The Financial Conduct Authority (FCA) has fined two former Dolfin Financial (UK) Limited executives a combined £446,800 and banned them for life over a scheme that took £400,000 from foreign nationals in place of the £2 million investment the Home Office required, 99 times over. The Authority’s own estimate of the scheme’s net profit is £25.2 million, and it sought to disgorge none of it.

The FCA published Final Notices against former chief executive Denisz Andras Nagy (£324,800) and former finance director Sanjay Maraj (£122,000) on August 26, 2026, both dated August 25, 2026, each carrying a full prohibition under section 56 of the Financial Services and Markets Act 2000 (FSMA). Co-founder Roman Joukovski has referred his Decision Notice to the Upper Tribunal, so nothing against him is decided. This analysis works through what the notices establish, why the penalty arithmetic lands so far below the money involved, how three individual-accountability regimes handle a firm that no longer exists, and what an unresolved Tribunal reference does to the precedent.

Key facts

• £324,800 — penalty on Denisz Andras Nagy (DAN01061), cut from £464,068.80 by a 30% Stage 1 discount, plus a section 56 prohibition (FCA Final Notice, August 25, 2026).
• £122,000 — penalty on Sanjay Maraj (SXM02506), cut from £174,385.25 on the same basis, plus a section 56 prohibition (FCA Final Notice, August 25, 2026).
• £35.5 million gross fees to Dolfin-connected companies, of which the FCA estimates £25.2 million was net profit after £10.3 million of commission to introducing immigration agents (Nagy Final Notice, paragraph 2.7).
• 99 Tier 1 investor visa clients used the scheme; 77 took the “Gold” option, paying £400,000 while Dolfin-connected companies supplied the remaining £1.6 million (Nagy Final Notice, Annex 1.5–1.6).
• £0 — Step 1 disgorgement in both notices; the FCA “has not identified any financial benefit” derived directly from the breaches by either man (paragraphs 6.3–6.4).
• £290,043 — Nagy’s relevant income, the base for his penalty. Maraj’s was higher at £387,522.76, yet his fine is a third of Nagy’s.
• June 30, 2021 — special administrators appointed over Dolfin, after the FCA’s First Supervisory Notice of March 12, 2021 under section 55L(3)(a) FSMA. The insolvency remains open.

Methodology and sources

This analysis rests on four primary FCA documents read in full: the Final Notices for Denisz Andras Nagy (44 pages) and Sanjay Maraj (43 pages), both dated August 25, 2026; the Decision Notice for Roman Joukovski (51 pages, June 30, 2026); and the First Supervisory Notice for Dolfin Financial (UK) Limited of March 12, 2021. Every figure below traces to a numbered paragraph in one of those documents rather than to the FCA press release of August 26, 2026. Comparative material comes from the Central Bank of Ireland and the Australian Prudential Regulation Authority (APRA); market-wide penalty totals are our own count of the FCA’s 2026 fines table as at September 2, 2026. Findings against Mr Joukovski are provisional and treated as such throughout.

What the notices establish about the £400,000

The Immigration Rules for the Tier 1 (Investor) route required a minimum £2 million investment of the applicant’s own money in share or loan capital of active, trading UK companies. The visa loan business inverted that. Under the Gold service — 77 of the 99 clients — the foreign national deposited £400,000 into a Dolfin client account. It was never invested; it was a fee. The £2 million purchase of “Conflicted Securities” was assembled from that fee plus £1.6 million routed from a British Virgin Islands company controlled by Nagy, which passed briefly through the client’s own account before returning to source as consideration for the same securities — bonds issued by companies in which Dolfin or its directors held an interest. A call option, often paired with a power of attorney, let Dolfin reclaim them at the end of the five-year holding period. Dolfin then wrote to the Home Office saying the client had invested £2 million in UK businesses.

The pricing was tiered, and the tiers are the clearest evidence of design. Gold and Jade both carried a £400,000 fee and both delivered settlement in five years — Jade simply took £2 million and returned £1.6 million within about a week. Platinum cost £100,000 and compressed settlement to three years; Palladium cost £150,000 and compressed it to two. A product priced by the year of settlement is not an investment with an incidental immigration benefit. The FCA found the arrangement “inherently artificial”, comprised of “contrived transactions which had no genuine commercial rationale”, and that Nagy called it a “grey area product” while Dolfin held limited in-house immigration expertise. Three staff resigned over its legality.

Both men were also found to have concealed the business from the FCA. Nagy omitted its existence in dealings with supervisors in November and December 2019, and between February and April 2020 gave an instructed immigration lawyer incomplete and inaccurate information, so that the resulting advice — shared with the FCA under limited waiver of privilege — addressed a version of the business that did not exist. Maraj turned a blind eye to colleagues’ misleading responses between November 2019 and May 2020. Both misrepresented the scheme’s key features when interviewed. That concealment, not the visa arrangement alone, carries the integrity finding.

Three regimes, one question: who is left to sanction

Jurisdiction / Regulator	Regime and legal basis	In force from	Scope	Route against the individual
UK (FCA)	FSMA 2000 ss.56 and 66; APER and COCON under the Senior Managers and Certification Regime	Dolfin’s controlled functions became Senior Management Functions on December 9, 2019, per both Final Notices	Approved persons, plus conduct outside the approved role where integrity is in issue	s.66 penalty and s.56 prohibition: £324,800 and £122,000, August 25, 2026
Ireland (Central Bank of Ireland)	Central Bank (Individual Accountability Framework) Act 2023; Conduct Standards; SEAR	Act commenced April 19 and December 29, 2023; Conduct Standards December 29, 2023; Certification Regulations January 8, 2024; SEAR July 1, 2024	Common Conduct Standards for all Controlled Function roles; Additional Standards for Pre-Approval Controlled Function holders	Administrative Sanctions Procedure “directly against individuals … rather than only for their participation in breaches committed by a regulated firm”
Australia (APRA and ASIC)	Financial Accountability Regime Act 2023, jointly administered; ASIC guidance RG 279	Deposit-taking institutions and licensed NOHCs March 15, 2024; insurers and superannuation trustees March 15, 2025	Banking, insurance and superannuation accountable entities and their accountable persons	Obligations attach to named directors and senior executives of the accountable entity

Sources: FCA Final Notices; Central Bank of Ireland, Individual Accountability Framework; APRA, Financial Accountability Regime. Last updated: September 2, 2026.

The UK’s answer is the oldest and, on this evidence, the most complete: section 56 attaches to the person, not the permission, so it survives the firm. Ireland’s 2023 Act closes the gap that makes such cases hard — before it, the Central Bank generally had to establish a firm breach before pursuing the individual who caused it, and removing that “participation link” means an Irish Dolfin would not be frustrated by the firm’s collapse into insolvency. Australia’s regime maps named accountable persons to responsibilities inside an accountable entity — a structure that presumes the entity is there to be mapped.

That presumption is the arbitrage. A scheme run through a British Virgin Islands vehicle, a Bermudan parent and a Liechtenstein foundation — the ownership chain the FCA describes at Dolfin — touches an individual-accountability regime only where an approved person sits inside a regulated entity. It is the perimeter problem this desk traced in the UK’s critical third parties regime and in Australia’s scam liability framework: the rule reaches the licensed entity, the economics sit one step outside it.

“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.”

— Therese Chambers, joint executive director of enforcement and market oversight, Financial Conduct Authority (FCA press release, August 26, 2026)

The penalty arithmetic, and the £25.2 million it does not touch

Both penalties were built under the five-step framework in DEPP 6.5B. Step 1 is disgorgement, and in both notices it is £0: the FCA “has not identified any financial benefit” that either man derived directly from the breaches. Step 2 takes a percentage of relevant income — the gross benefits from the employment in which the breach occurred. Nagy’s, for November 2015 to April 2020, was £290,043 at level 5 seriousness (40%), giving £116,017.20. Maraj’s, for June 2016 to November 2020, was higher at £387,522.76 but set at level 4 (30%), giving £116,256.83. At Step 2 the two sit within £240 of each other. The divergence comes at Step 4, where the FCA applied a deterrence multiplier of four to Nagy and 1.5 to Maraj, on the ground that each had received “substantial financial benefits from other Dolfin Group companies in addition to his relevant income”. A 30% Stage 1 discount produced £324,800 and £122,000.

The structural point sits inside that sentence. The FCA acknowledged, in the paragraph justifying the uplift, that both men received money from Dolfin Group companies beyond the salary its penalty is anchored to — then anchored the penalty to the salary anyway, because DEPP 6.5B.2G defines relevant income that way and Step 1 requires benefit traced directly to the breach. The £25.2 million was “dispersed amongst individuals and corporate entities connected to Mr Nagy and another individual”, and none is recovered here. Combined fines of £446,800 equal 1.8% of it, about £4,500 per visa.

Whether that is a failure depends on what enforcement is for. Prohibition, not the fine, is the operative sanction: both men are permanently excluded from any function at any authorised firm, which is what a regulator can deliver against a person whose firm is in administration. Recovery of the profit was never the FCA’s remit; confiscation sits with prosecutors, and the Home Office has pursued the beneficiaries directly, refusing leave to remain and indefinite leave to remain to many scheme clients after it closed the Tier 1 (Investor) route on February 17, 2022. The proportions here are typical: of the 14 fines the FCA published in 2026 to September 2, 12 fell on individuals, but those 12 accounted for £4.62 million of the £17.96 million total, on our count of the 2026 fines table. Individual enforcement is frequent and small.

What this means for compliance and legal teams

For UK-regulated brokers and wealth managers, the operative finding is not the visa scheme but Principle 11. The FCA found Nagy reckless or negligent in failing to notify it that Dolfin was launching a high-risk new service — an obligation easy to under-weight when a product is profitable and its legal characterisation is contested internally. If a desk is calling something a “grey area product” in writing, the notification test is met.

Second, instructing external counsel is not a defence if the instruction is incomplete. The FCA treated the procurement of immigration advice on inaccurate facts, then shared under limited waiver of privilege, as concealment rather than good faith. Firms relying on external opinions in a regulator conversation should assume the instructions themselves will be read against the advice.

Third, introducer economics deserve the same scrutiny as client economics. Immigration agents took typically £100,000 to £110,000 per client out of the £400,000 fee, and the FCA found Nagy took false comfort from one agent’s status as a regulated immigration adviser while it stood to gain from the volume it introduced. A regulated counterparty with a conflicted incentive is not an independent check.

Fourth, staff escalation creates a record. Three resignations over a revenue line’s legality appear in the Final Notice as evidence that concerns were raised and overridden — the objection becomes the regulator’s timeline. Expect internal dissent to carry the weight this desk saw in the CFTC’s Perez order and FinCEN’s $125 million UBS order.

“It is entirely commonplace for investors, lenders, founders or associated commercial participants to receive information about a company’s performance, participate in strategic discussions or comment on business proposals without exercising executive authority over a company’s operations.”

— Roman Joukovski, co-founder, Dolfin Financial (UK) Limited, in written representations recorded in his Decision Notice, which he has referred to the Upper Tribunal and which has no effect pending that determination (FCA Decision Notice, June 30, 2026)

What is next: the Tribunal, and what it can change

Mr Joukovski’s reference is the live question. The FCA’s provisional case is that he was a shadow director of Dolfin without approval and a controller without notification under section 422 FSMA, despite never being registered as a director at Companies House. His representations rely on Secretary of State for Trade and Industry v Deverell [2001] Ch 340, which requires the board be “accustomed to act on the directions or instructions of the shadow director”, and argue that no contemporaneous document shows Dolfin’s directors habitually acting on his instructions. The FCA answers that the test “may properly be satisfied by a combination of documentary and other evidence and appropriate inference”. That is a real dispute about the evidential threshold for shadow directorship, and the reason no precedent on it exists yet.

The timetable is the other unknown. The nearest comparator is Jes Staley: Decision Notice in October 2023, an Upper Tribunal decision dismissing the reference on June 26, 2025, Final Notice on July 23, 2025 — roughly 21 months, and the Tribunal cut the penalty from £1.8 million to £1.1 million for a reason specific to Barclays’ deferred shares rather than the merits. On that pace, a determination for Mr Joukovski would not be expected before 2028. Until then the FCA’s account of who designed the visa loan business is contested, and the two settled notices — which attribute a leading role to Nagy alongside “another individual” — carry findings no Tribunal has tested. Dolfin’s special administration, opened June 30, 2021, also remains ongoing.

FAQ

What was the Dolfin visa loan business?

A service Dolfin Financial (UK) Limited offered to foreign nationals applying for a UK Tier 1 (Investor) visa between 2016 and 2019, where the Immigration Rules required a £2 million investment of the applicant’s own money. Under the most-used “Gold” option the applicant paid £400,000 as a fee, and Dolfin-connected companies circulated the remaining £1.6 million through the applicant’s account to create the appearance of a £2 million purchase of bonds issued by Dolfin-connected companies.

Why were the individuals fined rather than the firm?

Dolfin entered special administration on June 30, 2021, after the FCA restricted its regulated activities that March, and the insolvency remains open. A penalty on an insolvent firm competes with client and creditor claims. Sections 56 and 66 FSMA attach to the individual rather than to the firm’s permission, so prohibitions and personal penalties survive the firm’s failure — which is why individual accountability regimes matter most in exactly this situation.

What does the 30% Stage 1 discount mean?

Under DEPP 6.7, an individual who agrees the penalty and other terms at the earliest stage of the FCA’s executive settlement procedures receives a 30% reduction on the Step 4 figure. Nagy’s Step 4 figure was £464,068.80, discounted to £324,800; Maraj’s was £174,385.25, discounted to £122,000. The discount does not apply to any Step 1 disgorgement, which was £0 in both cases, so here it reduced the entire penalty.

Why is Nagy’s fine larger when Maraj earned more?

Because the Step 2 percentage and the Step 4 deterrence multiplier differ. Nagy’s relevant income was £290,043 assessed at level 5 seriousness (40%); Maraj’s was £387,522.76 at level 4 (30%). Those produce almost identical Step 2 figures, £116,017.20 and £116,256.83. The FCA then applied a deterrence multiplier of four to Nagy, reflecting his leading role, and 1.5 to Maraj, whom it accepted benefited to a lesser extent.

Is Roman Joukovski banned?

No. The FCA has issued a Decision Notice proposing a prohibition, and Mr Joukovski has referred it to the Upper Tribunal. The FCA states that the findings in that notice “are therefore provisional” and that the proposed action “will have no effect pending the determination of the reference by the Tribunal”. He is contesting the FCA’s case that he acted as a shadow director and was a controller of Dolfin. No penalty was proposed against him.

What should a UK compliance function take from these notices?

Three things. Principle 11 notification of a high-risk new service is a live obligation, and internal language such as “grey area product” is itself evidence the threshold is met. External legal advice procured on incomplete instructions is treated as concealment, not mitigation. And introducer due diligence must record the enquiry actually made, because a counterparty’s regulated status does not cure its conflict of interest. Compare our analysis of CP26/23 and non-UK client perimeters.

Image: The Rolls Building, Royal Courts of Justice, London, by Roger Green, via Wikimedia Commons (CC BY-SA 4.0).

This article is informational analysis only and does not constitute legal, regulatory, tax, or investment advice. Regulatory frameworks change frequently and interpretation depends on facts and circumstances; primary documents and official regulator guidance always supersede summaries. Firms should consult qualified legal counsel and their relevant supervisory authority before taking any action based on the analysis above.