Whistleblowing Protections Extended to Support UK Sanctions Enforcement

The Public Interest Disclosure (Prescribed Persons) (Amendment) Order 2025, which came into force on 26 June 2025, marks a significant step in aligning whistleblower protections with the UK’s evolving sanctions regime. By expanding the scope of who is considered a “prescribed person” for the purposes of whistleblowing, the legislation aims to reinforce sanctions compliance and expose breaches more effectively.

Crucially, the Secretary of State for Business and Trade, the Secretary of State for Transport, and HM Treasury have now been designated as prescribed persons for specific sanctions-related matters. This includes disclosures concerning financial sanctions, transport sanctions, and certain trade-related restrictions, thereby broadening the routes through which individuals can safely report misconduct or regulatory breaches.

For whistleblowers, this amendment strengthens their ability to raise concerns about sanctions breaches without fear of retaliation at work. Protected disclosures made to these departments will now qualify for employment law safeguards under the Public Interest Disclosure Act. For organisations, the change signals increased regulatory attention on sanctions enforcement and raises the stakes for compliance failures.

This legislative update also reflects the government’s wider commitment to enforcing sanctions in response to geopolitical threats, including the ongoing circumvention of restrictions against Russia and sanctioned entities. By empowering whistleblowers and clarifying reporting channels, the UK continues to reinforce its sanctions architecture and underline the role of individual accountability in financial crime prevention.

Firms operating in sensitive sectors such as finance, transport, and international trade should take note of this development, review internal reporting mechanisms, and ensure staff are aware of their rights and obligations when it comes to sanctions-related whistleblowing.

See the guidance here.