Westminster Policy News & Legislative Analysis

Sarah’s Trust to close; CIO dissolution not yet confirmed

Sarah’s Trust, the charitable foundation chaired by Sarah Ferguson, said on Monday 2 February it will “shortly close for the foreseeable future” after months of discussion. The announcement followed the US Department of Justice’s 30 January publication of further Epstein‑related material released under the Epstein Files Transparency Act. (itv.com)

Emails within the US release show Ferguson corresponded with Jeffrey Epstein after his 2008 conviction, with one message describing him as “the brother I have always wished for.” Images published in the cache also appeared to show Andrew Mountbatten‑Windsor crouched over an unidentified woman; he has consistently denied wrongdoing. Being named in the files does not in itself indicate criminality. (apnews.com)

Operational closure is not the same as legal dissolution. Sarah’s Trust remains on the Charity Commission register as of 3 February 2026. It is a Charitable Incorporated Organisation (CIO) – foundation model – registered on 7 June 2018 (charity no. 1178691). Listed trustees are Sarah Ferguson (chair), Elizabeth Mitford Ferguson and Deborah Hare. For the year to 31 May 2025, the charity reported £31,423 income and £114,377 expenditure. (register-of-charities.charitycommission.gov.uk)

Closing a CIO follows a defined legal route. Trustees must first decide to close and, because a foundation CIO’s trustees are also its members, pass a members’ resolution. They must then make a trustee declaration confirming all liabilities are settled and set out how any remaining assets will be applied before submitting an application to the Commission for voluntary dissolution. (gov.uk)

After an application is filed, the Commission publishes a notice on the register. Subject to any representations, removal from the register follows after three months, at which point a CIO ceases to exist. Until removal, trustees remain in office and legally responsible for compliance. (gov.uk)

In practical terms, trustees preparing for wind‑down should settle debts, handle restricted or special‑trust funds correctly, consider transfers to suitable receiving charities, address staff and contract issues, and ensure GDPR‑compliant treatment of records. Key financial and governance records must generally be retained for at least six years from the end of the financial year in which they were made. (gov.uk)

Trustees should also consider whether the situation constitutes a reportable Serious Incident-such as material reputational harm or risks to the charity’s work-and, where appropriate, file a report with the Commission and notify any other relevant regulators (for example the ICO for data matters). (gov.uk)

In public statements and on its website, the charity highlighted recent activity including partnerships with more than 60 organisations in over 20 countries, large‑scale aid distribution during the COVID‑19 period, and support connected to the war in Ukraine. (itv.com)

The announcement comes after several UK organisations ended Ferguson’s patronages in September 2025 following earlier disclosures, including Julia’s House, Teenage Cancer Trust, the Natasha Allergy Research Foundation, the Children’s Literacy Charity, the National Foundation for Retired Service Animals, Prevent Breast Cancer and the British Heart Foundation. (itv.com)

Legally, the US release sits within the Epstein Files Transparency Act framework. On 30 January 2026 the Justice Department said it had published more than 3 million additional pages (including images and videos) to comply with the Act; it has since acknowledged redaction failures affecting some materials and outlined steps to correct them. (justice.gov)