Decision

Charity Inquiry: Kantor Foundation and Kantor Charitable Foundation

Published 22 April 2026

Applies to England and Wales

The charities

Kantor Foundation (‘KF’) and Kantor Charitable Foundation (‘KCF’) were registered with the Commission as separate charities on 26 June 2017 and were governed by trust deeds. 

The objects of KF and KCF were:

“The trustee shall hold the capital and income of the trust fund upon trust to apply the income, and all or such part of parts of the capital, at such time or times and in such manner to or for the benefit of such exclusively charitable objects and purposes in any part of the world as the trustee may in its discretion think fit.”

KF and KCF furthered their objects by providing grants for exclusively charitable purposes.

From their inception to July 2024, the sole trustee of KF and KCF was Kantor Trustees, a private limited company. On 30 July 2024, Kantor Trustees ceased to exist following its compulsory strike-off by Companies House.

Dr Vitacheslav Kantor (‘Dr Kantor’) was a director of Kantor Trustees from 25 January 2017 until 30 May 2022. Although there were other directors of Kantor Trustees, Dr Kantor was its sole member and was registered at Companies House as the only person with significant control of the company, having 75% or more of the voting rights and the power to appoint and remove directors. In practice, this meant Dr Kantor exercised control over Kantor Trustees, and by extension, over KF and KCF.

KF and KCF ceased to exist following their dissolution and they were both removed from the Register of Charities on 30 May 2025.

Background and Issues under Investigation

His Majesty’s Treasury’s (‘HMT’) Office for Financial Sanctions Implementation (‘OFSI’) is the authority responsible for ensuring financial sanctions are properly understood, implemented, and enforced in the United Kingdom. Financial sanctions include restrictions on designated persons, such as freezing their financial assets, as well as wider restrictions on investment and financial services.

On 6 April 2022, Dr Kantor was named as a ‘designated person’ for the purposes of the Russia (Sanctions) (EU Exit) Regulations 2019 (S.I. 2019/855) (the ‘Russia Regulations 2019’).

The Russia Regulations 2019 were made under the Sanctions and Anti-Money Laundering Act 2018 (‘the Sanctions Act’). These should be considered with the Sanctions (EU Exit) (Miscellaneous Amendments) (No. 2) Regulations 2020 and the Sanctions (EU Exit) (Miscellaneous Amendments) (No. 4) Regulations 2020. The Russia Regulations 2019 enable the Secretary of State to designate a person, which can result in the freezing of funds and economic resources of certain persons, entities or bodies who are or have been involved in destabilising Ukraine or undermining or threatening the territorial integrity, sovereignty or independence of Ukraine or obtaining a benefit from or supporting the Government of Russia.

Pursuant to regulation 6(1) of the Russia Regulations 2019, the Secretary of State may not designate a person unless there are (i) reasonable grounds to suspect that a person is an “involved person”, and (ii) the designation of the person is appropriate. An “involved person” means a person who:

• is or has been involved in (i) destabilising Ukraine or undermining or threatening the territorial integrity, sovereignty, or independence of Ukraine, or (ii) obtaining a benefit from or supporting the Government of Russia
• is owned or controlled directly or indirectly by a person who is or has been so involved
• is acting on behalf of or at the direction of a person who is or has been so involved, or
• is a member of, or associated with, a person who is or has been so involved

Regulation 6(3)(a) to (g) of the Russia Regulations 2019 sets out the ways a person is involved in destabilising Ukraine or undermining or threatening the territorial integrity, sovereignty, or independence of Ukraine. Examples include providing financial services, or making available funds, economic resources, goods, or technology that could contribute to destabilising Ukraine or undermining or threatening the territorial integrity, sovereignty or independence of Ukraine and obstructing the work of international organisations in Ukraine.

By virtue of Dr Kantor’s designation, it is a criminal offence to make funds or economic resources available (directly or indirectly) to him. It is also a criminal offence for him or anyone else to deal with funds or economic resources he owns, holds or controls which effectively freezes Dr Kantor’s assets.

At the time of being designated, Dr Kantor was a director and sole member of Kantor Trustees. As such, Dr Kantor had indirect control over KF and KCF.

Considering the Commission’s regulatory concerns regarding Dr Kantor’s designation and his role at KF and KCF, the Commission opened statutory inquiries (the ‘inquiries’) into both charities on 7 April 2022 under section 46 of the Charities Act 2011 (the ‘2011 Act’). Dr Kantor and two other directors of Kantor Trustees were notified of the inquiries on the same date, and the Commission publicly announced their opening on 22 April 2022.

In deciding to open the inquiries, the Commission took into account the real risk that the assets of both KF and KCF would be subject to financial sanctions following the designation of Dr Kantor, if he remained in his position as a director of Kantor Trustees.

The scope of the inquiries were to:

• determine whether either KF or KCF could continue to operate and was viable following sanctions being imposed on Dr Kantor as one of the directors of Kantor Trustees

• consider the conduct of the trustees and whether they have discharged their legal duties and responsibilities in their management and administration of KF and KCF

After opening the inquiries, a range of the Commission’s regulatory powers were exercised. Further information is provided below under ‘Regulatory action taken’

Findings

Whether the charities could continue to operate and were viable following sanctions being imposed on Dr Kantor

The registration applications for KF and KCF, which were submitted to the Commission in January 2017, estimated that their combined gross annual income would be £2,000,000, with the principal donor being Dr Kantor. During the inquiries, it was found that Dr Kantor was in fact the sole donor to both charities.

Having exercised the Commission’s information gathering powers, the inquiries ascertained that the combined total of the charities’ assets, as of 6 April 2022, was £305,717, $100,000 USD, and €141,636 EUR. These funds were donated to the charities by Dr Kantor (prior to his designation) and were being held, in the charities’ name, by a banking institution. The inquiries further ascertained that both KF and KCF had various grant agreements in place with multiple charities, of which payments for varying amounts were due to be paid.

That said, following the designation of Dr Kantor, a number of these charities, which had grant agreements in place with KF and KCF, contacted the Commission stating that they no longer wanted to be associated with Dr Kantor and the charities. As such, they would no longer accept any further grant funding from either KF or KCF.

Under the Sanctions Act, a General Licence can be issued to allow for specified activities to be undertaken which would otherwise be prohibited by financial sanctions. On 30 May 2022, OFSI issued General Licence INT/2022/1834876 in relation to an Interim Manager, appointed by the Commission, to act as receiver and manager in respect of the property and affairs of a charity. In practice, this means an Interim Manager (appointed by the Commission) can lawfully act to apply charitable funds that are subject to financial sanctions because of the Russia Regulations 2019.

Given that Dr Kantor was the sole member of Kantor Trustees which had control over the assets of KF and KCF, the Commission was concerned about the effect of Dr Kantor’s designation on these assets, specifically whether the assets were subject to financial sanctions.

Considering Dr Kantor’s designation, as well as regulatory action taken by the Commission which resulted in Dr Kantor being unable to act as a director of Kantor Trustees (see ‘regulatory action taken’ below), the inquiries took the view that the situation could most effectively be resolved with the appointment of an Interim Manager under section 76(3)(g) of the 2011 Act. Once appointed, the Interim Manager would be able to rely on the above General Licence to take over management of KF and KCF’s funds and make an assessment of how they should be handled.

In June 2023, the inquiries concluded that KF and KCF were no longer viable and that they should be wound up and dissolved. The inquiries reached this view having taken into consideration several factors, which included:

• the reputational damage to the charities by virtue of Dr Kantor’s designation

• the charities’ inability to obtain additional funding due to the financial sanctions imposed on Dr Kantor, their sole donor

• the trustee of the charities, Kantor Trustees, being unable to act following the resignation of two of its three directors (following Dr Kantor’s designation) and action being taken by the Commission to remove Dr Kantor as trustee of and for World Holocaust Forum Foundation (‘WHFF’) under section 79(4) of the 2011 Act; and

• the inquiries judged it highly unlikely that the charities would be able to recruit suitable trustees and/ or secure funding to pursue their charitable purposes

Conduct of the trustees and whether they have discharged their legal duties and responsibilities in their management and administration of the charities

Dr Kantor

The inquiries found that the conduct of Dr Kantor, as a director of Kantor Trustees, fell below that which the Commission expects and that Dr Kantor, via Kantor Trustees, was responsible for misconduct and/ or mismanagement in the administration of KF and KCF.

The legal consequences of being designated make it, in the Commission’s view, impossible for a designated person to be a trustee (or as was the case here a director and sole member of a corporate trustee). This is because it is a criminal offence for funds or economic resources to be made available to a designated person which would include making such available to a person or company owned or controlled by a designated person.

Trustees have a legal responsibility for the administration of their charity. They are custodians of charitable funds and hold them on trust for their charity. They have control over the management and administration of the charity and therefore, its assets.

Therefore, a designated person would be unable to act in the administration of a charity without an offence being committed. If a trustee becomes designated (or a designated person has ownership or control over a corporate trustee as was the case here), the designated person must resign from their position immediately.

If a charity’s assets are subject to financial sanctions, unless licensed to do so by OFSI a person would not be able to deal with them without that being a criminal offence. Conversely, if the trustee in question did not deal with charity funds and simply left them dormant, then they would be failing to discharge their legal duties as a trustee in the management and administration of a charity. In either scenario, this amounts to misconduct and/ or mismanagement in the administration of a charity.

Despite his designation, Dr Kantor did not resign from his position as director and sole member of Kantor Trustees. Nor did he adequately respond – at the relevant time – to the Commission’s regulatory concerns about his continued involvement and role in KF and KCF. In April 2022, the Commission issued directions under section 47 of the Act requiring Kantor Trustees to provide a number of pieces of information and responses to questions, including to explain the impact of his designation on his ability to remain as a director of the trustee of KF and KCF. One response – stating only that Kantor Trustees had “no comments” on the designation of Dr Kantor – did not address the Commission’s substantive regulatory concerns about Dr Kantor.  Other responses were incomplete, even after granting an extension, and complete information was not provided until after the deadline. This was in the context of the urgency of the situation and the need for the Commission to take protective action. This was a failure to cooperate with the Commission which was misconduct and / or mismanagement for which Dr Kantor was responsible.

A charity’s reputation is a valuable asset, and forms part of its property, that trustees have a duty to safeguard. Dr Kantor’s designation negatively impacted the charities’ reputation, ability to operate and exposed it to increased risks, given his public association with activities in destabilising Ukraine or undermining or threatening the territorial integrity, sovereignty or independence of Ukraine or obtaining a benefit from or supporting the Government of Russia. Such links between a charity and a designated person erode public trust and confidence in the charity and the charitable sector as a whole.

Dr Kantor’s failure to resign and thus safeguard the reputation of KF and KCF constitutes misconduct and/ or mismanagement in the administration of both charities.

As a consequence, the Commission took action in respect of Kantor Trustees and Dr Kantor. Further information concerning this is provided below under ‘Regulatory action taken’.

Kantor Trustees’ other directors

In addition to Dr Kantor, Kantor Trustees had two other directors prior to his designation. These individuals resigned from their positions on 7 April 2022 and 26 May 2022, respectively.

Throughout the inquiry, no evidence was found to question the conduct of either director. Furthermore, there was no evidence suggesting that they failed to fulfil their legal duties and responsibilities as a director of Kantor Trustees in its role as the corporate trustee of KF and KCF.

Conclusions

Where misconduct and/ or mismanagement occurs within a charity, the Commission will ensure that those responsible are held accountable for their actions and/ or inaction. Where necessary, the Commission will take robust regulatory action to protect charitable assets and uphold public trust and confidence in charity.

The inquiries concluded that Dr Kantor, as a director of Kantor Trustees, failed to discharge his legal duties and responsibilities and was responsible for misconduct and/ or mismanagement in the administration of the charities. As a result, the Commission suspended Kantor Trustees from acting in any capacity as trustee, charity trustee, officer, agent, employee, or member of both KF and KCF.

On 30 May 2022, following regulatory action being taken by the Commission as part of a separate inquiry into the now-removed charity, WHFF, Dr Kantor became automatically disqualified from acting as a trustee of, or for, any charity in England and Wales. In accordance with Kantor Trustees’ governing document, this disqualification led to him immediately ceasing to be a director of the company. Coupled with the earlier resignations of the company’s two other directors – following Dr Kantor’s designation – this left Kantor Trustees without any directors. Further information is provided below under ‘Regulatory action taken’.

The inquiries also concluded that KF and KCF were no longer viable. Consequently, the Commission facilitated their dissolution after their remaining assets were granted to other charities for activities in line with the general objects of both charities.

Regulatory Action Taken

Information gathering powers

The inquiry exercised the Commission’s information gathering powers under sections 52 and 47 of the Act on multiple occasions both to obtain documents and answers to questions.

Freezing the charities’ assets

On 7 April 2022, the inquiry exercised the Commission’s power under section 76(3)(d) of the 2011 Act to make an order prohibiting the banking providers of KF and KCF from parting with any property held on behalf of either charity without the prior written consent of the Commission.

On 6 May 2022, the inquiry again exercised the Commission’s power under section 76(3)(d) of the 2011. This second order prohibited Kantor Trustees from parting with any property it held on behalf of either KF or KCF without the prior written consent of the Commission.

Restricting Dr Kantor from entering into transactions on the behalf of KF and KCF

On 27 April 2022, the inquiry exercised the Commission’s power under section 76(3)(f) of 2011 Act, prohibiting Dr Kantor from entering into any transaction in the administration of either KF or KCF without the Commission’s prior written consent.

Suspension of Kantor Trustees

On 23 May 2022, the inquiry exercised the Commission’s powers under section 76(3)(a) and section 83(2) of the 2011 Act to suspend Kantor Trustees from acting as trustee, charity trustees, officer, agent, employee, or member of both KF and KCF.  

On the same date, the inquiry gave statutory notice of its intention to remove Kantor Trustees as a charity trustee of KF and KCF, in accordance with the requirements of the 2011 Act.

On 25 September 2022, representations were submitted on behalf of Dr Kantor in response to why the Commission should not proceed with removing Kantor Trustees as a charity trustee of both KF and KCF.  

These representations were considered by an independent reviewer (the ‘Reviewer’) as part of the Commission’s decision review procedure. On 20 April 2023 the Reviewer concluded that although the legal test for removal under section 79(4) of the 2011 Act had been met, it was not proportionate for the Commission to proceed with the removal.

This conclusion was based on the fact that Kantor Trustees was, in effect, no longer functioning as trustee of KF or KCF. Two of its directors had resigned in April and May 2022, leaving Dr Kantor as the sole remaining director. Additionally, on 30 May 2022, Dr Kantor was removed as a trustee of and for WHFF under section 79(4) of the 2011 Act, as part of a separate inquiry into that now-removed charity.

By virtue of Kantor Trustees governing document, Dr Kantor ceased to be director of the company with immediate effect following his removal (on 30 May 2022) under section 79(4) of the 2011 Act.

As such, the Reviewer concluded that the Commission’s intention to remove Kantor Trustees – an action was taken before Dr Kantor’s disqualification – was no longer necessary or proportionate and need not be pursued. This decision represented the final decision of the Commission.

Removal under section 79(4) of the 2011 Act results in automatic disqualification from acting as a trustee or holding a senior management position in any charity in England and Wales, unless a wavier is granted by the Commission or the courts.

It is a criminal offence to act as a trustee or hold a senior management position in a charity whilst disqualified. In accordance with its obligations under section 182 of the 2011 Act, Dr Kantor’s name has been entered onto the Register of Removed Trustees.

Interim Managers

On 31 May 2022, in light of Kantor Trustees no longer being in a position to act as charity trustee of either KF or KCF, the Commission appointed Mr Tom Murdoch and Mr Tony Pidgeon of Stone King LLP as Interim Managers of both charities. The appointment was made by order under section 76(3)(g) of the Act. The scope of their appointment included assuming day-to-day management and administration of the charities, and assessing their future viability. The Interim Managers also took control of the charities’ assets, including funds held in bank accounts, and assessed how to proceed with ongoing grant obligations.

During the Interim Managers’ appointment, the inquiry exercised the Commission’s powers under sections 85 and 105 of the 2011 Act to facilitate the use of the charities’ funds and to enable the settlement of outstanding liabilities.

On 14 June 2023, following a review of the Interim Managers’ assessment of the future viability of KF and KCF, the Commission concluded that neither charity was viable. Accordingly, the Commission directed that the charities be wound up and dissolved, by way of an order under section 84B of the 2011 Act.

As part of their work, the Interim Managers ascertained that there were a number of outstanding Gift Aid claims pending to be paid by HMRC. Following consultation with HMRC, the Interim Managers secured the outstanding claims which totalled, for both charities, £1,515,807.78.

After identifying and settling the charities’ liabilities, the Interim Managers distributed charitable grants to a number of organisations, totalling £1,388,000.00.

The Interim Managers also recovered a violin – by Riccardo Antoniazzi (Milano 1912) – which had been loaned by KF to a musician in Austria. Upon recovery, the violin was gifted to a registered charity under a Deed of Gift containing terms requiring its use to promote music education for the public benefit. At the time of the original loan in 2019, the violin was valued (by KF) at £150,810.

Throughout their appointment, the Interim Managers ensured the preparation and submission of the charities’ accounts, Trustees’ Annual Reports, and annual returns.

The total cost of the Interim Managers’ appointment, including VAT and disbursements, amounted £459,211.00 and was met from the charities’ funds.

Having completed the scope of their appointment, the Interim Managers were discharged in relation to KF and KCF on 25 November 2025, by order made under section 76(6) of the 2011 Act.

Issues for the wider sector

The purpose of this section is to highlight the broader issues arising from the Commission’s assessment of the issues raised publicly that may have relevance for other charities. It is not intended as further comment on the charities in addition to the findings and conclusions set out in the earlier sections of this report but is included because of their wider applicability and interest to the charity sector.

Financial sanctions

Financial sanctions are generally imposed to:

• coerce a regime, or individuals within a regime, into changing their behaviour (or aspects of it) by increasing the cost on them to such an extent that they decide to cease the offending behaviour
• constrain a target by denying them access to key resources needed to continue their offending behaviour, including the financing of terrorism or nuclear proliferation
• signal disapproval, stigmatising and potentially isolating a regime or individual, or as a way of sending broader political messages nationally or internationally; and/or
• protect the value of assets that have been misappropriated from a country until these assets can be repatriated

Whilst the Foreign, Commonwealth and Development Office (‘FCDO’) is responsible for the UK’s international sanctions policy, His Majesty’s Treasury’s Office for Financial Sanctions Implementation (‘OFSI’) is the authority responsible for implementing financial sanctions. OFSI helps to ensure that financial sanctions are properly understood, implemented, and enforced in the UK. They have produced a factsheet for charities which provides answers to frequently asked questions on financial sanctions.

The main implication of being designated is that the designated person or entity is subject to financial restrictions. Financial sanctions come in many forms but one of the most common types of financial sanctions is a targeted asset freeze. This means that it is a criminal offence for a person (including the designated person) to deal with funds or economic resources belonging to, or owned, held or controlled by a designated person. It is also a criminal offence to make funds or economic resources available, directly, or indirectly, to or for the benefit of, a designated person or entity.

Trustees have a legal responsibility for the administration of their charity. They are custodians of charitable funds and hold them on trust for their charity. They have control over the management and administration of the charity and therefore, its assets.

If a serving trustee becomes a designated person, they would be unable to act in the administration of the charity without an offence being committing. If a charity’s assets are subject to financial sanctions, unless licensed to do so by OFSI a person would not be able to deal with them without that being a criminal offence. Conversely, if the trustee in question did not deal with charity funds and simply left them dormant, then they would be failing to discharge their legal duties as a trustee in the management and administration of a charity. In either scenario, this amounts to misconduct and/ or mismanagement in the administration of a charity.

If the trustee does not resign, the charity’s other trustees should see if they have the power under the charity’s governing document to remove them from office. If the trustees do not have this power, they should immediately seek the Commission’s advice. If the designated person does not resign as a trustee and the charity’s other trustees cannot or do not remove them, the Commission will consider using its legal powers to do so.

If a charity has appointed a designated person as a trustee, or a trustee is subsequently designated, this should be reported to OFSI and the Commission immediately as a serious incident.

The Commission has produced a quick guide for cross-checking trustees with the consolidated list of financial sanctions targets.