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Publication
Keeping your dawn raid guidance current
Unannounced inspections or ‘dawn raids’ are used by antitrust authorities to obtain evidence when there are suspicions that individuals or businesses have infringed the antitrust rules.
Global | Publication | September 2020
In the last 12 months, new and improved technology tools have come to market which can provide cost and time efficiencies in delivering an IBOR transition project. However, relying on these tools to do things they can’t, or failing to use them where they could add real value, has the potential to make a material difference to project delivery.
The use of new tools and approaches mean IBOR transition is a multidisciplinary project, in which delivery expertise, technological understanding and legal skills are equally important. It is vital that a project team is built which recognises the value of these different skillsets so as to allow them to work effectively together. The importance of this is hard to overstate.
A full due diligence on external support is strongly recommended. Has the internal team seen the tools that will be relied on? Have they been through the plan in sufficient detail that they would stake the success of the project on it? Assuming delivery is more sophisticated than a typical mandate, in diligence should be too, especially if the methodologies are new to some on the internal team. Effective risk transfer to an external provider for such a business critical project like IBOR is almost impossible.
The internal team needs to be appropriately confident in the solution.
An externally provided solution should be built around the priorities and particular needs and constraints of your business. Your supplier should also be able to offer insight based on their experience with other organisations, so that you benefit from the learnings from similar projects.
The challenge of securing budgets and resources is made significantly greater if the risk’s and challenges of the project are not fully understood. There are also vital internal stakeholders – such as information security – who may not have been closely involved in projects like this in the past. Early and effective engagement is vital.
Publication
Unannounced inspections or ‘dawn raids’ are used by antitrust authorities to obtain evidence when there are suspicions that individuals or businesses have infringed the antitrust rules.
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