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November 17, 2025 55 mins

Today’s episode is part of a special series of Following the Rules produced in association with Simmons & Simmons, an international law firm supporting financial institutions across the global regulatory landscape.

The series offers practical insights to help financial services firms navigate legal, regulatory, technological, and cultural change.

In this episode, we’re diving into one of the most intense moments a business can face - a dawn raid.

When Nick Ephgrave took over as Director of the UK Serious Fraud Office in 2023, he’s pledged “swifter action and more dawn raids” - a clear signal that the agency is refocusing on proactive, visible enforcement.

But what does a dawn raid actually look like in practice? How should firms respond when investigators appear unannounced at the door? And how can businesses prepare, both legally and culturally, for such a high-pressure event?

To answer these questions, we’re joined by two experts on the topic:

  • Camilla de Silva, who spent over five years at the SFO, rising to Joint Head of the SFO’s Fraud, Bribery and Corruption division, before joining Simmons & Simmons in 2020 as a Partner in its Disputes and Investigations group. Since 2023, she has lead Simmons & Simmons’ Corporate Crime and Global Investigations group; and,
  • Emma Isaac, who worked as criminal legal adviser before moving to the SFO in 2013. In February, she became a member of the agency’s senior leadership team when she was appointed Joint Head of the SFO’s Fraud, Bribery and Corruption division.

Together, they discuss how enforcement dynamics are shifting, what mistakes companies tend to make under pressure, and what practical steps legal and compliance teams can take today to be ready if the SFO comes knocking.

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Short on time? You can read the episode highlights on The Banker's Risk & Regulation hub...

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