Expansion to Whistleblowing Protections for Sanctions Breaches
The UK Government has announced important changes to whistleblowing legislation, extending legal protections to individuals who report breaches of financial, trade and transport sanctions. These reforms, coming into effect on 26 June 2025, are intended to improve enforcement by encouraging greater transparency and information-sharing across regulated sectors.
Legislative update
The Public Interest Disclosure (Prescribed Persons) (Amendment) Order 2025 expands the scope of whistleblowing protection under the Employment Rights Act 1996. Specifically:
HM Treasury has been added as a “prescribed person”, allowing workers to report suspected breaches of financial sanctions directly and benefit from statutory protection against unfair dismissal and detriment.
The Secretary of State for Business and Trade and the Secretary of State for Transport are now also prescribed persons for the purposes of reporting trade and transport-related violations. This includes disclosures about breaches such as import/export restrictions, aircraft and shipping offences, and director disqualification measures.
These amendments ensure that workers who raise concerns about compliance failures within the UK’s sanctions regime are now legally protected in doing so.
Purpose and Impact
The legislative changes aim to:
Strengthen the enforcement of UK sanctions by making it easier and safer to report potential breaches
Improve the quality and quantity of intelligence reaching regulators and enforcement bodies
Align the UK more closely with international frameworks, such as those in the United States and European Union, where whistleblower protections in the context of sanctions are more established
Employer considerations
From 26 June 2025, employers should ensure that their internal reporting procedures, whistleblowing policies, and staff training are updated to reflect the broader scope of protection.
Creating a workplace culture where employees feel safe raising concerns internally is crucial. Failing to respond appropriately - or retaliating against those who raise issues - may result in legal claims under whistleblowing and employment protection laws.
Looking ahead
While this marks a significant expansion, the UK framework still falls short of some international models. Protections currently apply mainly to workers reporting on their current or former employers, which may not cover the full complexity of modern sanctions evasion, often involving third parties or intricate networks.
There is growing support for further reforms, including financial incentives for whistleblowers in economic crime cases, which are being explored by the Serious Fraud Office and others.
Conclusion
The expansion of whistleblowing protections signals the UK’s intent to take a more robust approach to sanctions enforcement. By broadening the categories of protected disclosures and prescribing relevant government bodies, these changes aim to support more effective oversight and encourage individuals to report concerns without fear of retaliation.
Contact our Whistleblowing Lawyers for Advice
If you have concerns about sanctions breaches or need expert guidance on whistleblowing protections, Osborne & Wise is ready to support you. Contact our experienced team today for confidential advice—available by phone or video call. Same-day appointments can be arranged to help you understand your rights and take the next step with confidence.