On 21 May 2025, the Public Interest Disclosure (Prescribed Persons) (Amendment) Order 2025 was laid before Parliament. Coming into force on 26 June 2025, it amends the Public Interest Disclosure (Prescribed Persons) Order 2014 by adding HM Treasury as a new prescribed person for disclosures relating to breaches of UK financial sanctions, and expanding the matters that can be disclosed to the Secretary of State for Business and Trade and the Secretary of State for Transport expressly to include disclosures relating to sanctions.

The purpose of the changes is to extend whistleblower protection to encompass sanctions-related functions, to enhance transparency and accountability within the Government, and to improve oversight in relation to misconduct or abuse in relation to UK sanctions.

What is the UK sanctions framework?

UK sanctions are part of the policy objectives designed to protect national security, promote global peace and security, and defend international norms and standards. Sanctions can include financial restrictions (such as asset freezes), trade measures (such as arms embargoes), immigration controls (e.g. travel bans), and transport sanctions (on aircraft and shipping).

The principal piece of UK sanctions legislation is the Sanctions and Anti-Money Laundering Act 2018 (SAMLA) which includes powers to make regulations imposing new sanctions, as well as rules and procedures regarding the types of sanctions that may be imposed, the amendment and lifting of sanctions, and the enforcement of sanctions (such as by way of fines and prosecution).

Other legislation relevant to the UK sanctions regime includes the Counter-Terrorism Act 2008, the Policing and Crime Act 2017, the Immigration Act 1971 and the Economic Crime and Corporate Transparency Act 2023.

How are whistleblowers protected?

Under the UK whistleblowing framework, workers are protected from unfair dismissal and detriment if they report certain types of wrongdoing, known as protected disclosures. To qualify for protection, the disclosure must be made to specific individuals or bodies. These bodies include the worker’s employer, a legal adviser, or a prescribed person.

With the addition of HM Treasury as a prescribed person, individuals who report to HM Treasury suspected sanctions violations in relation to financial transactions or services will be legally protected as whistleblowers under the Employment Rights Act.

With the addition of trade sanctions to matters that may be disclosed to the Secretary of State for Business and Trade as a prescribed person for whistleblowing, individuals who report suspected violations of trade sanctions (including import/export sanctions and director disqualifications sanctions) will be legally protected.

And with the addition of transport and licensing sanctions to matters that may be disclosed to the Secretary of State for Transport as a prescribed person for whistleblowing, individuals who report suspected violations of transport sanctions (including aircraft and shipping) and related licensing offences will also be legally protected.

Implications for organisations

Organisations should look to prepare now by taking the following steps:

  1. Organisations should review and update any internal whistleblowing policies to reflect that HM Treasury is now a prescribed person for sanctions-related disclosures.
  2. Staff should be informed about the new reporting avenues and protections available.
  3. Organisations should check that sanctions compliance programs are robust, and that potential breaches are identified and addressed promptly.
  4. Organisations should foster an environment where employees feel comfortable reporting concerns internally before escalating to external bodies.

By taking these steps, organisations can demonstrate a commitment to legal compliance and ethical conduct, while also protecting themselves from potential legal and reputational risks associated with sanctions breaches.

If you have any questions about whistleblowing, please contact employment lawyer Clive Howard.

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This article is for general information purposes only and does not constitute legal or professional advice. It should not be used as a substitute for legal advice relating to your particular circumstances. Please note that the law may have changed since the date of this article.