Interpol Red Notices and Diffusions: Powerful - And Dangerous - Tools of Global Law Enforcement
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where in a member country. While Red Notices and
Interpol Red Notices and Diffusions can serve a legitimate law enforcement pur-
pose, they are susceptible to abuse by regimes that use
Diffusions: Powerful — them to oppress political dissenters, as well as by countries
that treat civil disputes as criminal matters.
And Dangerous — Tools of This article sets out the basic principles of Interpol
Red Notices and Diffusions, and addresses the practical
questions of how to ascertain whether a client is the sub-
Global Law Enforcement ject of a Red Notice or Diffusion, and, if so, how to request
its cancellation.
I. Interpol
a. Interpol Generally
With 190 member nations, Interpol is the largest
client, who has been under investigation in a for- international law enforcement agency in the world.1 Its
A eign country, asks counsel if it is safe to travel inter-
nationally, or if there is a risk of arrest and deten-
tion even in countries that are not involved in the matter
stated mission is “[p]reventing and fighting crime through
enhanced cooperation on police matters.”2 It does not
employ its own police force.3 Interpol assists national law
under investigation. That question implicates a powerful enforcement agencies in combating transnational crime
tool of global law enforcement known as a “Red Notice,” and terrorism by providing “targeted training, expert
and an even more powerful tool called a “Diffusion.” investigative support, relevant data and secure communi-
These devices are issued and circulated by and through cations channels.”4 These tools help local police under-
Interpol, the International Criminal Police Organization. stand international trends in criminal activity, and con-
A Red Notice, issued by Interpol at the request of a mem- duct multinational investigations and operations.5
ber country, seeks the arrest of an individual in any of
Interpol’s 190 member countries. A Diffusion is a unilat- b. Interpol’s Constitution
eral notice from an Interpol member country, often Interpol’s Constitution sets out Interpol’s objectives
requesting the arrest of an individual. It is disseminated and general structure.6 Articles 2 and 3 are key provisions.
through Interpol, but lacks the screening that Interpol’s Article 2 states that Interpol aims “[t]o ensure and promote
rules require before a Red Notice is issued. Most common- the widest possible mutual assistance between all criminal
ly, Red Notices and Diffusions are enforced at points of police authorities within the limits of the laws existing in
entry, although in principle they may be enforced any- the different countries and in the spirit of the Universal
B Y J A C Q U E S S E M M E L M A N A N D E M I LY S P E N C E R M U N S O N
28 W W W. N A C D L . O R G THE CHAMPION
Declaration of Human Rights[.]”7 Article advising Interpol on projects that involve color-coded based on their purpose.33
3 sets forth Interpol’s principle of neutral- the processing of personal information; Some notices serve a purely information-
ity, stating that “[i]t is strictly forbidden and (3) handling requests for access to al function, such as Orange Notices,
for the Organization to undertake any Interpol’s files.22 Red Notices and which “warn of an event, a person, an
intervention or activities of a political, Diffusions fall within the CCF’s purview, object or a process representing a serious
military, religious or racial character.”8 as they involve the collection and use of and imminent threat to public safety.”34
personal information.23 Green Notices “provide warnings and
c. Structure of Interpol Interpol is not subject to national intelligence about persons who have
Interpol’s supreme governing body legislation aimed at protecting personal committed criminal offences and are like-
is the General Assembly, comprised of privacy, and is generally immune from ly to repeat these crimes in other coun-
delegates appointed by each member suit in national courts (including those of tries.”35 Purple Notices provide (and also
nation.9 The General Assembly meets the United States).24 Instead, Interpol has seek) information regarding “modi
annually to make decisions relating to a set of rules designed to protect individ- operandi, objects, devices and conceal-
policy, resources, finances, working ual rights, and the CCF oversees adher- ment methods used by criminals.”36
methods and programs.10 Interpol’s ence to those rules.25 Yellow Notices “help locate missing per-
Executive Committee oversees the imple- NCBs are responsible for ensuring sons or … identify persons who are
mentation of decisions made by the that any information they provide to unable to identify themselves.”37
General Assembly.11 The Executive Interpol’s databases is accurate, relevant The remaining varieties of notices
Committee is composed of the President, and up to date, and that its processing request information or action from the
INTERPOL RED NOTICES AND DIFFUSIONS
three Vice Presidents and nine Delegates, conforms with the Organization’s network of police forces connected by
each from a different member country.12 Constitution, the NCBs’ respective Interpol.38 Blue Notices are issued to “col-
The day-to-day operations of Interpol national laws, and international treaties.26 lect additional information about a per-
are carried out by the General Additionally, the General Secretariat son’s identity, location or activities in
Secretariat, which is headquartered in oversees the NCBs to confirm compliance relation to a crime,” while Black Notices
Lyon, France, and which operates 24 with Interpol’s rules and Constitution.27 request “information on unidentified
hours a day, 365 days a year.13 The The CCF serves as an additional level of bodies.”39 Red Notices “seek the location
Secretariat also has seven regional offices, compliance oversight, monitoring the and arrest of wanted persons with a view
and maintains liaison offices at the General Secretariat’s actions and han- to extradition or similar lawful action.”40
United Nations in New York and the dling requests from individuals who seek Yellow, Green, Blue and Red Notices
European Union in Brussels.14 Former access to the information in Interpol’s are submitted through Interpol’s I-Link
U.S. Treasury Department official databases or who challenge the use or system, a data exchange platform that
Ronald K. Noble, the current Secretary accuracy of that information.28 enables NCBs to record and access police
General, is charged with running the information contained in I-24/7,
General Secretariat.15 f. Collection and Use of Interpol’s secure global police network.41
Personal Information
d. National Central Bureaus Interpol has two sets of rules with b. Red Notices and
Each member nation of Interpol respect to obtaining and using personal Diffusions Generally
maintains a National Central Bureau information. The goal of the Rules on the Sometimes characterized as an inter-
(NCB) that acts as a liaison between the Processing of Data (RPD) is to “exchange national “wanted poster,”42 a Red Notice is
nation’s law enforcement agencies and a maximum of information of interest for a demand by the requesting NCB on all
Interpol.16 NCBs are the “lifeblood” of the purposes of international police coop- Interpol members to arrest a person
Interpol, contributing to its criminal eration,” while maintaining “due obser- wanted for prosecution or to serve a pre-
databases, and cooperating in cross-bor- vance of the Organization’s political neu- viously imposed sentence.43 A database
der investigations and operations.17 The trality, independence and mandate, and of called Travel Documents Associated With
NCB for the United States is “INTERPOL th[e] [members’] respective national leg- Notices (TDAWN) allows agents at bor-
Washington,” a joint venture of the islations and international conventions.”29 der points to check passport data against
Department of Justice and the The Rules on the Control of Information Interpol Notices.44 If a subject of a Red
Department of Homeland Security.18 Any and Access to Interpol’s Files (RCI) estab- Notice is located, the country in which
U.S law enforcement agency, from the lish the authority of the CCF, and allow the subject has been located shall imme-
Federal Bureau of Investigation to a local individuals access to personal data con- diately notify the requesting NCB and the
police department, seeking to interact tained in Interpol’s databases.30 General Secretariat, “subject to limita-
with Interpol must do so through tions deriving from national law and
INTERPOL Washington.19 II. Red Notices and applicable international treaties,” and
shall “take all other measures permitted
e. The Commission for the Diffusions under national law and applicable inter-
Control of Interpol’s Files a. Notices Generally national treaties, such as provisionally
The Commission for the Control of As an international police organiza- arresting the wanted person or monitor-
Interpol’s Files (CCF) is an independent tion with a declared vision of “connecting ing or restricting his/her movement.”45
monitoring body within Interpol that police for a safer world,” Interpol’s pri- Due to Fourth Amendment con-
oversees Interpol’s activities.20 The CCF is mary role is informational.31 Interpol straints, the United States will not arrest
composed of five members, each serving Notices facilitate information-sharing someone solely on the basis of a Red
a three-year term.21 The CCF’s primary and cooperation among police forces of Notice or Diffusion,46 although various
functions are (1) monitoring compliance member nations.32 Notices are issued by other countries will do so.47 Assuming the
with Interpol’s rules governing the collec- Interpol’s General Secretariat at the requesting country is not hostile to the
tion and use of personal information; (2) request of a member nation, and are United States, U.S. agents would notify it
W W W. N A C D L . O R G M AY 2 0 1 4 29
if a subject of a Red Notice was detected In addition, to support the charged with ensuring that Diffusions
entering this country.48 This would allow issuance of a Red Notice, a charge must comply with Interpol’s rules and
the requesting country to seek provision- meet a penalty threshold.63 For a Red Constitution.71 Requests for issuance of
al arrest with a view to extradition, in Notice that seeks a subject for prosecu- Red Notices that are awaiting approval
accordance with U.S. law.49 tion, the charged conduct must be by the General Secretariat are subject in
Red Notices may be “public” or “pri- punishable by “a maximum depriva- principle to its oversight, but that over-
vate.” Public Red Notices are published on tion of liberty of at least two years or a sight is severely limited by the opera-
Interpol’s website. These notices are more serious penalty.”64 Where the Red tion of I-Link. Because NCBs submit
accessible to the public under the Notice is for a subject being sought to Diffusions and requests for Red Notices
“Wanted Persons” link on the Interpol serve an imposed sentence, that sen- directly through I-Link, they are
homepage.50 Private Red Notices are tence must be “at least six months of “recorded instantly into the
notices that either have not yet been imprisonment” with “at least six Organization’s central database and
approved by the General Secretariat, or months of the sentence remaining to immediately accessible to police around
that the requesting nation has asked not be served.”65 the world,”72 without authorization or
be made public on the Interpol website.51 The General Secretariat has the review by the General Secretariat.
They are circulated among the police authority to issue a Red Notice in the
forces of member nations via I-Link.52 absence of these requirements, but only c. Ascertaining Whether a
Diffusions are a less formal alert if, “following consultation with the Client is the Subject of a
mechanism than Red Notices, but can requesting National Central Bureau or Red Notice or Diffusion
INTERPOL RED NOTICES AND DIFFUSIONS
serve a similar function: they can “request international entity, it considers that
the arrest or location of an individual or publication of the requested red notice i. Public Red Notices
additional information in relation to a would be of particular importance to Because public Red Notices are pub-
police investigation.”53 Diffusions are pub- international police cooperation.”66 lished on Interpol’s website, they are easi-
lished on I-Link by the issuing NCB with- A request for issuance of a Red ly accessible.73 If an individual is subject to
out any review by the General Secretariat.54 Notice must contain “sufficient identi- a public Red Notice, there will be an entry
Thus, the only entity certifying the accura- fiers” of the subject, which requires at on the “Wanted Persons” list in the indi-
cy of a Diffusion, and its compliance with least one of the following: (1) a photo- vidual’s name that includes basic personal
Interpol’s Constitution and rules, is the graph and certain additional data (e.g., information and a photograph.74
issuing NCB.55 Notices (including Red alias, parent names, further physical
Notices) must be disseminated to the description, DNA profile, or finger- ii. Private Red Notices
entire Interpol network,56 while Diffusions prints); or (2) family name, given name, And Diffusions
can be selectively distributed to specific gender, and date of birth (at least year of Determining whether an individ-
NCBs.57 Otherwise, Diffusions are treated birth), as well as a physical description, ual is the subject of a private Red Notice
like Notices — they are included in various DNA profile, fingerprints, or data con- or a Diffusion is not as simple. In cer-
databases accessible by local police and tained in identity documents.67 Further, tain circumstances, a cooperative NCB
border patrol agencies.58 In 2012, Interpol a Red Notice may only be issued if the might be willing to check I-Link on the
issued 8,136 Red Notices and disseminated requesting nation has furnished suffi- individual’s behalf. This might be feasi-
20,130 Diffusions.59 cient factual and legal information per- ble, for example, if the individual has
taining to the charges, namely: (1) a been granted asylum somewhere, in
i. Requirements for summary of the facts of the case, includ- which case that country’s NCB might
Issuance of a Red Notice ing the time and location of the alleged be willing to assist.75 In addition, the
The General Secretariat is responsi- criminal activity; (2) the criminal domestic law of certain countries might
ble for “checking the compliance of all charges; (3) the laws covering the provide a mechanism for seeking such
notice requests” and “ensuring that pub- offense, including, where possible, the information. INTERPOL Washington
lished notices continue to comply with wording of the relevant provision; (4) has a procedure for submitting requests
the conditions for their publication and the maximum penalty, or (in the case of for records under the Freedom of
are regularly assessed by the National a conviction) the sentence imposed and Information Act.76 These requests, how-
Central Bureau or international entity the portion of the sentence remaining to ever, only extend to INTERPOL
that requested their publication.”60 For be served; and (5) reference to a valid Washington’s records, not to records
issuance of a Red Notice, the offense arrest warrant or a judicial decision hav- maintained by Interpol.77
charged must be a “serious ordinary-law ing the same effect, and where possible, a In unusual cases, the lawyer might
crime,” and cannot raise “controversial copy of the warrant or decision.68 ask the potential requesting NCB direct-
issues relating to behavioural or cultural The General Secretariat must “con- ly. Of course, if the client is not already
norms,” or “relat[e] to family/private duct a legal review of all red notices the subject of a Red Notice or Diffusion,
matters.”61 These phrases are not defined prior to their publication to ensure com- such an inquiry might trigger an investi-
in Interpol’s rules. Offenses “originating pliance with INTERPOL’s Constitution gation of the client, so this approach
from a violation of laws or regulations of and Rules.”69 In addition, a Red Notice requires extreme caution.
an administrative nature or deriving that no longer meets the required stan- Ordinarily, the best option is to
from private disputes” are similarly inad- dards of publication must be canceled by submit a request to the CCF for access
equate to support issuance of a Red the General Secretariat.70 to the information contained in
Notice “unless the criminal activity is Interpol’s files.78 If counsel already has
aimed at facilitating a serious crime or is ii. The RPD’s Limited reason to believe there is an outstand-
suspected of being connected to organ- Application to Diffusions ing Red Notice or Diffusion, he or she
ized crime.”62 Again, these phrases are not And Red Notice Requests can skip the informational step and
defined in the rules. The General Secretariat is not request its cancellation.79
30 W W W. N A C D L . O R G THE CHAMPION
d. Ascertaining Whether a
Red Notice or Diffusion
Is in Effect, and Seeking
Its Cancellation Checklist for Challenging an
i. Submitting a CCF Request
Article 9 of the RCI provides that
Interpol Red Notice or Diffusion
v
“[a]ny person who so wishes may, freely
and free of charge, exercise the right of Ascertain Whether the Client Is the Subject of a Red Notice or Diffusion
access to personal information concern-
ing him which has been recorded in • Check the “Wanted Persons” list on Interpol’s
Interpol’s files.”80 This seemingly broad website for a public Red Notice.
“right of access” is actually quite limited.81 • If not listed, request assistance from a
Member countries “remain the owners of cooperative NCB (if there is one).
information they communicate to • If necessary, submit a request to the CCF for access to
INTERPOL and must give permission for information contained in Interpol’s files (see below).
its disclosure to requesting parties.”82
Thus, a subject of a Red Notice or • In unusual circumstances, ask the NCB suspected to
Diffusion has the right to be informed of have requested a Red Notice or issued a Diffusion
INTERPOL RED NOTICES AND DIFFUSIONS
to confirm that it has done so.
v
that fact upon request unless the relevant
NCB refuses to allow Interpol to provide Submit a CCF Request
the disclosure.83
The Operating Rules of the • Decide whether to ask the CCF to maintain complete
Commission for the Control of confidentiality with respect to the request.
Interpol’s Files (the Operating Rules) set • Complete the form “Request for Access to Interpol’s
forth the procedures the CCF follows in Databases” available on the Interpol website.
reviewing an individual request for
access.84 Individuals can request access to • Provide the following documentation:
information about themselves in — an original letter, in one of Interpol’s four working
Interpol’s databases by submitting a languages, signed by the subject of the requested
one-page form and supporting docu- information;
mentation to the CCF.85 This includes — a copy of an identity document for the subject; and
ascertaining whether a Red Notice has
been requested or issued, or a Diffusion — if submitted by a representative of the subject, an
disseminated.86 Applicants may also ask original power of attorney.
to modify or delete information in the • For requests that challenge information in Interpol’s files, provide:
files.87 Requests seeking cancellation of a — detailed reasons for the request; and
Notice or Diffusion, also called “chal-
lenges,” are made using the same form as — supporting documentation.
a request for access.88 • For requests concerning a minor, also provide:
The CCF reviews each submission to — a copy of an identity document for the adult
determine, in the first instance, if the submitting the request; and
request is “admissible.”89 A request is
admissible if it (1) includes an original, — documents establishing the relationship between the
signed letter explaining the purpose of adult submitting the request and the minor.
the request; (2) is written in one of the • If confirmation of receipt is not received within one month,
organization’s four official languages contact the CCF to ensure the submission arrived.
v
(English, French, Spanish, or Arabic); (3)
comes from the person it concerns, or Seek Cancellation If Notice Was Requested in Error
from that person’s duly authorized repre- or Is No Longer Applicable
sentative or legal representative; and (4) is • Ask the issuing NCB to seek cancellation.
accompanied by a copy of an identity
document for the person who is the sub- • If the issuing NCB refuses to seek cancellation, submit
ject of the request.90 If the request comes a request for cancellation to the CCF.
from a duly authorized representative of • If possible, ask a supportive NCB to report the
the subject, it must be accompanied by an matter to the General Secretariat.
v
original power of attorney authorizing
access to the information recorded in If a Client’s Request Is Denied by the CCF, Request
Interpol’s files.91 If the request is submit- Re-Examination If Grounds Exist
ted by a legal representative, it must • The request for re-examination must be based on a
include a statement to that effect.92 newly discovered fact that probably would have led to
If the CCF determines the request a different conclusion.
is inadmissible, it must inform the
applicant and provide the reasons for
its decision.93
W W W. N A C D L . O R G M AY 2 0 1 4 31
If the request is admissible, the CCF matters,”98 or that are based on offenses would probably have led to a different
will perform a “detailed assessment” of “originating from a violation of laws or conclusion if that fact had been known
the request.94 The CCF will evaluate com- regulations of an administrative nature or at the time the request was processed,”
pliance with Interpol’s Constitution and deriving from private disputes.”99 the party can apply for re-
rules, which mandate, inter alia, respect Confidentiality can be an important examination.109
for “the basic rights of individuals in con- strategic consideration. Interpol repre- Once the CCF has concluded its
formity with … the Universal sents that requests by individuals are not assessment, it issues its recommendation
Declaration of Human Rights,”95 avoid- recorded in its databases, and are not to the General Secretariat.110 The General
ance of “any intervention … of a political, accessible by NCBs.100 While performing Secretariat is not bound by that recom-
military, religious or racial character,”96 the assessment, however, the CCF can mendation, but will typically follow it.111
and compliance with international con- solicit additional information from the In the event of a disagreement between
ventions and domestic law.97 If the request requesting person and from the relevant the General Secretariat and the CCF, the
involves a Red Notice, the CCF will also NCB.101 Interpol assures that the NCB CCF may bring the dispute before the
assess compliance with Article 83 of the will not be contacted if the applicant Executive Committee of Interpol.112
RPD, which prohibits the issuance of Red explicitly requests complete confiden- This, however, is highly unusual.113
Notices that raise “controversial issues tiality.102 Likewise, if the CCF is “bound
relating to behavioural or cultural to communicate certain items of infor- 1. Required Forms and Documents.
norms,” that “relat[e] to family/private mation to the INTERPOL General The CCF provides a one-page form on
Secretariat or to the entities concerned, its website for requesting access to and
INTERPOL RED NOTICES AND DIFFUSIONS
in order to be able to process the deletion of information contained in
AFFILIATE NEWS request” it will do so unless explicitly Interpol’s files.114 The form is also used
Continued from page 13 forbidden from such communication by for requesting cancellation of a Red
the applicant in his or her request.103 Not Notice or Diffusion.115 In addition to
the bloodstream must be restricted to surprisingly, such a prohibition “may be basic information about the applicant,
psychoactive metabolites in order to detrimental to the requesting party, as it the form requires the applicant to set
avoid absurd results. And in a fourth restricts the CCF’s ability to successfully forth the reasons for the request, and to
case, State v. Whitman, the court process the request.”104 provide supporting documents.116
appointed AACJ as amicus curiae to In some instances, it will not be a
argue the case for the defense bar. For secret that a client has been targeted by a 2. Basis for Relief. A request for
more information, contact AACJ’s particular member nation. In such cases, cancellation of a Red Notice or
Executive Director Max Bessler at the fact of the application will probably Diffusion may be based on Interpol’s
480-812-1700 or email not need to be kept confidential, but Constitution and/or the RPD.117
defense@aacj.org. some of the information the client sup- Constitutional arguments can include a
plies the CCF might not be known to the violation of Article 2, which identifies
MACDL Creates member nation, and should be kept con- Interpol’s goal of promoting police
Advocacy Network fidential. Interpol states that, if so cooperation consistent with the spirit of
The Massachusetts Association of requested, the CCF “never shares per- the Universal Declaration of Human
Criminal Defense Lawyers (MACDL) sonal or confidential information with Rights (the Declaration), or of Article 3,
has created a statewide Witness NCBs that is not already known by the which prohibits Interpol’s involvement
Advocacy and Representation NCBs, such as elements of identification in matters of a political, military, reli-
Network (WARN) designed to pro- or location of the subject.”105 gious, or racial nature.118
vide pro bono legal representation for In other cases, the client might not When an individual claims the
individuals who are contacted by law be sure if he or she is a target, and would information contained in Interpol’s files,
enforcement agents for questioning want full confidentiality (including as to or a Red Notice issued on the basis of
or interrogation. This network, the the fact of the application) to avoid trig- that information, violates Article 3, the
first of its kind in the United States, gering interest where none may exist. In CCF applies the “predominance test” to
will make prompt referral of cases to such a case, the need for complete confi- assess the claim.119 Under this test, the
volunteer local attorneys — an dentiality might outweigh the risk that CCF evaluates the ordinary criminal law
important and crucial step to closing the CCF will be unable to process the aspects of the case and the Article 3
the gap in the provision of legal rep- request. Each case requires its own eval- aspects, determining which predomi-
resentation in the criminal justice uation. nates.120 The CCF will recommend can-
system. It will address the inherent The rules do not specify the burden cellation of a Red Notice, or deletion of
inequity of the current system where- of proof the applicant is required to information in Interpol’s files, where the
in only individuals with adequate meet in order to have information mod- Article 3 aspects of the case predomi-
means are able to protect their rights ified or deleted, or to have a Red Notice nate.121 In an Article 3 assessment, all rel-
when confronted by law enforcement or Diffusion canceled. The CCF does not evant information is examined, includ-
agents. WARN has been in operation publish the standards it applies and does ing the following nonexclusive factors:
for less than a month and has already not promulgate its decisions or the rea- (1) the nature of the offense, specifically
assigned counsel to two witnesses. soning in individual cases.106 If the the charges and relevant facts; (2) the
For more information, contact request is rejected in whole or in part, status of the individual concerned; (3)
MACDL’s President Elizabeth A. Lunt however, the CCF must explain its rea- the identity of the source of the informa-
lunt@zalkindlaw.com. n
at 617-742-6020 or email sons to the requesting party.107 tion; (4) the position taken by a member
There is no right of appeal from a nation or authorized international enti-
CCF decision,108 but if the requesting ties apart from the source of the infor-
party has “discover[ed] … a fact which mation; (5) the obligations under inter-
32 W W W. N A C D L . O R G THE CHAMPION
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national law; (6) the implications on protect the customs and beliefs of native subjected to torture or inhuman treat-
Interpol’s neutrality; and (7) the general West Papuans legally and peacefully.128 ment, Wenda argued that the Red Notice
context of the case.122 In 2002, Wenda was arrested by was inconsistent with the “spirit” of the
The General Secretariat maintains a Indonesian authorities and, after being Declaration and thus violated Article 2
repository of practice on the application detained for over two months, was of Interpol’s Constitution.140
of Article 3 that is available to NCBs.123 A charged with inciting an attack on a
cooperative NCB might be willing to police station which resulted in multi- 3b. Violation of Article 3 —
provide access to the repository, which ple deaths.129 Wenda denies culpability, Prohibition on Interventions of a
could be a useful source of information. and says he was detained, tortured, Political, Military, Religious or Racial
Arguments under the RPD will usu- and solicited for bribes by the Character. Wenda also invoked Article 3
ally be based on one or more of Articles Indonesian judge and prosecutor of Interpol’s Constitution, which pro-
5(3), 11, 12, 76 and 83. Article 5(3) pro- before escaping and fleeing to the hibits Interpol from engaging in activi-
vides that information collected by United Kingdom.130 The U.K. granted ties “of a political, military, religious or
Interpol should be processed with “due Wenda political asylum.131 racial character.”141 Wenda argued that
observance” of Interpol’s political neu- In the U.K., Wenda created the Free the charges against him were politically
trality and relevant national laws and West Papua campaign, a nonviolent motivated, citing the abuse he suffered
international conventions. Article 11 international movement promoting the during his pretrial detention; the fact
requires Interpol to use data “with due independence of West Papua.132 His that he was not indicted until two
regard for the law applicable to” the activism required significant interna- months into his detention; the absence
INTERPOL RED NOTICES AND DIFFUSIONS
requesting NCB, and to “respect the tional travel, which became nearly of key witnesses at trial and the admis-
basic rights” of the subject of the Red impossible when Wenda learned that, at sion by the court of written statements
Notice or Diffusion, in accordance with Indonesia’s request, Interpol had issued without an opportunity for cross-exam-
Article 2 of Interpol’s Constitution and a Red Notice for him in 2011.133 On April ination; and the solicitation to bribe the
the Declaration. Article 12 provides that 24, 2012, Fair Trials International filed judge and prosecutor.142 Wenda noted
data processed by Interpol must be an application on Wenda’s behalf with that the U.K. would have denied his
“accurate, relevant, not excessive in rela- the CCF, seeking to cancel the Red request for asylum had there been suffi-
tion to their purpose and up to date[.]” Notice.134 In August 2012, Interpol can- cient evidence he was guilty of the
Article 76 states that Interpol is not celled the Red Notice.135 Wenda’s applica- crimes charged.143
required to issue a Notice if doing so tion, discussed below, was premised Wenda also argued that the real
“could prejudice the Organization’s largely on violations of Articles 2 and 3 objective of the Red Notice was to
image or interests.” of Interpol’s Constitution. impair his ability to travel, and thereby
Article 83 imposes specific require- eliminate his ability to engage in politi-
ments for issuance of a Red Notice, 3a. Violation of Article 2 — cal activism outside the U.K., and that
including minimum penalty thresholds Infringement of The Declaration. this was a politically motivated abuse of
for the underlying offense, the provision Wenda invoked Article 2 of Interpol’s Interpol’s notice system.144
of personal information sufficient for Constitution, which provides that
law enforcement to identify the subject, Interpol aims to “ensure and promote 3c. Compliance With Obligations
and restrictions on the use of Red the widest possible mutual assistance of Domestic And International Law.
Notices in conjunction with private dis- between all criminal police authorities Although the RPD was not yet in effect
putes, family matters, administrative within the limits of the laws existing in at the time of Wenda’s application,
offenses, and violations of cultural or the different countries and in the spirit Wenda made an argument that could
behavioral norms. This Article is fre- of the Universal Declaration of Human now be made under Article 5(3), which
quently ignored, as Red Notices have Rights.”136 Wenda argued that the Red requires that member nations process
been issued in connection with mort- Notice violated Articles 12 and 19 of the information in Interpol’s databases
gage loan defaults and other commercial Declaration by causing an “arbitrary “with due observance of … their
disputes.124 Any such abuses should be interference with [his] privacy, family, respective national legislations and
contested vigorously before the CCF. home … [and] correspondence”; by international conventions to which
3. Benny Wenda’s Successful “attack[ing] … his honour and reputa- they are parties.”145 Wenda argued that
Application for Cancellation of a Red tion”; and by violating his “right to free- his trial failed to comply with interna-
Notice. Although Interpol’s website dom of opinion and expression.”137 tional conventions to which Indonesia
does not provide sample applications, Wenda also argued that the Red was a party.146
Fair Trials International, a not-for- Notice violated Article 5 of the Wenda’s application was granted,
profit legal organization in the United Declaration by exposing him to the risk but the CCF did not reveal which of his
Kingdom, has submitted a number of of future “torture or … cruel, inhuman arguments it considered most effective.
CCF requests and has made two of or degrading treatment or punishment” Nevertheless, the Wenda application
those requests available on its website.125 in Indonesia.138 Wenda’s application provides a useful example of a successful
One of these applications, that of detailed the ill-treatment he suffered challenge to a Red Notice.
Benny Wenda, resulted in the while detained in Indonesia, and cited
cancellation of a Red Notice.126 reports from Human Rights Watch, 3d. Prejudice to Interpol’s Image
Wenda is an activist from West Amnesty International and the United and Interests. Interpol has been criti-
Papua, an area of New Guinea that is Nations, which documented the contin- cized for its willingness to assist nations
considered part of Indonesia.127 Wenda uing abuse against West Papuan that have questionable human rights
served as Secretary-General for the tribal activists.139 Because the Red Notice records or a history of abusing the Red
assembly representing the West Papuan would assist in returning him to a nation Notice system.147 In a suitable case,
people, an organization that seeks to where there was a real risk he would be Article 76 of the RPD enables counsel to
34 W W W. N A C D L . O R G THE CHAMPION
INTERPOL RED NOTICES AND DIFFUSIONS
argue that Interpol is prejudicing its Within one month of its determination, announced that his lawyers would file a
image and interests by allowing a mem- the CCF is required to send the General request with the CCF to have the Red
ber nation with a poor human rights Secretariat a report containing its Notice canceled.160 About one year later,
record to maintain a Red Notice or recommendations.155 The General Interpol canceled the Red Notice.161 In its
Diffusion against the client.148 Secretariat then has one month to reject communication with Harrath, Interpol
those recommendations before the stated that “after re-examining all the
4. Timeline for CCF Challenge. report becomes final.156 information in the file,” it “considered that
There is no published timeline for Anecdotal evidence, gathered from the proceedings against [him] were pri-
deciding a request for information or a well-publicized cases involving requests marily political in nature.”162 The Red
challenge to information contained in for Red Notice cancellation, provides fur- Notice had been in effect for 20 years.
Interpol’s files. The CCF’s Operating ther insight into the timeline of a CCF
Rules state that the CCF processes request. These cases, however, might not 4b. Petr Silaev. For Russian activist
requests in the order received, reserving be fully representative, as most applica- Petr Silaev, the CCF challenge process
the right to “decide to give priority to a tions do not receive the kind of media took about five months, but was unsuc-
particular request.”149 The CCF is attention these cases received. It appears cessful. In July 2010, Silaev participated
required to acknowledge receipt of a that publicity and political support can in a demonstration protesting construc-
request within one month of its have an effect on Interpol. tion of a highway through the Khimki
submission,150 and, as a threshold matter, forests near Moscow.163 After seeing his
the CCF Secretariat must determine 4a. Mohamed Ali Harrath. Mohamed fellow protestors arrested by Russian
whether the request is admissible.151 If it Ali Harrath, a political dissident who police, Silaev fled in April 2012, and was
is, the CCF Secretariat makes a “detailed endured imprisonment and torture for granted asylum in Finland.164 Russia cir-
assessment of the request by reference to campaigning against President Ben Ali’s culated a Diffusion requesting Silaev’s
the Organization’s Rules” and submits a regime in Tunisia, became the subject of a arrest, and in August 2012 Spain
summary of the case to a CCF session Red Notice in 1992.157 He fled to the detained Silaev.165 Spain, however,
for consideration and United Kingdom, where he lived in exile refused to extradite him, concluding
recommendations.152 The CCF, however, until his arrest in South Africa in January that the Russian charges were politically
meets only three times a year.153 Thus, 2010 based upon the Red Notice.158 motivated.166 Nevertheless, the Diffusion
depending on the number of requests,154 Extradition proceedings were instituted, remained in effect.167 On May 20, 2013,
it could be months before the CCF but after the Tunisian government failed Fair Trials International filed a request
Secretariat makes an admissibility to provide evidence in support of the with the CCF to have the Diffusion can-
decision, and more months before the charges, the South African court dis- celed and information in Interpol’s files
CCF evaluates the merits of the request. missed the case.159 Harrath then regarding Silaev deleted.168 On Oct. 25,
W W W. N A C D L . O R G M AY 2 0 1 4 352013, Interpol denied the request, stat- financial and visa-related penalties on believes the Red Notice or Diffusion
ing that “there is no reason to believe Russian citizens who have committed was simply requested in error, the most
that the retention of information [relat- human rights violations. direct route for its cancellation is
ing to Silaev] in INTERPOL’s files Browder was already well known through the NCB that applied for it.178
would not be in compliance with before his dispute with Russia. The The requesting NCB must withdraw its
INTERPOL’s rules.”169 high-profile nature of the dispute, how- request and ask the General Secretariat
ever, was likely a factor in Interpol’s to cancel the Notice immediately when:
4c. William Browder. William decision to cancel the Blue Notice with- (1) the purpose of the request has been
Browder, a British investment banker, in one month of his request for its can- achieved; (2) the alert is linked to and
became the subject of a Blue Notice in cellation.175 Interpol released a rare dependent upon another request
May 2013 after campaigning against public statement about its decision, whose purpose has been achieved; (3)
human rights abuses by the Russian explaining that the CCF had “conclud- the NCB no longer wishes to maintain
government.170 Although Blue Notices ed … the case was of a predominantly the request; or (4) the notice no longer
(which seek information about the political nature.”176 Later, when the meets the conditions for publication.179
identity, location, or activities of an Russian Federation sought the issuance NCBs can seek cancellation of request-
individual in relation to a crime) differ of a Red Notice against Browder, ed notices at any time, and should do
from Red Notices, the procedure for Interpol again responded publicly, so when the subject of the notice has
seeking their cancellation is identical.171 announcing its refusal to “be used by served his or her sentence or has been
Interpol canceled the Blue Notice with- the Russian Federation to seek the acquitted.180 If the NCB refuses to with-
INTERPOL RED NOTICES AND DIFFUSIONS
in one month of Browder’s request.172 arrest of Mr. William Browder.”177 draw its request and ask for cancella-
Browder had become a human tion, the attorney should submit a
rights activist following the death of his ii. Seeking Relief From the request for cancellation to the CCF,
accountant, Sergei Magnitsky, in a NCB That Requested the supported by documentation showing
Russian prison.173 Magnitsky had been Red Notice or Diffusion that cancellation is required.
arrested after exposing a corruption There are other potential avenues If the underlying arrest warrant is
scheme by the Russian government.174 for challenging a Red Notice or based on inaccurate information, or is
Browder became a proponent of a bill, Diffusion. If the client has been acquit- otherwise susceptible to challenge in the
the U.S. Magnitsky Law, which imposes ted, has served his or her sentence, or issuing country, counsel should work
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Something Better!with local counsel to challenge the arrest Committee cannot resolve the issue, it is http://www.interpol.int/About-INTERPOL/
warrant in order to have it withdrawn or submitted to the General Assembly.186 Structure-and-governance/National-Central-
vacated. In turn, this would require can- While the dispute is pending, the support- Bureaus (last visited May 1, 2014).
cellation of the Red Notice or Diffusion ive NCB can request that the General 17. Id.
based on the arrest warrant.181 Secretariat apply interim measures to pre- 18. About INTERPOL Washington, THE
vent the Red Notice or Diffusion from UNITED STATES DEPARTMENT OF JUSTICE,
iii. Working With a Supportive being circulated among member nations http://www.justice.gov/interpol-washington/
NCB to Cancel a Red or published on Interpol’s website.187 about.html (last visited May 1, 2014).
Notice Or Diffusion 19. See id.
Under certain circumstances, the Conclusion 20. Commission for the Control
client’s most powerful ally might be a sup- of INTERPOL’s Files, INTERPOL,
portive NCB. For example, if the client has A client might have good reason to http://www.interpol.int/About-INTERPOL/
been granted asylum, counsel might ask be concerned about international travel, Structure-and-governance/Commission-for-
the asylum country’s NCB to help chal- as many countries will arrest and detain the-Control-of-INTERPOL’s-Files (last visited
lenge the Red Notice or Diffusion. the subject of a Red Notice or Diffusion. May 1, 2014).
Pursuant to Articles 24, 25 and 135 of There are steps that can be taken to try to 21. See INTERPOL’s Rules on the Control
the RPD, the General Secretariat may ascertain whether the client is the subject of Information and Access to INTERPOL’s Files,
delete information in its databases, includ- of a Red Notice or Diffusion, and, if so, to INTERPOL (Feb. 15, 2010), at arts. 2–3, avail-
ing cancelling Red Notices or Diffusions, try to have it canceled. Nevertheless, the able at http://www.interpol.int/Media/
INTERPOL RED NOTICES AND DIFFUSIONS
based on data obtained from another challenges are substantial. Files/Legal-material/Reference-
NCB.182 A supportive NCB can report a Documents/Rules-on-the-Control-of-
defect in the information used to support Notes Information-and-access-to-INTERPOL’s-
the Red Notice or Diffusion, identify any 1. Overview, INTERPOL, http://www. Files-RCI.
impropriety in the charges or the prosecu- interpol.int/About-INTERPOL/Overview (last 22. Id. at art. 1.
tion, or otherwise question compliance visited May 1, 2014). 23. See INTERPOL’s Rules on the
with Interpol’s Constitution and rules.183 2. Vision and mission, INTERPOL, Processing of Data, INTERPOL (Mar. 14,
The General Secretariat is charged with http://www.interpol.int/About-INTERPOL/ 2013), art. 18, available at http://
ensuring that disputes between NCBs are Vision-and-mission (last visited May 1, www.interpol.int/Media/Files/Legal-mater-
solved by “concerted consultation.”184 If 2014). ial/Reference-Documents/INTERPOL’s-
that fails, the matter is referred to the 3. See INTERPOL FAQs, INTERPOL, Rules-on-the-Processing-of-Data.
Executive Committee.185 If the Executive http://www.interpol.int/FAQs (last visited 24. See Compliance with the rules,
May 1, 2014). INTERPOL, http://www.interpol.int/About-
4. See Overview, supra note 1. INTERPOL/Legal-materials/Compliance-
5. Id. with-the-rules (last visited May 1, 2014); see
6. The Constitution, INTERPOL, also Mario Savino, Global Administrative Law
http://www.interpol.int/About-INTERPOL/ Meets ‘Soft’ Powers: The Uncomfortable Case
Legal-materials/The-Constitution (last visit- of Interpol Red Notices, 43 N.Y.U. J. INT’L L. &
ed May 1, 2014). POL. 263, 272 & n. 22 (2011); Catherine Heard
7. Interpol Constitution and General & Alex Tinsley, The Power of the Interpol Red
Regulations, INTERPOL (Oct. 15, 2008), Notice, 28 No. 8 INT’L ENFORCEMENT L. REV. 299
art. 2, available at http://www.interpol.int/ (2012). By Executive Order dated June 16,
Media/Files/Legal-material/Reference- 1983, President Ronald Reagan granted
Documents/Constitution-and-General- Interpol immunity from suit in the United
Regulations (internal quotation marks States. See Exec. Order No. 12425, 48 Fed.
omitted). Reg. 28069 (June 16, 1983).
W h e r e Do You 8. Id. at art. 3.
9. Structure and governance, INTERPOL,
25. See Compliance with the rules, supra
note 24.
F i n d Th e T im e ?
http://www.inter p ol.int/Ab out- 26. See INTERPOL’s Rules on the Processing
INTERPOL/Structure-and-governance (last of Data, supra note 23, at arts. 11–12.
visited May 1, 2014). 27. Id. at arts. 10(4), 12(3).
CLE on the go
10. Id. 28. See Compliance with the rules,
Any time; Any place
11. Id. supra note 24.
12. Executive Committee, INTERPOL, 29. INTERPOL’s Rules on the Processing
http://www.inter p ol.int/Ab out- of Data, supra note 23, at art. 5(3).
INTERPOL/Structure-and-governance 30. See INTERPOL’s Rules on the Control
/Executive-Committee (last visited May 1, of Information and Access to INTERPOL’s Files,
2014). supra note 21.
13. Id. 31. See Overview, supra note 1.
14. General Secretariat, INTERPOL, 32. Notices, INTERPOL, http://www.
http://www.inter p ol.int/Ab out- interpol.int/INTERPOL-expertise/Notices
INTERPOL/Structure-and-governance/ (last visited May 1, 2014).
General-Secretariat (last visited May 1, 33. Id.
2014). 34. Id.
Scan Here For More Information Online 15. Id. 35. Id.
16. National Central Bureaus, INTERPOL, 36. Id.
38 W W W. N A C D L . O R G THE CHAMPIONYou can also read
