Background
INTERPOL is one of the largest intergovernmental organizations, including 196 member countries, more than the United Nations itself. The INTERPOL Constitution stipulates that the organization’s aims are to “ensure and promote the widest possible mutual assistance between all criminal police authorities” and “establish and develop all institutions likely to contribute effectively to the prevention and suppression of ordinary law crimes” (Article 2). INTERPOL’s contribution to fighting crime is hard to overstate. In its more than one hundred years of existence, it has played a major role in bringing numerous dangerous criminals to justice, rescuing victims, recovering stolen property, and preventing crime. Unfortunately, INTERPOL has also become a powerful tool for oppressive regimes who have learned to utilize its channels to persecute their opponents. This abuse is widespread and in direct violation of the INTERPOL Constitution which strictly prohibits the organization from engaging in any activity of a political, military, religious or racial nature, and which requires it to act in the spirit of the Universal Declaration of Human Rights (Articles 2 and 3).
INTERPOL has a review mechanism which is designed to weed out requests from member countries that violate the organization’s rules. It also has a redress mechanism for victims of the abuse of its resources – the Commission for the Control of INTERPOL’s Files (CCF). CCF is an independent body with exclusive jurisdiction to adjudicate complaints from individuals challenging a government’s use of its resources. From the very beginning, these mechanisms have had major flaws, they have failed to stop INTERPOL abuse among non-democratic countries and they have fallen short of providing effective redress for the victims of these abuses.
Within the past several years, under pressure from human rights activists and advocacy organizations, INTERPOL has carried out reforms, which, however, still have not addressed a number of issues. INTERPOL’s pre-publication screening of government requests for international police cooperation remains deficient, the avenue of recourse offered by CCF is still short of compliance with basic fair trial standards, and its autonomy and independence are still fragile. As a result, oppressive regimes, undeterred, continue to abuse INTERPOL with considerable success, and numerous activists, reporters, entrepreneurs and other individuals continue to be detained and suffer significant economic and emotional hardships.
Why is it so easy for governments to place individuals on the INTERPOL wanted list?
To communicate via INTERPOL’s channels, member countries use notices, diffusions and messages, collectively referred to as “requests.” The INTERPOL notice system consists of a set of color-coded notices, each of which has a specific purpose. Among these is the Red Notice, a request to “seek the location of a wanted person and his/her detention, arrest or restriction of movement for the purpose of extradition, surrender, or similar lawful action.” Under its rules, INTERPOL, specifically its General Secretariat, must conduct a legal review of all Red Notices to ensure their compliance prior to their publication. That review has a very limited scope, however, and, as a result, INTERPOL frequently fails to recognize unlawful Red Notices which it therefore proceeds to publish in its databases with devastating consequences for the individuals affected. This is clear from the fact that in 68 percent of the 500 applications for deletion that were decided by CCF in 2023, it found that data being processed by INTERPOL did not comply with its rules. Similarly, in 2024, of 703 admissible deletion requests, 164 were removed by NCBs upon being challenged by applicants without the CCF’s review, and the CCF found over fifity percent of the remaining cases to be not compliant with the rules.
The prohibition on the organization’s engagement in activities of a political, military, religious or racial character and the condition that any processing of information via INTERPOL’s channels must be in the spirit of the Universal Declaration of Human Rights are not the only requirements that Red Notices and other government requests must meet. For example, a Red Notice must also contain the individual’s identity particulars (e.g., name, sex, date of birth, physical description), a charge of a serious ordinary-law crime that also satisfies the penalty threshold and does not derive from a private matter or dispute, a reference to a valid arrest warrant, and a summary of the facts of the case. It should be easy for INTERPOL to quickly evaluate prior to publishing a Red Notice whether the government has provided the identity particulars, and whether it has specified the provision in the country’s criminal law or met the penalty threshold. However, the summary of the facts of the case that governments must include in their requests for the publication of a Red Notice is usually very brief, only several sentences long, and not enough to assess the circumstances surrounding the criminal prosecution, the real reasons that led to it or the violations that the government might have committed in the course of the prosecution. Consequently, from this very limited information, the key challenge is how INTERPOL goes about detecting prosecutions that are politically motivated, lack due process, derive from private disputes, are based on invalid arrest warrants or otherwise defy the organization’s rules.
Non-democratic governments use INTERPOL’s lax requirements to trick the organization into believing that the prosecutions behind their requests for international police cooperation are lawful. They do so by charging their victims with ordinary law crimes rather than political, military, religious or racial crimes (for example, by charging a political opponent with fraud rather than insulting the head of the state) and making sure that the summary of the facts of the case in their requests for international police cooperation does not include anything that could raise suspicions about the real reasons for the prosecution. The requirement for a “reference to” a valid arrest warrant, which is all that INTERPOL’s rules require governments to supply, is not a strong safeguard. The legal validity will be assumed, absent a reason to query it, placing an onus on the good faith of governments. Even if the warrant is supplied, such a document adds little to the summary of facts provided by the government: it typically (with some exceptions) emerges from a cursory process in the absence of the defendant without her or him being represented. In the band of cases we are concerned with, in which courts further states’ persecutory interests, an arrest warrant will of course not tell the full story. As a result of these loopholes in INTERPOL’s rules, abusive Red Notices will often easily pass INTERPOL’s screening, placing an onus on the organization’s broader checks looking beyond formal requirements for other signs of persecutory intent. A potential safeguard that would allow INTERPOL to detect such unlawful prosecutions is additional detail in a notice request, such as the relationship of the complaining parties to one another, statement of proof of the elements of the alleged criminal act, disclosure of whether the subject of the notice is a member of an opposing political party or member of a recent outgoing administration, a disclosure of competing interests between the parties, and the like.
INTERPOL recognizes that the information that governments must produce in order for their Red Notices to be approved for publication is not sufficient to conduct a comprehensive analysis. INTERPOL admits that in order to ensure that a Red Notice is not of a politically, military, religious or racial character, the organization must examine each government request “on a case-by-case basis,” “separately, with due consideration for the specific context.” To conduct such an examination, INTERPOL’s Rules on the Processing of Data (RPD) require it to consider all relevant elements, including, among others, the nature of the offense, underlying facts, the general context of the case, status of the persons concerned, third parties’ positions regarding the case, such as advocacy organizations and governments, which might have already refused to extradite the individual in question (Article 34(3) of the RPD). INTERPOL has emphasized that such analysis requires “the examination and consideration of pertinent facts beyond those explicitly supplied in the request for police cooperation” (INTERPOL’s Repository of Practice on the Application of Articles 2 and 3 of INTERPOL’s Constitution at 17, § 56). In the following section we will review issues with INTERPOL’s application of these rules. As will be seen, there is currently a shortfall which leaves the onus on individuals to bring about a more comprehensive analysis by filing a complaint with CCF in respect of a Red Notice that has already been published.
In addition to Red Notices that are formally published by INTERPOL at a country’s request, there are also diffusions. Diffusions can be disseminated via INTERPOL for the same aim as Red Notices, that is, to detain for the purpose of extradition and criminal prosecution. However, unlike Red Notices, diffusions can be disseminated by governments without any prior screening by INTERPOL. The organization’s rules do not provide for any meaningful differences between Red Notices and diffusions that would force governments to resort to diffusions in exceptional cases only and thereby limit their number. In such a circumstance, why would a government that seeks to abuse INTERPOL risk having its Red Notice blocked before it is published (as unlikely as it is taking into consideration the ineffectiveness of the pre-publication screening) if it can create problems for the individual regardless of INTERPOL’s scrutiny by using a diffusion? It comes as no surprise, then, that the number of diffusions has been growing rapidly and may soon exceed the number of notices.
Although INTERPOL claims that it has launched pre-publication screening of wanted persons diffusions, it is important to take into consideration the semantics involved in this assurance. INTERPOL emphasises that it reviews all diffusions prior to recording them in its databases, that is, prior to them becoming visible (searchable) in INTERPOL’s files. It is important to note, however, that, unlike a Red Notice, a wanted persons diffusion is delivered via email to the National Central Bureaus (NCBs) that it is addressed to immediately after it is issued by the country-source of data and before INTERPOL decides whether it is compliant and whether it should be published in its databases. A potential safeguard against abusive diffusions is to require the same oversight and approval for diffusions, regardless of whether they are shared with all member countries or only a select member country.
INTERPOL’s rules require that it prevent all government abuse before it occurs. Yet INTERPOL is still far from complying with this requirement.
Not only do INTERPOL’s rules give the organization broad powers to block all abusive Red Notices, diffusions and other government requests before they enter the organization’s channels, the rules actually require INTERPOL to do so and give it broad discretion over mechanisms and tools to prevent government abuse before it occurs.
The INTERPOL Notices and Diffusions Task Force
In November 2017, during a meeting with representatives of the European Union, INTERPOL officials reportedly claimed that its Notices and Diffusions Task Force (NDTF), at the time a team of 30-40 staff, was reviewing up to 40,000 Red Notices recorded in the organization’s databases to determine if they were politically motivated. The meeting reportedly took place after Spanish authorities, acting on Turkey’s requests disseminated via INTERPOL, detained two European Union citizens.
It is unclear how, exactly, INTERPOL was planning on conducting such a massive review in an effective and objective manner. To thoroughly examine tens of thousands of government requests to ensure they were not politically motivated would be a colossal undertaking, even if INTERPOL’s staff and funding were significantly increased. As mentioned above, the NDTF would have to go far beyond what is already recorded in the organization’s databases, and it would need objective information about all of the circumstances of the case. However, because INTERPOL’s rules prohibit the organization from disclosing to individuals without the governments’ consent that they are on the international wanted list, in conducting such a review, INTERPOL would often have to look to a government alone for information about the criminal case and to whatever information the NDTF could find in the media and other open sources, if any. It is hard to imagine an oppressive regime using INTERPOL to persecute rather than prosecute being interested in an objective review of its conduct. On the contrary, such a government would be very selective in what it would produce in response to a request from INTERPOL. Add to that the fact that very few criminal prosecutions behind abusive Red Notices or diffusions receive any media coverage at all, even at the local level, and that there is virtually no publicly available information about the qualifications of the individuals comprising the NDTF, and it is hard not to question the effectiveness of its activities.
Indeed, NDTF’s practices are described obliquely on INTERPOL’s website, specifically on the webpage entitled Compliance and Review. First, the webpage refers to the NDTF’s assessment of Article 2 of the INTERPOL Constitution, without any detail as to what that assessment includes. This can be read together with the long-awaited publication in 2024 of the INTERPOL Repository of Practice mentioned above which was supposed to finally shed light on the organization’s application of Article 2 of its Constitution. That document contains a number of references to human rights standards, such as, for example, freedom of expression as applied to allegations involving speech. However, as we have pointed out above, persecutors are often not so obvious as to charge opponents with offences obviously implicating human rights norms. A key question is how INTERPOL addresses the thorny issue of compliance with the rule of law and fair trial standards in a prosecution, either to date or in terms of future treatment. The Repository of Practice added next to nothing on this issue. No one underestimates the difficulties of these assessments; yet one has the distinct impression that INTEROL evaded the issue in the Repository of Practice update. A potential solution to this situation is the addition of appropriate detail as to how the organization applies Article 2 to a given set of facts in the cases published in the Repository of Practice.
Secondly, the webpage refers to “technological tools” and “geopolitical information” as part of the analysis. This alludes to the use of public domain information about individual cases, the issue discussed above. It remains very unclear how INTERPOL goes about identifying relevant public domain information, what weight it gives to different materials and sources, to what extent its dialogue with NCBs is informed by what it finds or how it applies Article 2 in light of what it finds in the public domain. A potential safeguard against such vagueness is the additon of facts that clarify the nature of the relevant information without disclosing sensitive or identifying details, and this should not be too challenging to accomplish.
Thirdly, the webpage states that if doubt arises, the NDTF will undertake further steps which may include “seeking additional information from the requesting [NCB].” Job descriptions we have seen for roles within the NDTF refer to “engagement with member countries” as a major part of the work including “meetings with member countries.” It is not known how much of such dialogue there is, nor how INTERPOL approaches it. It appears likely that many requests, initially non-compliant, may be saved from rejection as a result of exchanges with the NDTF over lengthy periods; it is unclear how much of this ever becomes known to CCF (when it considers a complaint) or to individuals. A potential safeguard against the appearance that INTERPOL fails to identify and fully address deficient requests would be the disclosure of the exchanges in a response to a request for access or within the procedural posture section of the CCF decision.
No formal review of warnings of incoming abusive government requests. How governments-abusers use INTERPOL to keep their targets in suspense.
INTERPOL accepts requests from individuals to delete Red Notices, diffusions or other government requests already recorded in its databases (complaints) as well as requests to prevent such requests from entering the organization’s channels if it receives them in the future (preemptive requests). However, only the former is subject to a formal review. CCF has repeatedly ruled that its powers are limited to government requests already recorded in INTERPOL’s databases. If an individual warns CCF of an abusive government request that might arrive in the future, CCF does not render a decision on such a warning, but instead informs the INTERPOL General Secretariat that it has received a pre-emptive request and passes the information to the INTERPOL General Secretariat so that it can take it into account if a request is received. The General Secretariat, however, might not inform the individual whether it would block such a government request if it is received. INTERPOL’s approach to such warnings thereby allows governments to keep their targets in suspense for a very long time. A government may open a criminal case based on a trumped-up charge but decide not to resort to INTERPOL for some time to avoid losing before CCF. There have also been instances in which governments withdrew already published Red Notices or diffusions after CCF received complaints from individuals but before it was able to render a decision. In this regard, CCF again justifies its lack of further action by its lack of power to consider data that has not been recorded or is no longer recorded in INTERPOL’s databases. Likewise, the General Secretariat might not inform the individual whether it would block the same or another request from the same government if it receives one in the future. It is difficult to imagine a more excruciating process for individuals whose rights are supposed to be protected from government misconduct by such a system. For instance, according to a 2018 written submission by William Browder to the UK Parliament, Russia has made eight attempts to use INTERPOL's Red Notice system against him. A potential safeguard against abusive member countries’ manipulation of INTERPOL’s tools would be for the organization to inform the applicant as to the history of the data in their names and provide at least a general guideline regarding how future applications by that government might be treated, or at the bare minimum, an assurance that the applicant will be notified in the event of a future request and provided an opportunity to be heard on that request before it is accepted or rejected.
How those already declared victims of INTERPOL abuse end up in its databases again
In its activity report for 2017, CCF writes that it “dealt with cases where [governments] have sent a diffusion to INTERPOL members to request the arrest of an individual, whereas a request for a Red Notice has previously been refused.” According to the same report, CCF also had to deal with cases “which highlighted the use of the [INTERPOL Stolen and Lost Travel Documents] database where a diffusion or a notice to arrest a person was considered not to comply with INTERPOL’s rules.” That is, some governments, whose Red Notices INTERPOL had rejected due to their non-compliance with its rules, were able to put the same individuals back on the INTERPOL wanted list by disseminating diffusions. If diffusions were deleted as non-compliant, they utilized the INTERPOL Stolen and Lost Travel Documents database to target the same individuals.[1] This means that INTERPOL did not, at least in 2017, possess a comprehensive mechanism for the enforcement of its own decisions that would preclude governments from repeatedly abusing the organization’s channels. Such a mechanism, it seems, would require nothing more than a computer code to check incoming government requests against the list of individuals whose data INTERPOL has already deleted as non-compliant. To this day, it is unclear whether INTERPOL has fixed this loophole or not.
The redress mechanism intended to protect victims of INTERPOL abuse lacks due process: no right to a hearing, examine evidence or appeal
The INTERPOL reforms of 2016 addressed some issues with INTERPOL’s redress mechanism for individuals challenging government use of its channels. Prior to the reforms, CCF’s decisions were simply non-binding recommendations. They are now mandatory. Prior to the reforms, CCF was under no obligation to provide any reasoning for its decisions, and individuals usually received a short letter informing them that their complaints were approved or denied without further explanation. The reforms changed that. CCF’s decisions now include a structured and reasoned decision, albeit there are reservations about quality. Also, prior to the reforms, CCF was operating without deadlines, sometimes leaving individuals to wait for years for a decision. The reforms also set out a power to issue provisional measures – although this is now being rowed back. Another change brought by the reforms is that CCF is now staffed with more lawyers qualified in various key areas.
Despite the reforms, significant problems remain. To this day, individuals who challenge a government’s use of INTERPOL’s channels do not have the right to a hearing, to examine evidence that governments produce against them, or to appeal CCF’s decisions, the rights without which it is impossible to imagine any modern democratic system. The lack of individual right of access to information recorded in INTERPOL’s databases and to information that governments produce during CCF’s consideration of individual complaints is particularly alarming because it infringes on one of the fundamental due process principles, the equality of arms. It is often impossible to prepare a comprehensive argument against an abusive Red Notice or other government request disseminated via INTERPOL’s channels without possessing all information recorded in the organization’s databases. At the same time, governments often make extensive arguments to CCF, which are never seen by applicants until a summary of them appears in CCF’s decisions.
Additionally, CCF has been understaffed despite the constantly growing number of complaints and other requests from individuals, which has resulted in significant delays on its part and an inability to meet the deadlines set out in its Statute. Despite all these problems with the INTERPOL redress mechanism, recently, the INTERPOL General Assembly adopted amendments to CCF’s Statute which stand to adversely impact on significant aspects of CCF’s powers, in particular by delaying its involvement and limiting its powers to issue provisional measures.[2]
Unwillingness to publicly recognize countries-abusers
Widespread INTERPOL abuse has been going on for years, yet there has not been an official public report naming countries-abusers and the extent of their misconduct. No one has more information on this than INTERPOL itself. Although CCF is empowered to publish this information, including the number of complaints it has approved against each member country, as well as the nature of its violations, CCF chooses not to exercise this power. The obvious safeguard to address the ongoing problem of abusive INTERPOL member countries is to identify them, specify the sanctions imposed against them, impose a period of observations, and recognize any progress that the countries makes over time. This public highlighting of bad acts as well as improvements is aligned with the approach of multiple other international oversight endeavors, and indeed, is more likely to lead to improved behavior than does maintaining a shroud of secrecy over the bad actors. In the meantime, unfortunately, not only does INTERPOL refuse to publicly name the countries that abuse its resources to persecute political opponents and other victims of corrupt prosecutions, but it is reportedly imposing no sanctions at all on some of the worst abusers or lifting those imposed without any sign of the perpetrators halting their unlawful practices.[3]
[1] The Arrested Lawyers Initiative, Crackdown on Lawyers in Turkey and Misuse of INTERPOL’s Mechanisms (Oct. 1, 2025), https://arrestedlawyers.org/2025/12/01/tali-submission-to-the-unsrijl.
[2] Lawyers Against Transnational Repression, Lawyers Against Transnational Repression Responds to the Call for Contributions of the Committee on the Processing of Data (CPD) Concerning Draft Amendments to Articles 28, 33, 37 and 40 of the Statute of the Commission for the Control of INTERPOL’s Files (Apr. 6, 2025), https://www.latrint.org/our-work/lawyers-against-transnational-repression-responds-to-the-call-for-contributions-of-the-committee-on-the-processing-of-data-cpd-concerning-draft-amendments-to-articles-28-33-37-and-40-of-the-statute-of-the-commission-for-the-control-of-interpols-files; Lawyers Against Transnational Repression, Lawyers Against Transnational Repression and the European Criminal Bar Association Respond to the Call for Contributions of the Committee on the Processing of Data (CPD) Concerning Draft Amendments to Articles 8, 9, 15(3) and 22 of the Statute of the Commission for the Control of INTERPOL’s Files (Oct. 19, 2025), https://www.latrint.org/our-work/lawyers-against-transnational-repression-and-the-european-criminal-bar-association-respond-to-the-call-for-contributions-concerning-draft-amendments-to-articles-8-9-15-3-and-22-of-the-statute-of-the-commission-for-the-control-of-interpols-files.
[3] Cate Brown, Max Hudson, Julia Luft, Russia Using INTERPOL’s Wanted List to Target Critics Abroad, Leak Reveals, BBC (Jan. 26, 2026), https://www.bbc.com/news/articles/c20gg729y1yo; Mathieu Martinière, Robert Schmidt, Rémi Labed, Revelations on the Misuse of INTERPOL by the World’s Most Repressive Regimes, Disclose (Jan. 26, 2026), https://disclose.ngo/en/article/revelations-on-the-misuse-of-interpol-by-the-worlds-most-repressive-regimes; Mathieu Martinière, Robert Schmidt, INTERPOL: Turkish Journalists and Political Activists Flagged as “Terrorists” by the Organization, Disclose (Jan. 28, 2026), https://disclose.ngo/en/article/interpol-turkish-journalists-and-political-activists-flagged-as-terrorists-by-the-organisation.
