The FCA has announced a ban and fine for three wealth managers due to their reported involvement in a scheme helping clients bypass UK visa rules.
The FCA found that former Dolfin wealth managers Denisz Nagy, Roman Joukovski and Sanjay Maraj lacked integrity and were not fit and proper to work in financial services.
Mr Joukovski has appealed his ban to the Upper Tribunal so the punishment applied to him is provisional.
Between 2016 and 2019, the former Dolfin Financial (UK) Ltd (FRN 552894) wealth managers offered clients a scheme designed to create the false impression that visa requirements to enter and live in the UK had been met, allowing clients to pay 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 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.
According to FCA records, 93 people were recorded as regulated individuals at the firm.
The FCA found that former Dolfin chief executive Denisz Nagy and co-founder Roman Joukovski played leading roles in creating and operating the scheme, while former finance director Sanjay Maraj was responsible for the financial aspects.
All three have been banned from working in financial services. Former chief executive Denisz Nagy has been fined £324,800 and former finance director Sanjay Maraj £122,000 for their roles in the scheme.
Dolfin was placed into special administration in June 2021 and is now going through an insolvency process. The firm offered investment management, advisory, execution-only and custody services to overseas investors.
Most customers of Dolfin were transferred to Britannia Financial Group in July 2021.
The FSCS has yet to accept claims from clients of the failed firm but is aware of the business.
The FCA said Mr Nagy and Mr Maraj deliberately concealed the scheme's true nature from the FCA and the Home Office. The FCA found that Mr Joukovski deliberately concealed from the regulator both his involvement in 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.
Mr Joukovski has referred his Decision Notice to the Upper Tribunal where he and the FCA will present their cases. The proposed action outlined in his notice will be provisional until a decision is made by the Tribunal whose decision will be made public on its website, the FCA said.
Mr Nagy agreed to settle his fine with the FCA and received a 30% discount. Without the discount, the penalty would have been £464,000.
Mr Maraj also agreed to settle and received a 30% discount. Without the discount, the penalty would have been £174,300.
The Home Office has acted against many of the Dolfin clients that used the scheme by refusing their applications for leave to remain and indefinite leave to remain in the UK. It closed the Tier 1 investor visa route of entry to the UK from February 2022.