SAMR team at HQ at 08:30
Verify, call counsel, freeze deletion, escort, log. Do not start an internal town hall.
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Dawn Raids · 03 Editorial guide
China Dawn Raid and Regulatory Inspection Response Guide
Give first-response routing for unannounced inspections without obstructing authorities or destroying evidence. This topic routes; it does not decide the legal outcome on your facts.
First job Give first-response routing for unannounced inspections without obstructing authorities or destroying evidence.
Decision railauthority arrives → verify → control scene → preserve → accompany → record → escalate
See routing factsAuthority-on-site or evidence-hold route
Open dawn-raid routingUse this only when an inspection, raid or preservation clock changes the next step. This hub is orientation, not a raid playbook.
Start here
Key considerations
The first questions are about urgency, governance and preservation — before collection expands or interviews begin.
- Which authority is present, who are the officials and what credentials, notices, authorisations or requests have they presented?
- Who is the designated response lead, local counsel contact, IT contact and contemporaneous log keeper?
- What people, rooms, systems, documents or devices are in scope — and how can the company cooperate without obstruction, deletion or unnecessary disclosure?
Direct answer
What this page decides
Owner
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02
This page owns on-site inspection and dawn-raid choreography: identify the authority, verify documents, assign escorts and a log, stop deletion, and record what was asked, copied or taken. It does not decide the underlying antitrust, bribery, tax or customs case. Pharma and device teams keep the sector playbook as an overlay, not a second national raid owner. Antitrust first-hour screens remain under the Antitrust hub. Employees should be truthful and not speculative. Do not invent search-warrant formalities from another jurisdiction.
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 |
|---|---|---|
| Who is at the door? | SAMR, public security, tax, customs and others have different mandates. | Authenticate before any document dump. |
| Are they asking employees questions now? | One response channel; no freelance interviews. | Escort + log; call counsel. |
| IT wants to ‘help’ by wiping a laptop? | Deletion can be obstruction. | Hold systems; record imaging. |
| Is this really an internal allegation? | Wrong playbook. | Internal investigations L4. |
| Pharma sales team on a hospital campus? | Sector overlay. | Keep this page as national owner; use pharma playbook as overlay. |
| Follow-up deadline on the visit notice? | The first-hour log drives the response clock. | Counsel + chronology. |
Scope
What this page owns — and what it does not
Whoreception, GM, GC, IT and designated raid team at a mainland China site.
Eventunannounced or short-notice authority presence.
This page owns scene control and the contemporaneous record.
Exclusionsmerits of the investigation; criminal defence in custody; internal-investigation scoping after they leave.
National owner of dawn-raid routing. Pharma URL is overlay.
Practical workflow
Action, evidence, legal gate, output
| Action | Documents / evidence | Legal gate | Output |
|---|---|---|---|
| Receive and verify | Credentials, notices, authorisations | Do not refuse lawful entry | Identity and mandate log |
| Notify the response team | Raid roster, counsel numbers | One speaker to officials | Escort assignments |
| Instruct employees | Short holding script | Truthful, no speculation, no deletion | Floor message |
| Accompany searches | Room list, device list | Privilege / privacy flags to counsel | Search accompaniment notes |
| Record copies and seizures | Inventory of what left the building | Ask for copies / receipts where the process allows | Seizure / copy schedule |
| Debrief and split tracks | First-hour log, follow-up dates | Internal investigation is a later owner | Counsel brief |
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 |
|---|---|---|---|
| Official credentials and notices | Mandate and identity | Reception / escort | Cannot later prove who asked for what |
| Contemporaneous log | Times, rooms, questions, commitments | Designated logger | Memory after the team leaves |
| IT access and export record | What systems were opened | IT | Unexplained imaging |
| Employee interview list | Who was questioned | HR / escort | Inconsistent later statements |
| Follow-up request letter | Response clock | GC | Missed deadline |
Common failure points
Where files usually break
Leaving officials alone in a records room.
The GM arguing the merits at reception.
Staff photographing the raid for WeChat groups.
Routine auto-delete jobs left running.
Handing over personal phones without a request or a record.
Treating a tax inspection script as an AML raid script.
Forgetting that a parallel criminal risk may already exist.
Illustrative forks · not case advice
Moments where sequence matters
Public security asking for a named employee
Criminal Defense owns the person-risk. This page still owns site control if they are searching premises.
After they leave, sales wants to ‘align stories’
That is obstruction risk. Move to Internal investigations with a preservation hold, not a rehearsal.
FAQ
Narrow follow-ups owned by this page
Must we let them in before counsel arrives?
Do not obstruct a lawful inspection. Request counsel attendance while cooperating. Exact powers depend on the authority and instrument produced.
Can employees refuse questions?
Do not invent a US-style right to remain silent for every inspection. Instruct truthfulness, no guessing, and escalation to the response lead.
Is the pharma dawn-raid playbook the national page?
No. It is a sector overlay. This L4 is the national owner.
Where is the first-hour Quick Answer?
china-dawn-raid-first-hour. It must keep linking here.
Decision map
Keep the question bounded.
- Authenticate and escalateReceive officials professionally, verify and record credentials and documents, notify the response team and request counsel attendance where appropriate. Do not delay or obstruct lawful activity.
- Control the response channelAssign escorts and one log keeper. Route questions and requests through the response lead while employees remain truthful and avoid speculation.
- Protect evidence and systemsStop deletion and routine destruction, preserve relevant systems, and have IT record searches, exports, imaging or access. Do not hide, alter or remove material.
- Close the first-hour recordLog what was requested, reviewed, copied, taken, said and committed. Preserve follow-up deadlines and separate regulator response from any internal investigation that follows.
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.
01
Supporting guide
02Pharma & Device Anti-Corruption Dawn Raid Response Playbook
A sector-specific reference for responding to anti-corruption dawn raids in life sciences.
Related practice
03Data Privacy & Cybersecurity national guide
Use this guide for China data privacy, cybersecurity and cross-border data-transfer questions.
Related practice
Criminal Defense national guide
Use this guide for suspect rights, detention and criminal-procedure questions.
Helpful to prepare
Facts that make the next conversation clearer.
These items are orientation aids, not a legal requirement list.
dawn raid responseSAMR inspectionpublic security visitcredentialsdocument requestsfirst 120 minutes
Related legal file
Stay in this practice; send neighbouring questions to their owner.
Counsel hand-off
What to bring when you instruct
Instruct regulatory investigations counsel immediately (antitrust, anti-corruption, tax or criminal as the credentials indicate). Bring: copies or photos of credentials and notices, the live log, IT export list, names of employees questioned, and any follow-up date. Do not circulate a narrative email while the team is still on site.
Local context
Add the city only when it changes implementation.
National routing first. Local notary, court or bureau practice second.
Open city and province guidesCounsel hand-off
Need qualified counsel?
Investigations counsel can define scope, preserve evidence, manage interviews and privilege, and coordinate internal findings with reporting or enforcement risk.
Find investigations 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.