China Dawn Raid First Hour

A China dawn raid requires an immediate response protocol: identify the authority and legal basis, copy the notice, preserve documents and devices, assign employee escorts, and involve appropriate counsel. Antitrust, pharma and other sector investigations may add different substantive rules, but the first-hour preservation and control steps remain critical.

Identify the badge, copy the notice, shadow them, do not hide phones — deletion in the first hour is its own problem.

The first hour of a PRC dawn raid or on-site inspection is protocol: who is at the door (SAMR, PSB, tax, customs, CAC), what the notice authorises, who in the company meets them, where they may go, and a simultaneous call to counsel. Do not destroy WeChat. Employees should not freelance interviews. Privilege is limited. This upgrade keeps the live alias. Sector guides (pharma anti-corruption raids) stay put. Antitrust first-hour is /china-antitrust-investigation-first-hour.

The classification screen

4 questions before you choose the route.

This page identifies the right question and evidence. It does not determine the legal outcome on a reader’s facts.

Who is at the door?

Agency and notice.

Who

What may they take?

Devices, paper, questions.

Scope

Who shadows and logs?

One trained owner per team.

Shadow

Counsel inbound?

Now, not after lunch.

Counsel

Working rule: The first hour of a PRC dawn raid or on-site inspection is protocol: who is at the door (SAMR, PSB, tax, customs, CAC), what the notice authorises, who in the company meets them, where they may go, and a simultaneous call to counsel.

What changes the answer

The signal ledger.

These facts move the question beyond a label and into a product, money-flow and control analysis.

Signal

Ask the operating question

Why it changes the route

Delete WeChat groups

First reflex.

Worse.

Broader Investigations & Compliance analysis needed

Second related guide.

Do not.

Treat SAMR as a customer visit

No log, no counsel.

Failure.

Prepare before you escalate

Bring a compact evidence docket—not a pitch deck.

Give a compliance team or counsel the operating facts that reveal the perimeter.

01Inspection noticePhoto it.

02Visitor logNames and IDs.

03Device list they imagedWhat left the building.

Common confusions

Questions people ask before they build.

Short answers for orientation. The right result can change with the service model and current rules.

Can we refuse entry?

Generally no if the notice is valid. Argue scope, do not bar the door.

Is this the antitrust page?

Pharma raids have a sector guide.

Primary authorities

Reviewed sources support orientation, not a fact-specific assessment.

PRC Anti-Unfair Competition Law (NPC)

SAMR

Supreme People’s Procuratorate

National laws database (NPC)