The dawn raid protocol: the first six hours decide the next six years

An unannounced search is not the start of an investigation. It is the middle of one. By the time officers reach your premises, an agency has usually spent months building a file. The raid exists to capture what the file cannot: original documents, live devices, and unguarded statements from your staff. The company's task in the first six hours is narrow. Do not obstruct. Do not volunteer. Record everything. This briefing sets out how, as the law stands in early 2026.

Who can knock

Four agencies account for most unannounced visits to businesses in Pakistan.

The National Accountability Bureau operates under the National Accountability Ordinance 1999, as substantially amended in 2022 through 2024. Its search and seizure powers are exercised in aid of inquiries and investigations into offences under the Ordinance. Following the 2022 amendments and the litigation that ended with the intra-court appeal decided in 2024, the amended Ordinance holds the field, including a monetary threshold for NAB jurisdiction of five hundred million rupees [THRESHOLD AND CURRENT STATUS TO BE VERIFIED BY REVIEWING LAWYER].

The Federal Investigation Agency exercises police powers under the FIA Act 1974 read with the Code of Criminal Procedure 1898. Searches proceed under warrant (sections 96 to 103 CrPC) or, in defined circumstances, without one (section 165 CrPC). Section 103 CrPC requires searches to be witnessed by independent persons; officers routinely bring their own. Cybercrime matters formerly with the FIA now sit with the National Cyber Crime Investigation Agency under the Prevention of Electronic Crimes Act 2016 as amended in 2025, and searches of data ordinarily require judicial authorisation under that Act [SECTION REFERENCES TO BE VERIFIED BY REVIEWING LAWYER].

The Competition Commission of Pakistan may enter and search premises under section 34 of the Competition Act 2010, and section 35 permits forcible entry with prior authorisation. CCP inspections focus on evidence of prohibited agreements and abuse of dominance.

The Federal Board of Revenue may enter and search business premises under section 175 of the Income Tax Ordinance 2001, with parallel powers under the sales tax law. The SECP holds inspection and investigation powers over companies under the Companies Act 2017 [SECTION REFERENCES TO BE VERIFIED BY REVIEWING LAWYER], though it rarely arrives unannounced.

The first hour: at the door

Reception decides more than it knows. Every front desk should hold a one-page instruction: ask the officers to wait in a meeting room, take no questions, and call two numbers — the designated internal coordinator and external counsel. Officers cannot be refused entry where their authorisation is valid, but a short wait while counsel is called is not obstruction. Ask for it politely and note the response.

Before anything else, examine the paperwork. Identify the agency, the statutory power invoked, the premises named, the subject matter described, and the names of the officers present. Photograph or copy the warrant or authorisation if permitted. If a document names a different address, a different company, or a different subject, say so once, calmly, on the record — and then let the officers decide how to proceed. Do not physically resist a search you believe is defective. The remedy for an unlawful search is in court, not in the corridor.

Hours two to five: shadow, record, protect privilege

Assign one employee to each officer. The shadow's job is to watch and write: which rooms were entered, which cabinets opened, which files and devices taken, what was said. This running note is often the only contemporaneous record the company will have, and it becomes the backbone of any later challenge.

Privilege must be claimed in the moment or it may be lost in practice. Communications with the company's advocates are protected under Articles 9 and 12 of the Qanun-e-Shahadat Order 1984. Whether that protection extends to in-house counsel is not settled in Pakistan [POSITION TO BE VERIFIED BY REVIEWING LAWYER]. Where officers reach for files or mailboxes containing legal advice, state the claim, ask that the material be sealed pending resolution, and record the request even if it is refused.

Employees may be asked questions. The company cannot instruct staff to refuse all cooperation, but every employee is entitled to answer only what is asked, to say "I do not know" when true, and to decline to speculate. No employee should sign a statement without reading it. Article 13 of the Constitution protects an accused against self-incrimination; a person who is not yet accused should still answer with care.

Demand an inventory. Officers seizing documents or devices should list what they take; the CrPC and agency rules contemplate seizure memos. Check the list against the shadows' notes before signing anything, and note discrepancies in writing on the memo itself.

What you must not do

Three mistakes convert a survivable search into a second case. First, destruction: deleting emails, shredding files or wiping devices during or after a raid can constitute a separate offence, including under section 201 of the Pakistan Penal Code and under electronic-crimes provisions. A litigation hold should issue within the hour. Second, obstruction: blocking officers, hiding personnel or spiriting documents off-site invites both charges and adverse inference. Third, volunteering: explanations offered in the heat of the day, by staff who do not know the file, tend to harden into admissions. Answers come later, in writing, through counsel.

After the team leaves

The sixth hour matters as much as the first. Convene the coordinator, the shadows and counsel the same day. Consolidate the notes into a single record while memory is fresh. Image the systems that were searched so the company knows what the agency has. Consider whether a listed company's continuous disclosure obligations under the PSX Rule Book are engaged [POSITION TO BE VERIFIED BY REVIEWING LAWYER]. Decide, with counsel, whether to challenge the search, engage with the agency, or both. And brief the board — accurately, briefly, and in a privileged setting.

What this means for you

Write the protocol before you need it. A one-page reception instruction, a designated coordinator with a deputy, and external counsel's number on the wall cost nothing and change everything. Train reception and security twice a year; a raid usually begins before senior management arrives. Keep privileged material segregated and marked in the ordinary course, because privilege claimed in advance is easier to defend than privilege asserted mid-search. Issue a litigation hold the same morning and confirm it in writing. Never let an employee sign an unread statement, and never let anyone — however senior — improvise answers on the day. If your company operates in a regulated or politically exposed sector, rehearse the protocol once a year with a tabletop exercise. The companies that emerge intact from dawn raids are not the ones with the best arguments. They are the ones with the best notes.