FCA Bans Former Wealth Managers: What the £35.5m Visa Scheme Says About Fitness and Propriety

The Financial Conduct Authority has banned two former senior figures at Dolfin Financial (UK) Limited and decided to ban a third after finding that they were involved in a scheme designed to help clients bypass UK investor visa requirements.

The FCA said the scheme enabled at least 99 individuals to obtain investor visas and generated at least £35.5 million in fees for Dolfin-connected businesses and immigration agents.

Former chief executive Denisz Nagy has been fined £324,800 and former finance director Sanjay Maraj £122,000. Both have also been prohibited from working in financial services.

The FCA has separately decided to ban Dolfin co-founder Roman Joukovski. He has referred the matter to the Upper Tribunal, meaning the findings concerning him remain provisional pending determination of that reference.

For regulated firms, the case is particularly relevant because the FCA concluded that the individuals lacked integrity and were not fit and proper to work in financial services.

That reinforces why fitness and propriety assessments should look beyond qualifications and technical experience to consider regulatory history, conduct and other information relevant to a senior or controlled appointment.

What Did the FCA Find?

According to the FCA, the scheme operated between 2016 and 2019.

At the time, individuals seeking a Tier 1 investor visa were generally required to invest £2 million of their own money in qualifying UK investments.

The FCA found that most clients using the Dolfin scheme instead paid a fee of £400,000.

It said the arrangements were deliberately structured to create the false impression that the required £2 million investment had been made.

The regulator found that Nagy and Joukovski played leading roles in creating and operating the scheme, while Maraj was responsible for its financial aspects once established.

The FCA also found that Nagy and Maraj deliberately concealed the true nature of the scheme from the FCA and Home Office.

In relation to Joukovski, the FCA said it found that he concealed his involvement with Dolfin and the scheme and acted as a shadow director without FCA approval. As noted above, those findings are provisional while his Upper Tribunal reference is ongoing.

The FCA's enforcement record for 2026 describes the action against Nagy and Maraj as involving failures of integrity, openness and co-operation, alongside fitness and propriety concerns.

Why Integrity Matters in Regulated Appointments

Financial services recruitment is not simply about whether a candidate has the experience to perform a role.

For relevant positions, firms also need to consider whether the individual is fit and proper to carry out their responsibilities.

The FCA's principal fitness and propriety considerations include:

• Honesty, integrity and reputation.
• Competence and capability.
• Financial soundness.

These areas require different forms of assessment.

A candidate may have extensive technical expertise while still having regulatory, conduct or reputational history that warrants further consideration.

Similarly, the absence of an obvious adverse finding does not remove the need for proportionate verification where the role carries significant regulatory responsibility.

Conflict International's SMCR Screening & FCA Vetting Services support regulated firms with background screening for Senior Managers, Certification staff and other relevant appointments.

Regulatory History Should Be Independently Checked

One of the most important elements of regulated screening is establishing a candidate's previous regulatory and professional history.

Depending on the role and circumstances, relevant checks may include:

• Previous FCA registration or controlled functions.
• Regulatory enforcement or disciplinary action.
• Regulatory references.
• Employment history.
• Directorships and corporate interests.
• Relevant litigation or insolvency records.
• Sanctions and watchlists.
• Appropriate adverse-media research.

The purpose is not to treat every historic issue as evidence that somebody is unsuitable.

Context matters.

An allegation, historic dispute or company association should not automatically determine an employment decision. Equally, material regulatory information should not be ignored simply because a candidate otherwise presents a strong professional profile.

The employing firm remains responsible for assessing the relevance of any findings to the particular function.

Regulatory References Are Different From Conventional References

For relevant SMCR appointments, regulatory references can be particularly important.

They serve a different purpose from a standard employment reference.

Rather than simply confirming dates of employment and job title, regulatory references can provide information required under FCA rules concerning conduct, disciplinary matters or previous fitness and propriety concerns.

Firms must take reasonable steps to obtain appropriate regulatory references from relevant previous employers covering the required period.

However, regulatory references should form part of a wider assessment rather than being considered in isolation.

Independent employment verification, public-record checks and other role-appropriate screening can provide additional context where necessary.

Our guide, What is SMCR Screening? Your Complete Guide to FCA Vetting, explains the wider framework for regulated screening and fitness and propriety assessments.

Senior Appointments Can Require Wider Background Verification

The more senior the appointment, the greater the potential impact of an inaccurate or incomplete assessment.

Senior individuals may control significant financial resources, influence organisational culture, deal directly with regulators and make decisions affecting customers and markets.

A proportionate screening programme may therefore extend beyond basic identity, employment and qualification checks.

Depending on the position, firms may consider relevant:

• Corporate interests and directorships.
• Regulatory history.
• Financial information.
• Criminal-record checks where lawful and appropriate.
• Professional qualifications.
• International employment history.
• Relevant public-record information.
• Online and reputational information.

The scope should always reflect the responsibilities of the role.

Applying the same screening package indiscriminately to every employee can create unnecessary checks without necessarily improving the quality of the assessment.

Fitness and Propriety Is Not a One-Off Exercise

Another important aspect of SMCR is that fitness and propriety does not necessarily end when an individual is appointed.

Certification staff must be assessed as fit and proper at least annually.

Changes in role, new responsibilities or newly identified relevant information may also require firms to reconsider whether additional verification is appropriate.

This does not mean employers should continuously investigate employees without cause.

Any repeat screening should remain necessary, lawful and proportionate to the individual's responsibilities.

The objective is to ensure that material information relevant to a regulated function is considered when required, rather than treating the original pre-employment screening exercise as permanently conclusive.

Screening Supports the Decision — It Does Not Make It

Background screening is one component of the fitness and propriety process.

It can help establish factual information, identify discrepancies and bring relevant regulatory or professional history to the attention of the hiring firm.

It cannot decide whether somebody is fit and proper.

That judgement remains with the regulated firm, taking account of the individual's role, the information identified and the applicable FCA requirements.

This distinction is important.

Effective screening should provide decision-makers with reliable information rather than attempt to substitute an automated or predetermined judgement for the firm's own regulatory responsibilities.

Strengthening SMCR and FCA Vetting

The FCA's action concerning the former Dolfin senior figures is a particularly clear reminder of the importance regulators place on integrity in financial services.

For firms recruiting Senior Managers, Certification staff or other regulated personnel, technical capability should therefore be assessed alongside appropriate verification of regulatory, professional and personal history.

Conflict International provides UK and international Pre-Employment Screening Services, including specialist support for regulated financial-services appointments.

Our screening programmes can combine regulatory references with identity, employment, qualification, financial, criminal-record and other relevant checks according to the role and the firm's requirements.

If your organisation requires screening for a senior or regulated financial-services appointment, contact Conflict International to discuss an appropriate SMCR and FCA vetting programme.