The inquiry into Mountain of Fire and Miracles Ministries International exposed one of the most troubling examples of how weak oversight in charitable networks can create an ideal environment for money laundering. The case revealed a vast organisation with over one hundred bank accounts, poor internal control, and an alarming absence of trustee supervision. What began as a regulatory investigation into mismanagement soon reflected the same warning signs that anti-money laundering specialists observe in high-risk financial institutions.
Charities hold a unique position in the economy. They benefit from tax exemptions, attract large volumes of donations, and operate across borders. But that same structure can easily be exploited. When governance is weak and internal controls fail, charity money laundering becomes a hidden risk, concealed behind the appearance of faith or philanthropy.
This case shows what happens when growth and complexity outrun governance. A decentralised structure without proper oversight can transform a legitimate religious network into a potential laundering conduit. The investigation findings reflect not only poor administration but also systemic exposure to money laundering typologies that AML professionals must recognise early.
Table of Contents
Charity money laundering and the scope of the inquiry
Mountain of Fire and Miracles Ministries International, a large Christian organisation registered as a UK charity, had expanded to more than ninety branches nationwide. Each branch functioned almost independently, maintaining its own bank accounts and making major financial decisions without central approval. By the time the Charity Commission intervened, the number of accounts exceeded one hundred.
The inquiry, opened under section 46 of the Charities Act 2011, uncovered a structure in which trustees had little to no visibility over the financial operations of their branches. Funds were moved, deposited, and spent without consolidated oversight. Income was reported late or not at all, while branches purchased properties, signed lease agreements, and made settlements independently.
The Commission froze the charity’s assets after confirming that donor funds were at risk. An interim manager was appointed in 2019 to rebuild internal controls and governance frameworks. The appointment lasted five years, underscoring the scale of the disarray.
From a money laundering perspective, these findings outline all three traditional stages of laundering. The placement phase appeared through uncontrolled cash deposits into multiple branch accounts. The layering phase emerged through inter-branch transfers and property transactions made without trustee awareness. The integration phase manifested through the use of funds for regular activities, blending potentially illicit assets into legitimate operations.
Although no proven criminal laundering was confirmed, the pattern of financial mismanagement created an ideal environment for it. This is a critical distinction in AML analysis: the absence of a conviction does not eliminate exposure. Weak systems invite abuse, and abuse often precedes criminal detection.
Financial crime typologies and regulatory implications
Charities are particularly vulnerable because they rely on trust. Donations are rarely questioned, especially when made in the name of religion or humanitarian purpose. The Mountain of Fire case shows how that trust can be undermined when governance collapses.
- Autonomous branches and fragmented controls
Each branch opening its own account created opacity. Without consolidated reporting, there was no single ledger of incoming and outgoing funds. Such fragmentation mirrors the layering techniques used by money launderers to move funds through multiple entities. - Property transactions and settlements
Several branches purchased or occupied properties without authorisation. Some faced legal action for lack of planning permission, while others paid settlements for employment disputes. Property dealings are a classic method for integrating illicit funds. The lack of oversight allowed large sums to circulate outside official review. - Governance failures and conflicts of interest
The inquiry noted that the founder had unilateral authority to appoint trustees, and that employees were serving as trustees. This structure concentrated power and removed independence. Weak governance is not merely poor practice, it is a recognised enabler of money laundering in non-profit structures. - Record-keeping and late reporting
The charity’s financial accounts were repeatedly late, inaccurate, or missing. Some years had no complete filings. From an AML viewpoint, delayed reporting is a red flag. It conceals the origin and use of funds, complicating detection of suspicious activity. - Lack of donor and recipient verification
Without systematic donor due diligence, large donations could be accepted from unknown or high-risk sources. Similarly, beneficiaries and vendors were not properly verified. These weaknesses make the charity an attractive vehicle for illicit transfers disguised as donations or project funding.
Under UK law, trustees are personally responsible for ensuring proper financial management. The Proceeds of Crime Act 2002 criminalises the concealment, conversion, or transfer of criminal property. While the Money Laundering Regulations 2017 primarily apply to regulated financial institutions, charitable organisations are still expected to adopt proportionate controls to prevent abuse.
By failing to implement adequate internal checks, the charity’s trustees exposed the organisation to risks directly aligned with money laundering offences, even if unproven. The case demonstrates that regulatory non-compliance can itself represent a money laundering vulnerability.
Governance, reform and AML lessons
After five years under regulatory supervision, the charity adopted a new governance framework intended to separate central oversight from branch operations. The “hub and spoke” model introduced independent financial control, unified accounting, and trustee approval for all major decisions.
For AML professionals and trustees alike, this restructuring offers lessons that extend beyond the case.
Central oversight is non-negotiable.
Every account in a charitable network must be known, monitored, and reconciled. Multiple uncoordinated accounts make tracking impossible and undermine the chain of accountability.
Donor due diligence must be proportionate but consistent.
Large or unusual donations should trigger verification. Anonymous or high-risk jurisdiction donors must be screened. The perception of goodwill cannot replace compliance checks.
Transaction monitoring is vital even for non-profits.
Automated alerts for unusual transfers, round-number payments, or inter-branch fund movements can expose early red flags. A simple spreadsheet or dashboard is often enough to begin building visibility.
Governance independence must be preserved.
Trustees should not be employees, family members, or direct subordinates of founders. Independence allows critical challenge and protects against conflicts that enable misuse.
Training and accountability build prevention.
Trustees and senior staff need AML and governance training tailored to the charitable sector. Awareness of typologies, red flags, and record-keeping standards reduces exposure.
The appointment of an interim manager was a decisive step. It restored structural integrity but also underscored how fragile governance can become when left unattended. The regulatory intervention illustrates that AML relevance extends well beyond banks and financial firms. Charities, especially those with complex or international operations, face equal expectations of transparency.
Preventing future charity money laundering
The most valuable outcome of this inquiry is its warning to the wider sector. Rapid growth, decentralisation, and weak governance are recurring risk patterns in faith-based and community charities. As donations increase, financial complexity multiplies. Without early control, these organisations can unintentionally mirror money laundering schemes.
A risk-based approach must become standard across all charities, regardless of size. Each must identify its risk exposure, document mitigation measures, and test their effectiveness. This includes:
- Creating a central list of all bank accounts and authorised signatories.
- Setting policies for branch autonomy, with strict thresholds for independent financial action.
- Performing annual audits that include AML risk testing.
- Establishing escalation processes for suspicious or unverified donations.
- Reporting serious incidents promptly to the regulator.
From a broader compliance perspective, the Mountain of Fire case is an early signal of how non-profits may face increased scrutiny under future AML frameworks. Regulators are expected to tighten expectations for transparency, with greater alignment between charity governance and AML obligations.
The line between mismanagement and laundering risk is narrowing. Regulators now treat poor governance not merely as administrative failure but as a potential enabler of financial crime. The charity’s recovery, while complete on paper, remains a cautionary tale of what unchecked autonomy can produce.
Related Links
- UK National Risk Assessment of Money Laundering and Terrorist Financing 2025
- Charity Commission Compliance Toolkit – Protecting Charities from Harm
- Proceeds of Crime Act 2002 (UK legislation)
- Money Laundering Regulations 2017 (UK legislation)
Other FInCrime Central Articles About Sham or Dubious Charities
- Global Charity Laundering Exposed Khalistani and Islamist Networks Funding Terror
- FATF Standards and Non-Profit Organizations: Balancing Security and Access
- OFAC Crackdown Unveils Hidden Millions Flowing to Hamas and FPLP via Sham Charities
Source: Gov.uk
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