SAMR investigations · 05 Editorial guide
China Antitrust Investigation Response
First-hour, information-request and leniency posture when an authority is in motion.
First job Preserve the record and identify the process stage before ordinary research.
Use this route when an information request, raid or closing date changes the next step. Confirm current rules on the national decision desk.
Direct answer
What this page decides
01
This page owns AT07: the antitrust-specific response to an inquiry, dawn raid, interview or information request from SAMR (or a local AMR). Scene choreography for any authority is the Investigations dawn-raid L4; this page adds standstill of document destruction, antitrust privilege hygiene, parallel criminal risk, and leniency/commitment routing. Supporting: /china-antitrust-investigation-first-hour. Do not invent leniency deadlines.
At a glance
Which fact changes the next route
Use the fact that changes ownership or urgency to decide the next move.
| Question | Why it matters | Next route |
|---|---|---|
| Officials on site now? | Scene control first. | /legal-guides/investigations-compliance/dawn-raids-regulatory-inspections and /china-dawn-raid-first-hour |
| Letter or phone from SAMR? | This page. | Counsel, hold, single channel. |
| Possible cartel? | Leniency fork. | Horizontal L4 + counsel immediately. |
| Deal filing already live? | Do not freelance a second narrative. | Merger L4 owner stays on the filing. |
Scope
What this page owns — and what it does not
Practical workflow
Action, evidence, legal gate, output
| Action | Documents / evidence | Legal gate | Output |
|---|---|---|---|
| Authenticate the contact | Letter, credentials | Do not ignore; do not overshare | Verified contact |
| Legal hold | Custodians, WeChat, email | No deletion | Hold |
| If on site, run raid protocol | Escorts, log | National dawn-raid L4 | First-hour log |
| Interview discipline | Who may speak | Truth, no speculation | Channel |
| Response and remedies | Facts, commitments, leniency | Counsel | Strategy |
Documents
What to gather before the next call
These items help clarify the file; they are not a legal requirement list.
| Item | Why needed | Who holds it | Risk if missing |
|---|---|---|---|
| Notice or questionnaire | Scope | GC | Missed deadline |
| Hold list | Evidence | IT | Spoliation |
| Org chart of the product/team | Who SAMR will ask for | HR | Wrong spokesperson |
Common failure points
Where files usually break
Drafting a PR narrative while the raid is running.
Treating SAMR like an internal audit.
Skipping the national dawn-raid page because ‘it is only antitrust’.
FAQ
Narrow follow-ups owned by this page
Is this the same as the investigations hub raid page?
No. IC05 is any authority on site. This L4 is the AML file after identity is known.
Quick answers
Need the short version? Start with one narrow question.
These explainers answer one question. They do not replace this topic route or a deep guide.
Curated resources
Open the asset that matches this job.
China antitrust decision desk
National decision desk for merger control, conduct and investigations. This remains the long-form owner.
Enforcement track
Investigation first-hour questions on the national desk.
Investigation first-hour checklist
First-hour checklist on the national desk.
Counsel hand-off
What to bring when you instruct
Instruct antitrust investigations counsel now. Bring: the notice, who has been spoken to, and whether a deal filing is live.
Local context
Add the city only when it changes implementation.
Local SAMR practice can matter after the national question is identified.
Open city and province guidesCounsel hand-off
Need competition counsel?
This hub organises transaction, conduct and investigation routes. It is not a filing decision.
Find competition counselLegal review
Who reviewed this guide
Need qualified counsel?
Move carefully. Move with a record.
Use the portal to identify counsel for this practice and related China-side issues.