Dawn Raids Are Back: What Sanofi’s Case Teaches Us About Compliance Readiness

On 30 September 2025, the European Commission carried out unannounced inspections at Sanofi’s premises in France and Germany, as part of an antitrust investigation into the flu vaccine market (Link to the news). The focus? Possible exclusionary practices that may amount to anticompetitive disparagement—a risk not always top of mind for compliance teams used to focusing on classic red flags like price-fixing or bid-rigging.

Why this matters for compliance officers

Dawn raids are a stress test for any compliance program. They come without warning, put employees under immediate pressure, and can have huge financial and reputational consequences. The Sanofi case shows that risks are not always obvious. Anticompetitive disparagement (e.g., spreading misleading information to undermine competitors) is subtler than cartel behavior—but no less serious.

Three takeaways for companies

1. Have a clear dawn raid protocol
   Employees should know exactly what to do if investigators arrive. Who talks to them? Where are the key documents? What are the company’s rights?
2. Train your teams regularly
   Protocols are only useful if people remember them under pressure. Training helps staff react calmly and consistently.
3. Map risks beyond the usual suspects
   Many compliance teams still focus heavily on pricing issues. But exclusionary practices, tying, or disparagement can fly under the radar. A robust competition risk map ensures nothing is overlooked.

The bigger picture

For compliance officers, the lesson is clear: competition risks are diverse, dynamic, and often unexpected. A well-prepared company is not just one that has a Code of Conduct—it’s one that anticipates less visible risks, keeps protocols fresh, and ensures every employee can act with confidence when the Commission comes knocking.

👉 At Naltilia, we help companies build automated risk maps and design controls and protocols —so you’re not caught off guard when regulators arrive.