Sanction whistle-blower to be protected in the UK

JUNE 26^TH, with the Public Interest Disclosure (Prescribed Persons) (Amendment) Order 2025 entering into force, OFSI has published new guidance on confidential reporting.

Public Interest Disclosure (Prescribed Persons) (Amendment) Order 2025

• The Public Interest Disclosure (Prescribed Persons) (Amendment) Order 2025 (Statutory Instrument 2025 No. 604) is a UK legislative update that came into force on 26 June 2025.
• It amends the Public Interest Disclosure (Prescribed Persons) Order 2014, which is part of the framework under the Employment Rights Act 1996 that protects whistleblowers.

🔍 Key Changes Introduced

1. Expanded List of Prescribed Persons:
• The amendment adds HM Treasury as a prescribed person for disclosures related to UK financial sanctions.
• It also expands the scope of disclosures that can be made to:
• The Secretary of State for Business and Trade, now including matters related to trade sanctions under the Sanctions and Anti-Money Laundering Act 2018.
• The Secretary of State for Transport, with broader coverage of transport-related sanctions.
2. Purpose:
• To strengthen whistleblowers protections by ensuring that individuals who report breaches of financial, trade, or transport sanctions are legally protected from retaliation (e.g., dismissal or detriment at work).
3. Policy Rationale:
• Sanctions are a critical part of the UK’s regulatory and foreign policy framework.
• The government aims to encourage transparency and compliance by making it safer for individuals to report wrongdoing in these sensitive areas.
4. Impact on Businesses:
• No new regulatory burdens are imposed.
• Businesses are expected to familiarize themselves with the updated list of prescribed persons and the types of disclosures covered.
5. Geographic Scope:
• The Order applies to England, Wales, and Scotland.

Guidance

1. This guidance applies to anyone who wishes to confidentially report information to OFSI about suspected breaches of UK sanctions, including those who consider themselves whistleblowers.
2. The amendments will help whistleblowers qualify for employment protections when disclosing information about financial sanctions to OFSI.
3. Please note that this guidance and the associated processes are separate from those relating to professional or statutory obligations to report to OFSI.
4. Please note, if you have a statutory or professional obligation to report to OFSI you should (unless you have identified a need to use this confidential process) report the information via the compliance reporting form process as outlined here.
• https://www.gov.uk/guidance/suspected-breach-of-financial-sanctions-what-to-do

References

1. The Public Interest Disclosure (Prescribed Persons) (Amendment) Order 2025 https://www.legislation.gov.uk/uksi/2025/604/made
2. Unlocking Whistleblowers Protections: A New Dawn for Sanctions Enforcement thttps://www.transparencynews.co.uk/articles/1615
3. To view this guidance, click here:
• https://www.gov.uk/guidance/confidential-reporting-to-ofsi
• https://www.gov.uk/guidance/suspected-breach-of-financial-sanctions-what-to-do