UK Government updates its guidance on reporting on breaches of trade sanctions and new law on disclosure is laid in Parliament

On 21 May 2025, the Department for Business Trade and Office of Trade Sanctions Implementation (“OTSI”) updated their guidance Report a suspected breach of trade sanctions by adding ‘Whistleblowing for trade sanctions’ section.

From 26 June 2025, a worker can report about a person or business they think is committing a breach of trade sanctions that are implemented and enforced by OTSI. These could include trade prohibitions in relation to (the below list is not exhaustive):

• military goods and technology
• luxury goods
• oil refining goods and technology
• iron and steel products
• Russia’s vulnerable goods and technology (as specified in Schedule 3I to the Russia (Sanctions) (EU Exit) Regulations 2019 (“Regulations”)
• sectoral software and technology (as specified in Schedule 3IA to the Regulations)
• provision of technical assistance, armed personnel, financial services or funds, or associated brokering services where such provision enables or facilitates the conduct of certain military activities (as specified in Chapter 2 of Part 5 of the Regulations, regulation 30)
• services relating to a relevant infrastructure sector in non-government controlled Ukrainian territory (as specified in Chapters 5 and 6 of Part 5 of the Regulations)
• services relating to tourism in non-government controlled Ukrainian territory (as specified in Chapter 6 of Part 5 of the Regulations)
• internet services (as specified in Chapter 6A of Part 5 of the Regulations)
• professional and business services (as specified in Chapter 6B of Part 5 of the Regulations)

The reporting of wrongdoing should be in public interest, which means that the disclosure may affect the general public.

Further to this, on 22 May 2025, the Public Interest Disclosure (Prescribed Persons) (Amendment) Order 2025 was laid before parliament. The new law, which will enter into force on 26 June 2025, amends whistleblowing legislation to strengthen the implementation and enforcement of UK sanctions.

A worker that will act as a whistleblower will qualify for the employment protections set out in the Employment Rights Act 1996. They cannot suffer detriment or dismissal at work because of their disclosure.

Updated: 27 May 2025

How Gherson can assist

The Gherson team have years of experience advising on compliance matters, including sanctions. We regularly advise clients on sanctions laws and can assist companies develop policies and systems aimed at prevention of sanctions risks.

If you have any questions arising from this blog, please do not hesitate to contact us for advice, send us an e-mail or, alternatively, follow us on X, Facebook, Instagram or LinkedIn to stay-up-to-date.

The information in this blog is for general information purposes only and does not purport to be comprehensive or to provide legal advice. Whilst every effort is made to ensure the information and law is current as of the date of publication it should be stressed that, due to the passage of time, this does not necessarily reflect the present legal position. Gherson accepts no responsibility for loss which may arise from accessing or reliance on information contained in this blog. For formal advice on the current law please do not hesitate to contact Gherson. Legal advice is only provided pursuant to a written agreement, identified as such, and signed by the client and by or on behalf of Gherson.

©Gherson 2025