Dolfin's loan scheme sold £2M investor visas for £400K — FCA banned its three top figures

From November 2015, London custody and brokerage firm Dolfin Financial ran a business line for 'Tier 1 investor visa clients' introduced by immigration agents. The Home Office programme required a minimum £2 million UK investment; Dolfin's version lent clients money to buy £2 million of bonds issued by companies in which Dolfin or its directors had an interest. The FCA later called the scheme inherently artificial: a Tier 1 investor visa for a £400,000 fee instead of a genuine £2 million investment.

The FCA's supervisory work from July to November 2019 surfaced the concerns, and that December Dolfin agreed to voluntary requirements barring new Tier 1 visa clients and the conflicted securities; in March 2021 the FCA used own-initiative powers to stop Dolfin carrying out regulated activities. The FCA found Roman Joukovski — who held no formal role at the firm — central to designing and overseeing the visa loan business while concealing his involvement; former CEO Nagy led its creation and former FD Maraj ran its finances, both concealing the scheme's nature from the FCA and the Home Office.

The scheme generated £35.5 million in fees. In findings published in 2026, the FCA banned all three men and fined Nagy £324,800 and Maraj £122,000, finding all unfit on honesty and integrity grounds; Joukovski, found to be a shadow director despite holding no formal role, has appealed to the Upper Tribunal. The FCA framed the case as a warning to firms operating where financial services meet other policy areas — here, immigration — and as an example of supervisory powers used long before enforcement.

FCA banned three former senior figures and fined two — £324,800 for ex-CEO Nagy, £122,000 for ex-FD Maraj; Dolfin has been barred from regulated activity since March 2021

The visa-introducer channel delivered wealthy clients who would pay handsomely for a workaround, and Dolfin controlled both sides: it lent the money and sold the bonds it had an interest in.

Launching the business without notifying the FCA, as Principle 11 required, and concealing Joukovski's role meant no regulator could test the scheme's lawfulness before it scaled.

The conflicted-bond structure made the artifice self-funding — clients' nominal £2M holdings were loans recycling Dolfin's own £400K fee — which is why the FCA called it inherently artificial.

When a product's only value is helping customers evade another regulator's rules, the scheme is one inspection from zero — and the fees it earns become the evidence against you.

Nagy and Maraj received final notices with bans and fines; Joukovski's appeal to the Upper Tribunal is pending, with commentators noting the risk of inconsistent findings and the failure of anonymisation — 'Individual A' and 'Individual B' were identifiable from identical text in the other notices. The FCA cites the case as an expansion of enforcement focus beyond financial-services rules into honesty and integrity generally.