EWJ August 62 2025 web - Journal - Page 13
How to Respond to a Dawn Raid:
A Guide to Dawn Raids in Financial
Crime Investigations
by Emilie Brammer, Associate , Dispute Resolution and Rhys Novak, Partner, Dispute
Resolution - www.charlesrussellspeechlys.com
Following the Serious Fraud Office’s (SFO)
announcement in February 2024 that it had “already
gone through more front doors in the last three months than
in the last three years” and its stated aim to “become a more
assertive” law enforcement agency, it is clear the SFO is
keen to speed up investigations. Over a year later, the
SFO’s enthusiasm to maintain momentum remains
clear, most recently evidenced by the arrest of three
individuals at the end of April 2025 following dawn
raids undertaken by more than 70 investigators across
five properties in connection with alleged bribery by
UK company, Blu-3.
familiarity with the legal, practical and organisational
foundations of a raid, is essential to mitigate the impact
of a raid and protect a company’s rights and interests.
This article will look at the scope of the powers of both
the SFO and the Financial Conduct Authority (FCA)
to undertake dawn raids, how a company can prepare
for a dawn raid, and practical steps that can be taken
to pro-actively manage a raid and its aftermath.
Which authorities can conduct a dawn raid in
financial crime investigations?
Dawn raids can be undertaken by a number of UK
agencies and authorities including (but certainly not
limited to) the SFO and the FCA. HMRC is another
obvious example.
Companies should familiarise themselves with (or
remind themselves of) the complexities associated
with dawn raids. Forward planning, ensuring
EXPERT WITNESS JOURNAL
11
AUGUST/SEPT 2025
