UK Strengthens Sanctions Oversight with New Whistleblowing Protections

The UK government has moved to fortify its sanctions enforcement regime by amending whistleblowing legislation to provide greater protection for those disclosing sanctions-related misconduct. The Public Interest Disclosure (Prescribed Persons) (Amendment) Order 2025 was laid before Parliament yesterday and is set to enter into force on 26 June 2025.

Whistleblowing & Sanctions Enforcement Aligned

The amendment broadens the scope of UK whistleblowing law by designating new sanctions-related matters that may be disclosed under the Public Interest Disclosure Act 1998 (PIDA). It prescribes the Secretary of State for Business and Trade, Secretary of State for Transport, and, for the first time, HM Treasury as appropriate bodies for receiving protected disclosures concerning their respective sanctions-related functions.

This significant step ensures that individuals who blow the whistle on breaches of financial sanctions, transport sanctions, and trade restrictions will qualify for employment protections, provided their disclosures are made to the appropriate department.

A Timely Move Amid Sanctions Complexity

The move is seen as a response to the increasing complexity and volume of sanctions following the UK's post-Brexit independence in foreign policy enforcement and the ongoing geopolitical volatility, including the sanctions regime targeting Russia and other jurisdictions.

By extending statutory protection to whistleblowers in this field, the government aims to encourage the reporting of sanctions breaches, deter non-compliance, and support more robust enforcement by UK authorities.

Implications for Employers & Regulated Entities

This legislative update reinforces the need for firms to maintain effective internal reporting channels and ensure staff are aware of their rights and protections under whistleblowing law. Organisations operating in sectors subject to UK sanctions including financial services, shipping and logistics, and international trade should revisit their whistleblowing policies and training to align with the upcoming changes.

Read the order here.