Decision

Charity Inquiry: Centre for Skills Enhancement Limited

Published 29 June 2026

Applies to England and Wales

The charity

Centre for Skills Enhancement Ltd (‘the charity’), subsequently known as Swift Messengers Gospel Centre (company number 05017522) ^{[footnote 1]}, is a charitable company governed by a memorandum and articles of association.  It was incorporated on 16 January 2004 and had been registered with the Charity Commission (‘the Commission’) since 6 April 2006.

The charity’s objects are:

• the advancement of Christian faith
• the relief of sickness and the preservation and protection of physical and mental health of those who confess Jesus Christ as their lord and saviour
• the relief of poverty
• the advancement of education

The charity’s entry can be found on the Register of Charities (‘the Register’).

Background and issues under investigation

On 13 September 2022, the Commission reviewed the charity after concerns were raised about its banking arrangements, and the fact that it was operating with only one trustee. Further checks showed that the charity shared a number of similar regulatory concerns with another charity, Jesus Power House Ministries Ltd 1128363 (a separate statutory inquiry was opened into this charity on 16 June 2023). Both charities had the same sole trustee, used the same address, and were operating with fewer trustees than required by their respective governing documents. Both charities had also submitted accounts to the Commission that failed to meet the requirements of the Charities Statement of Recommended Practice (‘SORP’).

On 16 June 2023 the Commission opened a statutory inquiry into the charity under section 46 of the Charities Act 2011 (‘the Act’).

The inquiry examined:

• the extent to which the charity’s trustees have and are complying with their legal duties in respect of the administration, governance and management of the charity, with particular regard to the
  • management of the charity’s finances and unauthorised trustee and related party benefits
  • whether the charity is accurately accounting for its funds and assets in accordance with legal requirements
  • whether the charity’s objects are being met and the charity is operating for the public benefit
  • whether there has been any misconduct and/or mismanagement by the trustees and consider whether remedial regulatory action is necessary.

The inquiry closed with the publication of this report.

Findings

The trustees’ compliance with their legal duties in respect of the administration, governance and management of the charity

The Commission’s guidance The essential trustee: what you need to know (CC3) sets out the key duties of all trustees of charities in England and Wales, and what trustees need to do to carry out these duties competently.

The charity’s governing document requires a minimum of three trustees. However, Mrs Onyekachi Anyanwu (‘the trustee’) confirmed, in response to the Commission’s enquiries both in writing and verbally, that she acted as the sole trustee for extended periods, including between 2013 and 2021, and again from March 2022 until September 2023.

The governing document stipulates that decisions must be taken by a quorum of at least one third of the trustees or by a minimum of two trustees, whichever is greater. It also provides that where trustee numbers fall below three, the remaining trustee(s) may act only to appoint new trustees or to call a general meeting. Decisions taken by the trustee alone were therefore taken in breach of the charity’s governing document as a quorum could not be reached and were invalid. This is misconduct and/or mismanagement in the administration of the charity.

During a books and records inspection (‘the inspection’), the inquiry was unable to locate any documentary evidence, such as trustee meeting minutes, appointment letters, resignation letters or signed declarations of trustee eligibility, to demonstrate that any other individuals were properly appointed and exercised trustee functions between 2021 and March 2022.

Although other individuals were listed as trustees on the Register and at Companies House between 2013 and 2021, the trustee stated that she acted as the sole trustee, and the inquiry found no evidence to contradict the trustee’s account. The discrepancies between the charity’s actual governance arrangements and the information recorded on the Register and at Companies House indicate that the trustee failed to accurately record, manage and report trustee appointments and resignations. Also, the charity had changed its name on 21 November 2006, which was correctly recorded at Companies House, but not updated on the Commissions register. This is misconduct and/or mismanagement in the administration of the charity.

The trustee failed to take appropriate and timely steps to fill trustee vacancies and failed to ensure that accurate and up‑to‑date trustee information was provided to the Commission and Companies House. Maintaining correct trustee records, ensure the charity is accountable and is a fundamental responsibility of the trustees. These failures are misconduct and/or mismanagement in the administration of the charity.

Following the opening of the inquiry, and after engagement by the Commission, two more trustees (‘the trustees’) were appointed in September 2023.

Management of the charity’s finances, unauthorised trustee and related party benefits and whether the charity is accurately accounting for its funding and assets in accordance with legal requirements

Trustees have a legal duty to manage their charity’s resources responsibly and act with reasonable care and skill. Trustees must, among other things:

• make sure the charity’s assets are only used to support or carry out its purposes
• avoid exposing the charity’s assets, beneficiaries or reputation to undue risk
• take special care when investing or borrowing

The inquiry found that the trustees failed to manage the charity and its resources responsibly.

Charitable expenditure

The inquiry found that a total of £489,797.50 of charitable funds were transferred into the personal bank accounts of the trustee and her husband. When directed on 9 January 2024 under section 47 of the Act to explain these payments, the trustees failed to respond by the required deadline. This failure to comply with a statutory direction is misconduct and/or mismanagement in the administration of the charity.

In a later response, the trustee said that these funds were to support projects in Nigeria but were transferred into personal bank accounts rather than being paid directly to suppliers. When asked to explain this approach, the trustee stated there was “no particular reason”.  The inquiry concluded that the transfer of substantial charitable funds into personal bank accounts, in the absence of any clear rationale, exposed the charity’s funds to undue risk, demonstrates poor decision making and a failure to act in the charity’s best interests. This is misconduct and/or mismanagement in the administration of the charity.

Whilst 65% of this expenditure was accounted for, further enquiries found that £172,256.80 of charitable expenditure paid to the trustee and her husband remained unexplained as no supporting evidence was provided to demonstrate that the funds had been applied for the charity’s purposes. Trustees are required to protect charitable funds and act with reasonable skill and care. The failure to do so exposed the charity to significant financial and reputational risk. This is a breach of trustee duties and is misconduct and/or mismanagement in the administration of the charity.

Additionally, during the inspection, a substantial number of receipts were found to have been altered. The trustee stated this had been done to record expenditure in a different accounting year. Altering original financial documents is a serious breach of proper accounting practice and undermines the transparency and reliability of the charity’s records. Such actions fall below the standards expected of trustees and is misconduct and/or mismanagement in the administration of the charity.

Investments

The inquiry identified eight payments totalling £9,831 to company A in April 2020, which the trustee informed us were investments. These investments were undertaken without proper due diligence or a risk assessment by the trustee and failed to provide any return for the charity. Furthermore, these investments were not disclosed in the charity’s accounts for the financial year end (‘FYE’) 31 December 2020. Trustees must make informed decisions in the best interests of the charity and should not expose the charity to undue financial risk. The trustee explained she made the decision to invest in company A following advice from ‘friends’ and would not elaborate further. The trustee further explained she could not recover the funds despite requesting them back from company A. The trustee failed to meet her legal duties by not undertaking proper due diligence on company A before investing the charity’s money, including failing to carry out a proper risk assessment. The trustee also acted in breach of the governing document by making the decision to invest whilst the charity was inquorate. This is misconduct and/or mismanagement in the administration of the charity.

A charity’s accounts must detail the accounting policies for investments, including the basis on which investments are measured. They must also state the amounts held or expended on investments.  Neither requirement was met in the accounts. This is misconduct and/or mismanagement in the administration of the charity.

The charity received a £50,000 Bounce Back Loan on 30 September 2020. There was no evidence that the trustee properly considered the decision to borrow these funds, including any assessment of affordability, whether the loan was required, the charity’s ability to repay the loan, or whether taking on debt was in the charity’s best interests. The loan was also not recorded in the charity’s accounts for FYE 31 December 2020 or for FYE 31 December 2021, contrary to accounting requirements. While defaulting on a loan is not in itself misconduct and/or mismanagement, the failure to follow proper decision‑making processes, maintain adequate financial records, and comply with statutory accounting duties is misconduct and/or mismanagement in the administration of the charity. Furthermore, this led to the bank closing the charity’s bank account and initiating restitution proceedings against the signatories to the account.

Failure to comply with accounting requirements

Charities must keep proper accounting records and prepare annual accounts that can be provided to the public on request. Where a charity’s gross income exceeds £10,000 per year, the trustees must submit an annual return to the Commission. Where gross income exceeds £25,000, the trustees must also submit a copy of the charity’s accounts and trustees’ annual report. These documents must be filed within 10 months of the end of the charity’s financial year. Failure to comply with these statutory reporting requirements may be a criminal offence. Trustees are required to ensure that their charity is accountable. A key element of this is meeting the legal accounting and reporting requirements.

The charity’s previous accountant (‘the previous accountant’) produced the accounts for FYE 31 December 2013 to FYE 31 December 2021. Throughout this nine‑year period, the accounts consistently failed to comply with SORP, indicating sustained shortcomings in the quality of the accountant’s work. The inquiry examined the circumstances of his appointment and found that the trustee had not carried out basic due diligence before engaging him. She relied solely on his assertion that he was an accountant and did not check whether he held relevant qualifications, was acting through a recognised accountancy practice, or possessed the necessary competence to undertake the role. The inquiry was unable to identify any record confirming his qualifications or professional affiliation. This demonstrates a failure of governance and decision making by the trustee in this appointment, which resulted in the charity failing to account for its use of charitable funds for many years.

Significant charity records were given to the previous accountant in order for them to produce the accounts, however they subsequently died and the trustee was unable to retrieve the charity’s records. The Commission also requested the location of the records from the trustees in an attempt to obtain them for the purposes of the inquiry. These details were not provided. The lack of records made it challenging for the new accountant to produce the outstanding accounts.

The decision to appoint the previous accountant was reckless and not in the charity’s best interests and is misconduct and/or mismanagement in the administration of the charity by the trustee.

The trustees appointed a new accountant to produce their accounts and on 23 September 2024, they submitted the long‑overdue accounts for the FYE 31 December 2022. However, despite having previously been told these must be compliant with SORP, they were not. The inquiry found that the accounts for FYE 31 December 2022 did not include the required independent examiner’s report.

Accounts for charities with an income over £25,000 must be independently examined by an independent examiner or audited by a person meeting the requirements within section 144(2) (a) or (b) of the Act. The inquiry found the accounts also did not properly record outstanding debts or related‑party transactions. This is misconduct and/or mismanagement in the administration of the charity.

Note 29 of the accounts for FYE 31 December 2022 also highlighted weaknesses in the trustees’ governance and record keeping. Note 29 reported that no receipts were provided evidencing expenditure, some invoices were unclear or missing essential detail, and in some cases only basic Microsoft Word documents listing expenses were supplied to the accountant.

The failure to submit the accounts on time or meet basic accounting requirements is misconduct and/or mismanagement in the administration of the charity.

The inquiry also found that while the accounts and trustee annual report were not required for FYE 31 December 2023 due to amount of income and expenditure for that year, the trustees failed to submit the required annual return. This is misconduct and/or mismanagement in the administration of the charity.

Whether the charity’s objects were being met and the charity was operating for the public benefit

The inquiry considered whether the charity was carrying out activities in furtherance of its objects and operating for the public benefit. While some records were provided, indicating that the charity may have furthered its objects, at an earlier stage, the inquiry found that the charity had ceased to operate for a significant period.

The trustee confirmed, in response to the Commission’s enquiries, that the charity was no longer active. Furthermore, the trustee confirmed that when the charity operated, it relied entirely on a separate charity, Jesus Power House Ministries Ltd, for premises, funds and volunteers. The trustee was also the sole trustee for Jesus Power House Ministries Ltd, often making it difficult to distinguish the charity’s activities from those of the other charity. As a result, the inquiry was not satisfied that the charity was furthering its own objects from late 2022 onwards.

A charity that has ceased to operate will, by its nature, not be furthering its objects or providing public benefit. This position is not, of itself, necessarily a concern. However, trustees are required to ensure that, where a charity is no longer operating, its affairs are properly managed, and appropriate steps are taken to address its future. The inquiry found that the trustees failed to take such steps.

The trustees failed to maintain adequate records demonstrating how and when the charity ceased to operate, failed to keep its accounting and regulatory information up to date, and failed to dissolve the charity in line with its governing document once it was no longer operational.

These failures, along with the fact the charity remained on the Register despite not operating, is misconduct and/or mismanagement in the administration of the charity. Subsequently, the charity was removed from the Register on 9 October 2025.

Conclusions

The inquiry concluded that there had been serious and sustained misconduct and/or mismanagement in the administration of the charity.

The inquiry found that the charity operated for extended periods without the minimum number of trustees required by its governing document. The trustee acted as the sole trustee for significant periods and took decisions while the charity was inquorate, rendering those decisions invalid. The failure to appoint sufficient trustees where required, combined with inaccurate and inadequate records demonstrates longstanding governance failures and is misconduct and/or mismanagement in the administration of the charity.

The inquiry further concluded that the trustee failed to manage the charity’s finances responsibly. Significant charitable funds were transferred into the personal bank accounts of the trustee and her husband without adequate authorisation, justification, or supporting evidence. A substantial proportion of this expenditure remained unexplained. The alteration of financial records and failure to accurately account for income, expenditure, investments, liabilities, and related‑party transactions undermined the transparency and reliability of the charity’s financial records and exposed charitable funds to undue risk. This is misconduct and/or mismanagement in the administration of the charity.

The inquiry concluded that the trustee failed to comply with fundamental accounting and reporting requirements over a prolonged period. Accounts were repeatedly non‑compliant with SORP, submitted late, or not submitted at all. The appointment of an accountant without carrying out any due diligence as to qualifications, professional status or competence, the loss of financial records, and the submission of incomplete and inaccurate accounts demonstrate a sustained failure to ensure the charity was properly accountable.

In relation to the charity’s financial position, the inquiry found that the trustees failed to properly understand or manage the charity’s solvency. Borrowing was undertaken without appropriate consideration of affordability or risk, liabilities were not accurately recorded in the charity accounts, and the charity was not dissolved once it was no longer operational. The trustees failed to take reasonable steps to manage the charity’s position, protect its charitable funds, or address its liabilities. This is misconduct and/or mismanagement in the administration of the charity.

The inquiry further found that the charity was wholly reliant on a separate charity for its activities and resources. There was a clear absence of effective governance, or independence from the other charity and the trustees failed to properly manage the charity’s affairs.

Collectively, these governance, financial, and regulatory failures demonstrate serious and persistent misconduct and/or mismanagement. They led to the Commission’s regulatory intervention, the suspension and removal of the trustee in another charity, and ultimately to the removal of the charity from the Register.

Regulatory action taken

On 4 September 2023, the inquiry made an order not to part with charitable property, under section 76(3)(d) of the Act, the impact of which was to freeze the charity’s bank account. The charity’s bank account was subsequently closed in March 2024.
The inquiry exercised its powers under sections 47(2)(a) and (b) of the Act on several occasions to obtain information and documentation from the trustees and a range of third parties.

On 26 June 2024, the inquiry exercised its powers under section 47(2)(c) of the Act to direct the trustees in post at the time to appear before the inquiry to answer questions relating to its inquiry.

On 15 January 2025, the inquiry exercised its powers under section 76(3)(a) of the Act to suspend the trustee from office pending consideration being given to their removal under s79 of the Act. The trustee was also suspended from the charity Jesus Power House Ministries Ltd.

On 19 May 2025, the inquiry exercised its powers under section 79(4) of the Act to remove the trustee from the position of trustee of Jesus Power House Ministries Ltd.  As a consequence, she is disqualified from acting as a trustee of, and from holding a senior management position with, this and any other charity.

The charity was removed from the Register on 9 October 2025 and Companies House was notified of our action.

Issues for the wider sector

Trustees are representatives of the charity they govern or the charitable funds they are responsible for. Trustees must be aware of and act in accordance with their legal duties. The conduct of trustees can be a key driver of public trust and confidence in the charity sector. When the conduct of trustees falls below the standards expected there can be damage to the reputation of individual trustees, the charity and possibly the wider charity sector.

In terms of decision making, trustees must:

• act within their powers
• act in good faith and only in the interests of the charity
• make sure they are sufficiently informed
• take account of all relevant factors
• ignore any irrelevant factors
• manage conflicts of interest
• make decisions that are within the range of decisions that a reasonable trustee body could make

It is important that charity trustees apply these 7 principles when making significant or strategic decisions, such as those affecting the charity’s beneficiaries, assets or future direction, and record their decision-making appropriately. Read the Commission’s guidance on trustees duties.

All charities must have an effective trustee body to control and administer the charity in accordance with its governing document, charity law and Commission guidance. Public trust and confidence depend on trustees acting properly and protecting the charity’s funds while pursuing its objects and activities.

Trustees have a legal duty to ensure that charitable funds are applied solely and reasonably in furtherance of the charity’s purposes. They are legally responsible and publicly accountable for protecting the charity, its property, funds and beneficiaries, and for ensuring that resources are used only for legitimate charitable purposes.

Due diligence is an important part of trustee duties and is essential in order to be assured of the provenance of charitable funds and confident that they know the people and organisations the charity works with and can identify and manage associated risks. It is vital that trustees have robust due diligence processes and ensure that these are consistently implemented.

Monitoring is a vital step in ensuring that a charity’s funds or property reach their proper destination and are used how the charity intended. The type and depth of monitoring may vary depending on the type of project, the location and the sums of money involved. It is vital that trustees have robust monitoring process in place including documentation such as verified reports, receipts and invoices.

Read the Commission’s guidance on due diligence, monitoring and verifying the end use of funds.

1. On 21 November 2006 the charity changed its name on Companies House to Swift Messenger Gospel Centre. However, the charity never informed the Commission of the name change or updated its name on the Commission’s Register of Charities. ↩