Decision

Charity Inquiry: OBAC - (Organisation of Blind Africans and Caribbeans)

Published 28 August 2025

Applies to England and Wales

The Charity

OBAC - (Organisation of Blind Africans and Caribbeans) (‘the Charity’) was registered on 19 May 2011. The Charity’s governing document was a Memorandum and Articles of Association incorporated on 19 November 2010.

The Charity was removed from the register of charities on 1 July 2024 after it ceased to operate and was dissolved. The charity’s entry can be found on the register of charities.

The charity’s objects were:

• to relieve the needs of disabled people in particular the blind and partially sighted by provision of an information and advice service
• to promote all or any charitable purposes primarily but not exclusively for the benefit of disadvantaged people and in particular the advancement of education, the protection of health and the relief of poverty, distress and sickness
• to work with similar likeminded organisations and individuals outside the UK and in particular Africa and Caribbean to promote charitable purpose for the benefits of marginalised and disadvantaged people and communities
• in practice, the Charity provided services including immigration advice, education and training to people who are blind or partially sighted

Charity’s trustees and CEO since it was registered:

Position	Name	From	To
CEO	Ibukun Olashore	23/04/2011	04/04/2022
Trustee 1 / Vice chair	Ruth Bishop	23/04/2011	29/10/2024
Trustee 2	Dwight Watson	28/03/2018	29/10/2024
Trustee 3	Diib Jama	23/04/2011	29/10/2024
Trustee 4	Rasheed Bello	23/04/2011	29/10/2024
Trustee 5		20/05/2011	29/01/2019
Trustee 6		20/05/2011	04/11/2021

Trustees 1, 2, 3 and 4 (‘the trustees’) were all in post at the time the inquiry was opened and remained in post until the Charity was dissolved.

Background and issues under Investigation

The Commission first engaged with the Charity in July 2021 through its Proactive Casework team to explore concerns around potential wrongdoing and/or abuse by Ms Olashore, the Charity’s Chief Executive Officer (‘CEO’). However, the trustees failed to properly engage and cooperate with the Commission or provide assurance that they were acting responsibly and in accordance with their legal duties.

On 2 November 2022, the Commission made an Order under section 52 of the Charities Act 2011 (‘the Act’) that ordered the trustees to provide documentary evidence and information related to the criminal convictions of the CEO and another employee of the Charity. The trustees failed to comply with this Order as the Commission did not receive a substantive reply and/or documents requested.

The underlying concerns about the CEO’s continued involvement in the Charity and the trustees’ ongoing failure to properly engage with the Commission and a failure to comply with an Order, resulted in the decision to open a statutory inquiry, under s46 of the Act 2011, on 15 December 2022.

The scope of the inquiry was to examine the administration, governance and management of the Charity by the trustees:

• whether the trustees have complied with and fulfilled their duties and responsibilities as trustees under charity law; in particular whether they exercised sufficient oversight over the Charity’s activities and executive leadership
• whether there has been any misconduct and/or mismanagement by the trustees

The inquiry closed with the publication of this report.

Findings

Whether the trustees have complied with and fulfilled their duties and responsibilities as trustees under charity law; in particular whether they exercised sufficient oversight over the administration, governance and management of the Charity and its activities and executive leadership

Failure to comply with the Charity’s governing document in relation to the Charity’s bank mandate

The inquiry found that the trustees in post at the time failed to ensure the Charity’s bank mandate was kept up to date following the death of trustee 5 in 2019 and resignation of trustee 6 in 2021. Under clause 50(3)(b) of the Charity’s governing document the authorised signatories on its bank mandate must comprise of the chair, the most senior employee of the Charity and other persons on the board.

In a meeting with the inquiry on 27 February 2023, trustee 4 confirmed that as well as being a trustee he was also the treasurer of the Charity. The inquiry found that despite his role as treasurer, he had no knowledge of which bank the Charity held its bank account with, or who the signatories were on the bank mandate. In addition, trustee 1 who was the vice chair of trustees, was unaware that she should also have been acting as a signatory to the Charity’s account.

This situation allowed the CEO to remain the only signatory on the Charity’s bank account and consequently they had sole control of the bank account. In addition to their failures to ensure the signatories on the bank mandate remained up to date, the inquiry also found that the trustees failed to exercise adequate oversight and control over the CEO’s use of the bank account.

Charity trustees have a duty to act in accordance with the Charity’s governing document. By failing to keep the bank mandate up to date and to exercise proper oversight and control, the trustees let the CEO have complete control over the Charity’s funds and thus exposing the Charity’s funds to undue risk. Having an out-of-date bank mandate for nearly 5 years is a breach of the governing document and therefore a breach of trust. It also constitutes misconduct and/or mismanagement in the administration of the Charity by the trustees.

Failure to comply with the Charity’s governing document in relation to Annual General Meetings (‘AGMs’)

The inquiry found that the last AGM had been held in March 2018.

An AGM was subsequently held by the trustees on 27 September 2023, five and a half years after the last AGM. However, not all trustees attended the AGM and/or gave a reason for their absence.

The inquiry found that the trustees did not call an AGM in line with the provisions of the Charity’s governing document which states “an Annual General Meeting (‘AGM’) must be held each year and not more than 15 months may elapse between successive AGMs”.

The trustees have a duty to act in accordance with the Charity’s governing document and a failure to do so is a breach of trust. The Commission also considers this to be misconduct and/or mismanagement in the administration of the Charity.

Failure to comply with statutory filing requirements

The inquiry found that the trustees failed to comply with their legal duty under Part 8 of the Act to prepare an annual return, annual report and accounts and to transmit them to the Commission within 10 months from the end of the Charity’s financial period.

The Charity’s annual return, annual report, and accounts for the financial year ending 31 March 2022 were submitted 243 days late. The Charity failed to submit annual returns, annual reports and accounts for the financial years ending 31 March 2023 and 31 March 2024.

All charities must maintain accounting records and prepare accounts. A charity’s accounting information must be submitted to the Commission within 10 months of the end of the financial year to which they refer. The failure to submit accounts and accompanying documents to the Commission constitutes misconduct and/or mismanagement in the administration of the charity.

Failures by the trustees in allowing the CEO to continue in post despite being automatically disqualified from being a trustee or holding a senior management position

The CEO was convicted on 3 and 4 April 2022 of conspiracy to do an act to facilitate the commission of a breach of UK immigration law by a non-UK national and of conspiracy to possess/control identity documents with intent. The CEO was later sentenced to 9 years at a sentencing trial which concluded on 13 July 2023. In his sentencing remarks Judge Dixon made comments highlighting that the Charity was used to front criminal activities. “You [the CEO] were the head of a charity [OBAC] which may well, in the past, have been set up with all good intentions but you used that charity as a front for your activities. The materials that I have seen during the course of both trials show that you were using OBAC as a way of disguising your dishonest activities and potentially finding people with whom you could take money.”

The role of CEO is a senior management function under s178(4) of the Act and because the offences involved dishonesty or deception the CEO was automatically disqualified from this role under s178(1) of the Act in April 2022.

The inquiry conducted an unannounced visit to the Charity’s office on 23 January 2023. At this visit, the CEO confirmed to the inquiry in person that they were still acting as CEO of the Charity.

The inquiry found that even after being made aware of the CEO’s convictions for serious criminal offences, the trustees failed to take any steps to address this matter, such as suspending the CEO and carrying out an internal investigation.

The Commission found that by allowing the CEO to continue to act and make decisions whilst being automatically disqualified due to their convictions and failing to take any reasonable steps to deal with the matter and review their appointment, the trustees were responsible for misconduct and/or mismanagement in the administration of the charity.

The trustees exerted insufficient oversight over the Charity, which led to it being used as a vehicle for criminal activity. If the trustees had acted with due care and skill, they likely would have identified what was happening and would have been able to take steps to address these matters and mitigate the impact on the Charity. Even when informed by the Commission on more than one occasion, the trustees did not act. By allowing the CEO to engage in criminal activities for over 10 years, and tarnish the Charity’s name, the trustees who were in post during this period have failed in their trustee duties. This is misconduct and/or mismanagement by the trustees in the administration of the charity.

The CEO continued to be listed as an immigration advisor on the Charity’s website even though she was no longer registered with the Immigration Advice Authority (IAA) ^{[footnote 1]}

The Charity was registered with the IAA (then OISC) to provide immigration advice and services on 4 July 2016. IAA registration lasts 12 months. It must be renewed annually through an application for continued registration.

Following the CEO being charged with serious criminal offences in March 2021 the First-tier Tribunal, General Regulatory Chamber, Immigration Services (‘FTT’) suspended the CEO on 24 May 2021 from providing immigration advice and services and was required to refer their clients to the other Level 2 advisor at the Charity.

On 4 April 2022 the IAA (then OISC) was informed of the CEO’s convictions, and they cancelled her registration on the basis that she was no longer competent or was otherwise unfit to provide immigration advice or immigration services, under paragraph 4A(e) of Schedule 6 to the Immigration and Asylum Act 1999 (as amended).

On 22 July 2022, the IAA (then OISC) refused the Charity’s application for continued registration which took effect on Friday 19 August 2022 because OBAC was not fit to provide immigration advice and/or services.

In the UK, only the IAA registered immigration advisers are legally able to provide immigration and asylum advice and services to the public. Since 19 August 2022, when the refusal took effect, it was a criminal offence for the Charity to provide immigration advice and services.

The inquiry found that in March 2023, the Charity was still providing immigration advice and/or held itself out as doing so.

The inquiry found that during the CEO’s suspension and later removal by the IAA and even following their convictions the CEO remained listed as an immigration advisor on the Charity’s website and remained as CEO.

The trustees’ failure to take any action to consider the appropriateness or legality of the CEO remaining listed as an immigration advisor after her suspension/removal and convictions is misconduct and/or mismanagement by the trustees.

The then trustees’ failure to consider and review the Charity’s position after its registration was refused and exposing the Charity to risk of a criminal conviction contrary to Section 91 of the Immigration and Asylum Act 1999, is misconduct and/or mismanagement in the administration of the Charity by then trustees.

Whether there has been misconduct and/or mismanagement by the trustees

As has already been set out in this report there are repeated instances of misconduct and/or mismanagement by the trustees in post at the relevant times. This includes a failure to comply with the Charity’s governing document, a failure to comply with statutory filing requirements and failure to have sufficient oversight and management of the CEO – including failing to ensure that the Charity was safeguarded following the CEOs convictions and automatic disqualification from acting in a senior management function.

In addition to this, further misconduct and/or mismanagement is set out below.

Failures to comply with Orders made by the Commission

The inquiry found that the trustees failed to comply with an Order issued under section 84 of the Act and a Direction under s47(2)(c) of the Act.

On 9 February 2023, the inquiry issued a Direction under section 47(2)(c) of the Act that directed the trustees to attend the Charity’s premises to give evidence about a number of matters to the inquiry. Two of the trustees failed to attend the meeting and/or provide a reason for their absence.

In order to address the identified areas of weakness in the Charity’s governance and administration, the inquiry issued an Order under section 84 of the Act to the trustees on 6 March 2023 which directed them to take certain specified actions within defined timescales. These actions included, but were not limited to, the trustees ensuring the Charity was no longer giving immigration advice or services and not holding itself out as doing so, reviewing the legality and appropriateness of the CEO’s ongoing role as CEO of the Charity, amending the bank mandate and completing and submitting to the Commission the Trustees’ Annual Report, Accounts and Annual Return for the Charity for the financial year ending 31 March 2022. The trustees failed to take any action and did not comply with the Order.

In accordance with section 76(1)(a) of the Act, failure to comply with an Order or Direction of the Commission is misconduct and/or mismanagement in the administration of a Charity.

Failure to respond and lack of cooperation by the trustees

Over the course of 3 years, the Commission sought to engage and discuss the Commission’s regulatory concerns with the trustees through face-to-face meetings and correspondence.

The inquiry found that the trustees either failed to attend meetings conducted as part of the inquiry on 27 February, 26 June and 16 October 2023 or, if in attendance, the trustees present were unable to provide adequate information or assurance to the inquiry in relation to the governance, administration, and management of the Charity.

There were multiple further instances of non-cooperation and compliance with the inquiry, including no response to letters, emails and phone calls to arrange meetings, monitoring visits and to provide documentary evidence.

The inquiry found that the failures by the trustees to properly cooperate with the inquiry is misconduct and/or mismanagement in the administration of the charity.

Failure to report serious incidents (‘RSI’) to the Commission

The Commission’s guidance states that trustees are expected to report an incident if it results in, or risks, significant harm to their charity’s reputation among other things. Further, the guidance states “An incident that involves actual or alleged criminal activity will usually be reportable to the Commission”.

The inquiry found that there had been a number of serious incidents between April 2022 and July 2023 that should have been reported to the Commission by the trustees but were not.

The CEO was first convicted on 3 April 2022. The trustees did not submit an RSI about this when it happened or when they first became aware. In a letter dated 14 November 2022, the trustees stated that they would have reported ‘the matter’ in their annual report, which was due on 31 January 2023. The trustees did not submit their accounting information until 1 October 2023 (243 days late) and there was no mention of any criminal convictions in the annual report.

On 4 April 2023, a person who was involved with the CEO and allegedly paid her £30k for his immigration application contacted a member of the Charity’s staff and made verbal threats to attack staff and cause damage to the building. Only after being prompted by the inquiry was an RSI was submitted to the Commission on 5 July 2023.

On or around 12/14 May 2023 the Charity’s premises was broken into causing significant damage to the interior including vandalism, the disturbance of filing systems and the theft of important equipment such as assistive technology tools needed for visually impaired staff. No RSI was submitted to the Commission until 5 July 2023.

The CEO was sentenced to 9 years imprisonment on 13 July 2023. The trustees did not submit an RSI to the Commission.

The failures by the trustees to both report incidents to the Commission, and to report other incidents within a reasonable timeframe, is considered to be misconduct and/or mismanagement in the administration of the Charity.

Exposing the Charity to risk – lease agreement

The inquiry found that the Charity’s sole income since 21 February 2023 had been from subletting its offices. When questioned in a meeting on 27 February 2023, the trustees had no knowledge of the terms of the lease agreement (between the Charity and the Charity’s landlord). The trustees had also had no knowledge of who one of the subletters who paid significant amounts was.

On 29 August 2023, the trustees provided the inquiry with a copy of its lease agreement dated 17 December 2021. Upon receipt and examination of the lease agreement the inquiry found that the Charity was not allowed to sublet the property.

Operating in breach of a lease creates clear risks to the Charity, including in relation to insurance and potential litigation. The inquiry found that the trustees were responsible for breaching and/or allowing a breach of a contract to continue which is misconduct and/or mismanagement in the administration of the Charity.

Conclusions

The Commission has concluded that there was serious misconduct and/or mismanagement in the administration, governance and management of the Charity as set out above by the trustees.

By their own admission, the trustees did not possess the skills and knowledge expected of trustees and they lacked awareness of their legal duties and responsibilities. In failing to exercise proper oversight of the CEO, they allowed the charity to be exploited by its CEO, exposing the charity to undue risk and significant reputational damage. The Commission has concluded that the trustees also failed to act responsibly after becoming aware of the Commission’s regulatory concerns, which ultimately contributed to the closure of the charity

The Charity’s trustees were afforded the opportunity to take steps to remedy their failings and to strengthen the governance of the Charity by complying with a s84 Action Plan issued by the Commission. The trustees took no action at all to comply with the Action Plan which demonstrated an unwillingness and/or inability to address the Commission’s regulatory concerns and put the Charity onto a proper footing. The trustees in post at the commencement of the inquiry were all disqualified from acting as trustees by the Commission as a result of these findings (see Regulatory Action below for more details).

On 23 April 2024 the Charity (which was also a registered company) was struck off by Companies House and dissolved on 30 April 2024, for failing to file accounts. The frozen funds in the Charity’s bank account automatically passed bona vacantia to the Crown. ^{[footnote 2]} On 1 July 2024, the Commission exercised its power under s34(1)(b) and removed the Charity from the Register of Charities as it had ceased to exist.

Regulatory action taken

During the inquiry, Directions and Orders were made under sections 47 and 52 of the Act to gather relevant information. The Commission directed the trustees under section 84 of the Act to take certain actions to address weaknesses in the Charity’s governance and management. The Commission also exercised its power under section 76(3)(d) of the Act and ordered the Charity’s bank not to part with property held on behalf of the Charity without the approval of the Commission.

On the 29 October 2024 Ruth Bishop was disqualified under section 181A of the Act from being a charity trustee and/or trustee for a charity and from holding an office of employment with senior management functions in charities for a period of 5 years.

On the 29 October 2024 Dwight Watson was disqualified under section 181A of the Act from being a charity trustee and/or trustee for a charity and from holding an office of employment with senior management functions in charities for a period of 3 years.

On the 29 October 2024 Diib Jama was disqualified under section 181A of the Act from being a charity trustee and/or trustee for a charity and from holding an office of employment with senior management functions in charities for a period of 5 years.

On the 29 October 2024 Rasheed Bello was disqualified under section 181A of the Act from being a charity trustee and/or trustee for a charity and from holding an office of employment with senior management functions in charities for a period of 5 years.

Issues for the wider sector

The abuse of charities for unlawful purposes is absolutely unacceptable. The Commission will take robust regulatory action where it finds that a charity has been abused in this way.

Trustees are jointly and equally responsible for the management of their charity. To be effective and to meet their statutory duties as charity trustees they must contribute to the management of the charity and ensure that it is managed in accordance with its governing document and general law.

Charity trustees must comply with Orders and Directions of the Commission. In some circumstances it may be a criminal offence (or contempt of court) for a charity or a trustee to not comply with an order or direction of the Commission.

1. Since Jan 2025 OISC (Office for Immigration Services Commissioner) is now called the Immigration Advice Authority (IAA). ↩

2. Occurs when a company is struck off and dissolved meaning the company no longer exists. From the date of dissolution, any assets of a dissolved company will be ‘bona vacantia’. Bona vacantia literally means ‘vacant goods’ and is the technical name for property that passes to the Crown because it does not have a legal owner. The company’s bank account will be frozen and any credit balance in the account will be passed to the Crown. ↩