Printed from the Field Fisher Waterhouse web site
Web address: http://www.ffw.com/practices/competition_eu_regulatory/dawn_raids.aspx

Practices

Dawn raids

The European Commission and national competition authorities carry out unannounced inspections or dawn raids, which all businesses can be subject to.  If there is a reasonable suspicion that records related to the inspection are being kept elsewhere, inspections can be made at those premises too.

The way in which a dawn raid is handled can have very significant financial consequences, both for an organisation’s reputation and also for their market value. Fines can be imposed and enhanced where co-operation is inadequate and failure to secure privileged documents can also prejudice rebuttal and defence.   

Our service

We protect you by helping you to be prepared for a dawn raid and by acting quickly and decisively when a dawn raid occurs.

Preparation means ensuring that your appropriate staff have the right training. As the frontline interface, your security and reception personnel need to know what to say and who to call when officials first arrive. In-house counsel, IT support, the press office and other key personnel also all need to know their respective responsibilities should a raid take place. This is important because failure to comply with the duty of co-operation can result in fines being imposed or can count as an aggravating factor when the penalties are being calculated. 

Our experience

We have extensive experience in helping our clients to minimise the risk that they will attract unwanted regulatory attention, but to also ensure that they are prepared for any inspection that occurs. We have an outstanding reputation for vigorously defending our clients where they are the target of unannounced inspections. In particular, we can:

  • carry out a compliance audit to identify risk factors
  • provide dawn raid ‘first aid kits’
  • immediate response to a raid
  • follow on protection

Dawn raids: do's and don'ts

Officials from national competition authorities and/or the European Commission may call at any or all of your offices to investigate possible anti-competitive practices. They can do this if they have reasonable suspicion of an infringement. In many instances the suspicion will arise as a result of a tip-off, a complaint, or a whistle blower. The law obliges companies and individuals to co-operate. Key do’s and don’ts in the event of such a visit being made are included in these PDFs: English/Japanese