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On June 26, 2025, the UK government brought into force the Public Interest Disclosure (Prescribed Persons) (Amendment) Order 2025 (the “2025 Amendment”), marking a notable development in the UK government’s sanctions enforcement strategy.

The 2025 Amendment expands the statutory protections given to whistleblowers to cover the reporting of breaches of UK sanctions to designated government departments.

This legislative development reflects the government’s cross-departmental push to strengthen the enforcement of financial, transport, and trade sanctions, particularly in light of persistent geopolitical instability and increasing complexity in global trade compliance.

A Targeted Amendment to a Broad Framework

The UK’s whistleblower regime is grounded in the Public Interest Disclosure Act 1998, which amended the Employment Rights Act 1996. Under this regime, whistleblowers receive legal protection from retaliation by their employer if they make a “protected disclosure” of certain categories of wrongdoing — typically to their employer or a “prescribed person.”

The Public Interest Disclosure (Prescribed Persons) Order 2014 (the “2014 Order”) designated specific public bodies as “prescribed persons” authorized to receive protected disclosures.

The 2025 Amendment expands this list by:

  • adding HM Treasury as a prescribed person for whistleblowing; and
  • prescribing specific sanctions-related matters that may be disclosed to:
    • The Secretary of State for Business and Trade (with respect to certain trade sanctions);
    • The Secretary of State for Transport (with respect to aircraft and shipping-related sanctions); and
    • HM Treasury (with respect to financial sanctions).

Why This Matters

These changes signal a clear policy shift toward integrating whistleblower protections into the UK’s sanctions architecture, in order to enhance sanctions enforcement. The effect is that whistleblowers will now enjoy greater confidence in their employment-related protections following a disclosure.

Critically, for a disclosure to be protected under the whistleblowing framework:

  • it must relate to a reasonable belief that one of the statutory categories of wrongdoing (e.g., a criminal offense, breach of legal obligation) has occurred or information in relation to that wrongdoing is being concealed; and
  • it must normally be made to the appropriate prescribed person and the disclosure must be in the public interest.

The alignment of these protections with sanctions enforcement reflects a recognition that whistleblowers can play a vital role in surfacing concealed or complex violations, particularly within multinational corporates and financial institutions.

What This Means for Businesses

For businesses, the 2025 Amendment increases exposure to scrutiny — not only from regulators, but also from employees who are now empowered to disclose non-compliance directly to authorities.

This is especially relevant for:

  • financial institutions navigating the UK’s financial sanctions framework;
  • logistics and maritime operators subject to transport sanctions; and
  • corporates engaging in dual-use or high-risk trade with jurisdictions subject to UK sanctions.

Failure to maintain adequate internal reporting mechanisms or whistleblower protections may lead to increased external disclosures, regulatory intervention, and reputational damage.

Practical Considerations

To mitigate risk and ensure compliance with the enhanced whistleblower regime, UK-based and international companies should:

  • update whistleblowing policies to reflect the expanded scope of protected disclosures, including the designation of HM Treasury as a “prescribed person”;
  • train compliance teams and employees on how to identify and escalate potential sanctions breaches and encourage internal reporting as a first step;
  • establish or enhance anonymous reporting channels to reduce the likelihood of external disclosures; and
  • review sanctions compliance frameworks to identify gaps in financial, trade, or transport-related controls.

The authors would like to thank trainee solicitor Samson Verebes for his contributions to this blog.

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