Decision

Charity Inquiry: Mountain of Fire and Miracles Ministries International

Published 20 October 2025

Applies to England and Wales

The charity

Mountain of Fire and Miracles Ministries International (‘the charity’) was registered on 30 October 2003. It is an unincorporated association governed by a constitution dated 31 August 2002 as amended on 26 September 2004 and 4 July 2024. The charity’s income and expenditure as recorded in its last submitted accounts for the financial year ending 31 December 2023, recorded an income of £2,710,006 and expenditure of £2,198,198.

The charity’s objects are:

“To propagate Christianity through 1. Youth programmes 2. Christian seminars and symposium, convention and crusades 3. Counselling programmes for the distressed and bereaved 4. Bible studies, theological education, evangelical raining and teaching of Christian faith 5. Publication and distribution of books, audio and video tapes, magazines, news bulletin, tracts and leaflets.6. Relief of poverty and deprivation 7. Programmes for the elderly and neglected”

The charity has approximately 50 branches across the UK, each with their own Pastor leading religious services. The charity’s entry can be found on the register of charities .

Trustees

The following have served as trustees of the charity during the relevant period:

Trustee	Position	Date of appointment	Date of resignation
Trustee A – General Overseer and former Chair of trustees	Former trustee	1 January 2005	7 January 2021
Trustee B	Former trustee	21 December 2018	7 January 2021
Trustee C	Former trustee	21 December 2018	7 January 2021
Trustee D	Former trustee	21 December 2018	7 January 2021
Trustee E	Former trustee	21 December 2018	7 January 2021
Trustee F	Former trustee	21 December 2018	11 February 2022
Trustee G	Current trustee	7 January 2021	To date
Trustee H	Current trustee	7 January 2021	To date
Trustee I	Current trustee	7 January 2021	To date
Trustee J	Current trustee	7 January 2021	To date
Trustee K	Current trustee	19 March 2021	To date
Trustee L	New trustee	7 December 2024	To date
Trustee M	New trustee	7 December 2024	To date
Trustee N	New trustee	7 December 2024	To date

Background and Issues under Investigation

Prior to the opening of the inquiry, in 2017 and early 2018, the Charity Commission (‘Commission’) had engaged with the charity further to reports of serious incidents made by the former trustees^{[footnote 1]} over potential misappropriation of charitable funds and possible theft of Gift Aid.

A Commission visit to the charity and an inspection of its books and records in February 2018 gave rise to concerns about the charity’s financial controls and the governance, particularly the adequacy of the former trustees’ oversight of the charity’s branch structure. It became clear that branch bank accounts had been opened without the knowledge of the then trustees. The books and records visit identified at least 100 bank accounts held by the charity’s branches over which the former trustees could not demonstrate that they had any oversight or control.

As a result of these regulatory concerns, a statutory inquiry (the ‘inquiry’) was opened into the charity under s46 of the Charities Act 2011 (“the Act”) on 27 March 2018 to examine the following regulatory issues:

• the governance, management and administration of the charity by the trustees, with specific regard to:
  • the extent of financial loss to the charity and the circumstances which led to the losses
  • whether adequate steps were or are being taken to recover such losses
  • whether reasonable steps were or are being taken to safeguard charity funds and assets
  • the adequacy of the trustees’ oversight and control of the charity’s branches
  • the adequacy of serious incident reporting by the trustees
• the extent to which the trustees have complied with their duties and responsibilities under charity law, including the trustees compliance with legal obligations for the preparation and filing of the charity’s accounts and returns
• whether and to what extent any issues or weaknesses in the administration of the charity
  • were as a result of misconduct and/or mismanagement by the trustees and
  • require rectification by the trustees or the Commission

Appointment of Interim Manager

When the inquiry was opened the charity was governed by a constitution dated 26 September 2004. Clause 3 of the constitution stated that ‘the charity is an affiliate of MFM Worldwide and shall therefore operate under the guardianship and overall control of the founder and General Overseer of MFM Worldwide’. The General overseer of MFM Worldwide is trustee A.

In addition, Clause 8.2 of the constitution stated that ‘the General Overseer of Mountain of Fire and Miracles Ministries Worldwide shall have power to appoint trustees and a secretary who shall together with the General Overseer constitute the Executive Committee.’

In 2018 three trustees resigned and the General Overseer/trustee A exercised the power in Clause 8.2 by appointing five additional trustees. However, three of these additional trustees were employees of the charity and continued to be remunerated. This was in breach of Clause 10 the charity’s governing document and created difficulties when managing conflicts of interest, particularly when the trustees needed to discuss employment matters.

The inquiry identified serious concerns over the role and independence of trustee A, which impacted the extent to which the other trustees of the charity were able to act in the best interests of the charity.

The inquiry identified that the charity operated by means of a branch structure, with poor and inadequate processes and reporting procedures between the branches and the central office which, due to a lack of oversight and scrutiny by the former trustees, created a risk to the charity’s assets.

As a result, to protect the charity’s funds and help improve its governance an Interim Manager (‘IM’) was appointed to work alongside the former trustees on the 1 August 2019.

For more details on the IM appointment please see the Regulatory Action section below. The findings of the IM helped to inform the inquiry findings, as set out in this report.

Findings

The governance, management and administration of the charity by the trustees

Governance

Trustees have overall responsibility for the management of their charity and ensuring that it operates for the public benefit, in line with its governing document. The inquiry found that the charity’s governing document was not fit for purpose.

Prior to the appointment of the IM, the charity had a complex and unworkable structure, with a central administrative branch and over a hundred branches operating across England and Scotland. The inquiry found that each branch had its own bank account giving rise to over 100 bank accounts holding charitable funds. The current and former trustees could not demonstrate that they had adequate control or oversight of these funds, with individual branches appearing to exercise autonomy in setting up new bank accounts and managing branch finances on behalf of the charity.

The inquiry found that substantial funds had been held in a particular bank account, but the purpose of those funds were unclear. Concerns about the risks of

misapplication or misappropriation of those funds resulted in the Commission making a freezing order under s76(3)(d) of the Act on 2 February 2022 to protect the funds.

It is clear that the governance of the charity had not adapted as the charity grew. The inquiry found that when the IM was appointed the existing systems for governance were ad hoc, ill-defined, and not subject to appropriate checks and controls. In particular the inquiry found that there was limited oversight by both the current and former trustees in respect of (amongst other things) the charity’s:

• financial performance
• insurance and regulatory arrangements
• financial controls and reporting (especially from the branches)
• legal matters
• operational matters

The inquiry also determined that the founder and General Overseer, trustee A, exercised too much authority over the charity and the other trustees. Trustee A resigned as a trustee on 7 January 2021 and his role as General Overseer to appoint and remove trustees was further reduced on 4 July 2024, when the charity’s constitution was amended to remove their power to appoint and remove trustees.

The inquiry also found that conflicts of interest were not given proper consideration or acted upon and resolved.

The failure by the current and former trustees to ensure that the governance structures and policies of the charity were suitable for the size and structure of the charity is misconduct and/or mismanagement in the administration of the charity.

Due to the failings in governance the IM in conjunction with the current trustees appointed Stone King LLP to undertake a governance review. This was completed in March 2024, and the key recommendations were as follows:

• that the charity considers establishing a “hub and spoke” model of incorporation. A “hub and spoke” model involves a central hub charity and separate spoke charities which are established for the same or similar purposes and have a relationship with the hub charity which can be contractual, constitutional or a mixture of the two
• that the charity takes steps to strengthen the governance of the charity by means that include but are not limited to the following:
  • reviewing, updating and introducing policies and procedures
  • recruiting additional trustees to enhance the skill set of the current board to support the effective governance of the charity
  • tightening internal financial controls
  • tightening control of the charity’s relationship with its branches
  • regularising the relationship between the charity and MFM Worldwide

Financial management

The inquiry found that the charity’s financial controls, where they existed, were not being adhered to by the trustees, staff, pastors and volunteers. This meant that charitable assets (for example members’ donations) were not adequately protected.

The branch structure of the charity means that the finances of the branches should be overseen centrally by the charity. However, the inquiry found that there was insufficient personnel resource within the charity to adequately complete the necessary financial administrative processes. This issue was compounded by the lack of expertise in financial matters across the charity and its branches. There were also no individuals holding senior positions at the charity who held appropriate professional qualifications.

The inquiry also found that the lack of financial controls had created an environment where informal and unapproved loan agreements (i.e. “soft loans” being loans from members that were extended to the charity and/or its branches with less stringent repayment terms compared with conventional loans) were made.

It became clear through the IM’s attempts to regularise the financial reporting at the charity and get a clear understanding of any liabilities that the charity had, that the branches did not always understand what was expected of them and often made decisions about expenditure, including significant property purchases, without the knowledge of or authorisation by the trustees. This proved to be very difficult to regularise and is one of the reasons why the IM was appointed for an extended period.

The lack of financial control and oversight by the former trustees placed charitable assets at risk and is misconduct and/or mismanagement by the current and former trustees.

Action plan

On 13 September 2024, the Commission made an Order under s84 of the Act (‘the action plan’) which directed the trustees to complete actions by the dates specified in the Order. The actions concerned submission of charity accounts, governance changes, employment and human resource issues, charity assets, policies and administrative matters. The Commission monitored the performance of the trustees against the specified actions and is satisfied that they have been completed.

The extent to which the trustees have complied with their duties and responsibilities under charity law, including the trustees’ compliance with legal obligations for the preparation and filing of the charity’s accounts and returns.

The former trustees failed to submit accurate and timely accounts, trustee annual reports and annual returns by the due date for the financial years ending 31 December 2012 through to the financial year ending 31 December 2019.

In addition, the current and former trustees failed to fully comply with Directions and Orders of the Commission requiring the trustees to submit documents and accounts and/or undertake specific tasks by specified dates which were issued by the Commission on 12 July 2018, 10 January 2020, 18 March 2021, 21 September 2021, 25 November 2021 and 27 April 2022.

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.

Trustees have 6 main duties as follows:

1. Ensure your charity is carrying out its purposes for the public benefit
2. Comply with your charity’s governing document and the law
3. Act in your charity’s best interests
4. Ensure your charity is accountable
5. Manage your charity’s resources responsibly
6. Act with reasonable care and skill

The inquiry found that there was a long history of the former trustees’ failure to act in accordance with their legal duty to comply with their charity’s governing document and the law. The former trustees failed to submit their accounting information to the Commission on time, which is a legal requirement under sections 163, 164 and 169 of the Act. Clauses 14 to 16 of the charity’s governing document require the trustees to comply with their obligations under the Act with regards to the transmission to the Commission of: 1) the charity’s statements of account, 2) the trustees’ annual report and 3) the charity’s annual return. The accounts and trustees’ annual reports for the financial years ending in 2015, 2016 and 2017 were filed 152, 163 and 151 days late respectively.

The current trustees also failed to fully comply with this legal duty as they were 151 days overdue in submitting the financial accounts and a trustee annual report for the financial year ending 31 December 2019.

The inquiry found that there were numerous examples of the current and former trustees’ failing to adequately oversee or monitor the charity’s branches. When the inquiry was opened, the charity had in excess of 90 branches nationwide (as opposed to 55 branches currently), which required the trustees to be able to rely on suitably qualified staff, with clear lines of financial reporting and delegated authority to the branches. This reporting structure was absent from the charity when the IM was appointed, and the inquiry found engagement with the branches was sporadic and unreliable. The inquiry found that branches often took decisions about expenditure without the trustees’ knowledge or permission, and they also failed to report on their income centrally in a timely manner. This made it especially challenging for the trustees, both former and current to have full knowledge of the charity’s income and expenditure and was one reason why the accounts were regularly submitted late or were qualified (i.e. being accounts on which the auditor has expressed reservations about whether they represent a true and fair view of the charity’s financial condition).

The lack of oversight and control of the charity’s finances by the former and current trustees placed the charity’s assets at risk and is considered misconduct and/or mismanagement in the administration of the charity. These failings are also a breach of the trustees’ legal duties to manage their charity’s resources responsibly. For example, through acting autonomously and without proper oversight, branches were exposed to legal claims from landlords, which resulted in losses to the charity. The former and current trustees failed to adequately oversee and monitor branches who entered into leases and took out mortgages without the authority of the trustees which exposed the charity to substantial liabilities. In addition, on occasion branches occupied property without first obtaining the necessary planning permission and were subject to legal action by a Council which resulted in losses to the charity.

Further losses arose as a result of the former and current trustees’ failure to regularise employment contracts which resulted in payments to settle employment disputes.

Conclusions

The Commission concluded that there was serious misconduct and/or mismanagement in the administration of the charity as the former and current trustees both failed to ensure that the charity’s governance and financial management kept pace with the growth of the charity. Serious failings were identified in the former and current trustees’ inability to manage and oversee the charity’s branches which created a risk to the charity’s funds.

The inquiry’s intervention addressed these regulatory issues through the appointment of an IM, who ensured proper oversight of the charity’s finances and facilitated incremental improvements to the charity’s governance and management. Whilst this was a protracted appointment, which incurred significant cost, it was ultimately successful in ensuring assurance regarding the charity’s expenditure and brought about the required improvements to the charity’s governance and administration.

Following the discharge of the IM, the Commission issued the action plan referred to above and is satisfied with the trustees’ compliance with the actions detailed within that. The Commission acknowledges the commitment of the current trustees to embed the improved governance and administrative processes at the charity and to continue to implement the recommendations set out in the independent governance review.

Regulatory Action Taken

Information gathering

The inquiry used information gathering powers under section 47 (a) and (b) of the Act to direct several individuals and entities, including the current and former trustees, to provide information to the inquiry.

The inquiry also met with all current and former trustees regularly throughout the inquiry.

Appointment of Interim Manager (“IM”)

On 1 August 2019, the inquiry exercised its powers under section 76(3)(g) of the Act to appoint Dr Adam Stephens of Evelyn Partners LLP [2], as Interim Manager (“IM”) of the charity.

The IM was initially appointed to work alongside the trustees of the charity with a specific remit to undertake the tasks specified in the schedules to the appointment Order. The specified tasks included the following:

• to undertake a review of the sufficiency of the charity’s financial processes, structures and resources
• to undertake a review of the charity’s governance and administration including the arrangements for the appointment and removal of any potential conflicts of interest
• to review all serious incidents
• to undertake a review of three branches
• to make recommendations for actions required to improve governance

On 21 September 2021, due to repeated failures by the current trustees to cooperate and fully comply with Commission orders and directions, the Commission, conducted a review of the IM appointment order and decided to vary the appointment order by appointing the IM to the exclusion of the current trustees. This varied Order, was challenged in the First Tier Tribunal (Charity) (“FTT”) by the current trustees on 28 September 2021.

The inquiry and therefore some of the work of the IM was significantly delayed waiting for the Tribunal proceedings to conclude. For example, the IM had to pause work relating to the review of the charity’s property, assets position and HR records for the purpose of devising a strategy to contract the charity’s branch structure. The Tribunal hearings were held on 29 September 2022 and 3 November 2022.

The FTT’s judgment was published on 27 January 2023. Whilst finding that there was misconduct and/or mismanagement in the administration of the charity which justified the continuing appointment of the IM, the judgment quashed parts of the varied order made in September 2021 including that the IM was appointed to the exclusion of the trustees. The FTT remitted the varied order back to the Commission for reconsideration, along with recommendations to consider. Therefore, and in accordance with the FTT directions, the Commission made a further Order dated 19 May 2023, to appoint the IM to the inclusion of the trustees. From this point the IM worked alongside the trustees until the IM was discharged on 13 September 2024.

The IM’s work during this period was focussed on tendering; appointing; and assisting the independent professional advisers to establish their review of governance at the charity and with the charity’s work in amending its constitution in July 2024. In addition, the IM continued with his tasks which included but were not limited to approving financial transactions above £5,000 (increased from the limit established in September 2021), analysing monthly payment runs, overseeing bank accounts, regularising lease arrangements and corresponding in relation to legal actions.

The IM was discharged on 13 September 2024. This was a challenging and protracted appointment, which lasted more than 5 years in total. The costs of the IM’s appointment were met out of the charity’s funds. Whilst the total time costs of the IM’s appointment totalled £2,224,075 for this period, the IM being mindful of the impact such costs have on the charity provided significant discounts to their rates and did not fully charge for the time costs of the appointment. The eventual cost to the charity was £1,018,926 plus VAT.

Other regulatory action

The inquiry used a number of regulatory powers, under the following sections of the Act:

• on 18 March 2021, the Commission made an Order under s84 of the Act directing the trustees to complete actions expedient in the interests of the charity
• on 2 February 2022, the Commission made an Order under s76(3) (d) of the Act being a direction nor to part with charity property during an inquiry
• on 12 June 2024, the Commission made an Order under s105 of the Act to enable the undertaking of actions expedient in the interests of the charity
• on 13 September 2024, the Commission made a further Order under s84 of the Act directing the trustees to undertake actions expedient in the interests of the charity

Issues for the wider sector

Trustees Roles and Responsibilities

Administration and Management

Every charity needs an effective trustee body which has control over the administration of the charity and acts as a whole, especially because all trustees are equal in responsibility. Trustees must ensure that their charity has adequate financial and administrative controls in place, and that the funds of their charity are applied for the benefit of the public for which it has been set up.

Where trustees are unable to undertake functions and obligations themselves, they must ensure that appropriate advice is taken and followed. In doing this, they 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 irrelevant factors, manage conflicts of interest and make decisions that are within the range of decisions that a reasonable trustee body could make. Meetings and decisions should be recorded.

Protection of Charity Assets

Charity trustees have a general duty to manage their charity’s resources responsibly, reasonably and honestly. This means not exposing their charity’s assets, beneficiaries or reputation to undue risk. It is about exercising sound judgement and then taking decisions that a reasonable body of trustees would do.

Trustees must put appropriate policies, procedures and safeguards in place and take all reasonable steps to ensure that these are followed.

If a charity owns land or buildings, trustees need to know on a continuing basis what condition it is in, that it is being properly used, and that adequate insurance is in place. The essential trustee: what you need to know, what you need to do (CC3) makes clear that decisions about charity land and property are important. If the charity owns or rents land or buildings, the trustees need to:

• make sure the property is recorded as belonging to the charity
• know on what terms it is held
• ensure it is properly maintained and being correctly used
• make sure the charity has sufficient insurance

Trustees are under a legal duty to ensure funds are used only in furtherance of their charity’s purposes and are legally responsible and accountable for their proper use. Trustees must be able to demonstrate that funds have been used for the purpose for which they were intended. This means that they need to take reasonable and proper steps to ensure that any money or resources have reached their intended beneficiaries. Trustees must take steps to monitor the specific use of their charity’s funds; this will always include verifying their proper end use. Due diligence is the range of practical steps that need to be taken by charities in order to be assured of the provenance of charitable funds and be confident that they know the people and organisations the charity works with and are able to identify and manage associated risks. When choosing partners to work with there must be proper due diligence checks relevant to their charity and the risks to ensure that they are appropriate partners for them to work with.

Reporting Duties to the Commission (Including Serious Incident Reporting)

A serious incident is an adverse event, whether actual or alleged, which results in or risks significant:

• harm to your charity’s beneficiaries, staff, volunteers or others who come into contact with your charity through its work
• loss of your charity’s money or assets
• damage to your charity’s property
• harm to your charity’s work or reputation

A serious incident should be reported to us immediately, not just on completion of the annual return. More information can be found on GOV.UK.

Trustees’ Accounting and Financial Duties

Financial Controls

Trustees must ensure that their charity has adequate financial controls in place. It is important that the financial activities of charities are properly recorded, and their financial governance is transparent. Charities are accountable to their donors, beneficiaries and the public. Donors to charity are entitled to have confidence that their money is going to legitimate causes and reaches the places that it is intended to, this is key to ensuring public trust and confidence in charities.

The Commission has produced guidance to assist trustees in implementing robust internal financial controls that are appropriate to their charity. Internal Financial Controls for Charities (CC8) is available on the commission’s website. There is also a self-check-list for trustees which has been produced to enable trustees to evaluate their charity’s performance against the legal requirements and good practice recommendations set out in the guidance.

Submission of Accounts and Annual Returns

Trustees of charities are under a legal duty as charity trustees to submit annual updates, returns, annual reports and accounting documents to the Commission as the regulator of charities depending upon the level of the charity’s income. Failure to do so is a criminal offence. The Commission also regards it as mismanagement and misconduct in the administration of the charity. Every charity’s accounting records must be sufficient to show and explain its transactions and disclose with reasonable accuracy its financial position. The report and accounts, when read together, should help users of the information to understand what the charity is set up to do, the resources available to it, how these resources have been used and what has been achieved as a result of its activities.

1. References to former trustees are those as listed in the table above. The same applies to references to current trustees and new trustees. ↩