As the Trump administration decries leaks to the news media, the UK government is considering proposals of its own that would significantly hike penalties for people who reveal state secrets.
Spies and civil servants who leak state documents would face 14 years in jail in the first overhaul of the Official Secrets Act (OSA) in about 100 years.
Until now the UK government has had a rather lenient position on leaks, with a maximum of just two years in jail, but the changes being discussed would raise that significantly.
The consultation would make it illegal to disclose any information about the security services.
It would also ban journalists from handling leaked secrets. That's triggered fears that the media would no longer choose to disclose wrongdoing, for fear of prosecution. Some analysts say this would instead force whistleblowers to leak online or abroad, and could also lead to an abuse of power by security agencies.
One of the principal reasons for these harsher laws is Edward Snowden. Even in the UK, his leaks, as well as Chelsea Manning’s, shook the intelligence services to the core, leading to an urgent review. Although there haven’t been leaks on Snowden’s level in the UK, there have been breaches.
This topic has recently been widely discussed in the U.S., following the leaks leading to Gen. Mike Flynn's resignation as national security adviser. It remains to be seen what would happen to the people who leaked information about his call with Russia’s ambassador, in which they discussed sanctions.
The U.S. doesn’t have an Official Secrets Act. It has only the Espionage Act – which carries a possible sentence of 30 years.
Experts in the U.S. have said the creation of a specific secrets act is unlikely, because as it stands, people are prosecuted under the more serious charge of espionage – which is said to create a greater deterrent.
But others argue that any deterrent has now been undermined, following the clemency granted by then-President Obama to Chelsea Manning.