UK: Whistleblowing: Sanctions Breaches
Authors: Stephen Miller and Corinna Harris
The government is making changes to whistleblowing legislation to strengthen the implementation and enforcement of UK sanctions.
The government is introducing changes to whistleblowing legislation in respect of qualifying disclosures made to a prescribed person concerning breaches of UK sanctions. From 26 June 2025 statutory protection from unfair dismissal and detriment will be extended to workers who report trade sanctions breaches to HM Treasury, the Secretary of State for Business and Trade, and/or the Secretary of State for Transport.
Key Action Points for Human Resources and In-house Counsel
The purpose of these changes is to strengthen the UK sanctions framework by helping whistleblowers qualify for protection when disclosing information about breaches of sanctions.
Separately, the drive to introduce whistleblower incentives for reporting complex economic crime is gathering momentum. In its Annual Business Plan the Serious Fraud Office has confirmed it is progressing whistleblower incentivisation reform. In addition, the Fisher review into disclosure and fraud offences will include a detailed evaluation of incentives for whistleblowers.
The Public Interest Disclosure (Prescribed Persons) (Amendment) Order 2025
