The UK Financial Conduct Authority (FCA) has banned three former senior executives of Dolfin Financial (UK) Limited over a scheme that enabled wealthy clients to circumvent the country’s investor visa requirements.

The regulator said the scheme operated between 2016 and 2019 and allowed clients to obtain UK investor visas without making the required £2 million investment in British companies. Instead, most participants paid a fee of £400,000, with the arrangement designed to create the appearance that the official investment threshold had been met. According to the FCA, at least 99 people obtained investor visas through the scheme, generating at least £35.5 million in fees for businesses connected to Dolfin and the immigration agents who referred clients.

Former Dolfin chief executive Denisz Nagy was fined £324,800 and prohibited from performing regulated financial functions. Former finance director Sanjay Maraj received a £122,000 fine and a similar prohibition. Both agreed to settle the FCA’s findings. Dolfin co-founder Roman Joukovski has also been banned from working in financial services. However, he has referred the FCA’s decision to the Upper Tribunal, meaning the findings against him remain provisional until the tribunal reaches a decision.

The FCA said Nagy and Joukovski played leading roles in establishing and operating the scheme, while Maraj was responsible for its financial arrangements. The regulator also found that Nagy and Maraj concealed the scheme’s true nature from both the FCA and the Home Office.