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:
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