraj £122,000. Both agreed to settle and took a 30 per cent discount; the undiscounted figures were £464,000 and £174,300. Both are banned from performing any function in relation to regulated activities. The FCA has also decided to ban Dolfin’s co-founder, Roman Joukovski, who has referred his Decision Notice to the Upper Tribunal. The findings against him are provisional and the prohibition has no effect until the Tribunal rules.

What the scheme did

Between 2016 and 2019, most clients using the scheme paid Dolfin a fee of £400,000 rather than investing £2m of their own money in UK companies, as the Home Office required under the Tier 1 (Investor) route. The FCA found the arrangement was deliberately designed to create the false impression that the investment requirement had been met.

At least 99 individuals obtained investor visas this way. The scheme produced at least £35.5m in fees for Dolfin-connected businesses and for the immigration agents who introduced the clients.

According to the FCA, Nagy and Joukovski created and ran the scheme, and Maraj handled its financial side once it was operating. Nagy and Maraj concealed how it worked from both the FCA and the Home Office. Joukovski, the regulator found, hid his involvement with Dolfin altogether, acting as a shadow director without approval and holding control of the firm without notifying it. Therese Chambers, the FCA’s joint executive director of enforcement and market oversight, said integrity is not optional in financial services.

The clients did not get away with it either

The detail that matters most to families sits in the FCA’s notes to editors rather than its headline. The Home Office has refused applications for leave to remain and indefinite leave to remain from many of the clients who used the scheme. So roughly a hundred people paid £400,000 for a residency position they have since lost, having also placed money with a firm that entered special administration in June 2021 and whose insolvency is still running five years later.

The timeline is worth keeping in view. The FCA restricted Dolfin from carrying on regulated activities in March 2021. The Tier 1 investor route itself closed to new applicants on 17 February 2022. The enforcement outcome arrived in August 2026, five and a half years after the firm was stopped.

What it means for family offices

Dolfin was an authorised firm, and that authorisation is precisely what made the arrangement saleable. Nothing about being FCA-regulated speaks to whether the underlying substance of a structure holds up, and residency-by-investment work usually sits outside the regulator’s perimeter anyway. The person who checks that the investment actually exists has to be someone the family instructs, not someone the promoter introduces.

The pricing was the signal. A fee of £400,000 in place of £2m of committed capital is not a discount on a service; it is a different transaction, and the family office reading the paperwork should have been able to say so. Where residency or citizenship advice comes bundled with a fee that replaces the qualifying investment, the question to ask is who carries the loss if the position is later unwound.

The allocation of consequences here is the durable lesson. Three individuals have been fined or banned. The families lost their immigration status and, for now, their access to assets. Regulatory sanction lands on the adviser; the immigration and financial exposure stays with the client.

Sources: Financial Conduct Authority; Professional Adviser.