A Numbers Game: The Worrying Data of Non-Compliant Notices Registered by Interpol

Interpol’s notices are among the most powerful tools at the organization’s disposal, enabling the arrest and extradition of individuals, as well as the collection of information about a person, or the dissemination of warnings regarding potential criminal activities.

However, with great power comes great responsibility. As readers of this blog know well, if issued improperly, notices, particularly red notices, impose severe consequences on innocent individuals, ranging from deportation and extradition proceedings to administrative detentions for status verification and even the freezing of financial assets. To prevent the misuse of these tools, Interpol’s Commission for the Control of Interpol’s Files (CCF) reviews a portion of the data registered with the organization and reports its findings annually to Interpol’s General Assembly.

We have taken a look at the statistics to see what they reveal. To date, the CCF has published reports covering the period from 2002 to 2023. Our analysis of the CCF’s data reveals some alarming trends, particularly in three areas: (i) the increasing number of requests submitted to the CCF, (ii) the persistent involvement of authoritarian regimes as issuers of contested notices, and (iii) the surprisingly high success rate of challenges to the legality and compliance of Interpol’s registered notices.

The CCF is often perceived as an understaffed and underfunded institution within Interpol. The data supports: in its first report (2002), the CCF received only 120 requests for review. However, this number has increased exponentially over the years, reaching a staggering 2,743 requests in 2023. In other words, the number of cases submitted to the CCF has risen by 2,133%, far exceeding the Commission’s original scope and budget.

The sharp rise in cases submitted to the CCF raises serious concerns about Interpol’s ability to keep up with the growing demand for oversight. The increase from just 120 review requests in 2002 to a shocking 2,743 in 2023 suggests that more individuals are finding reasons to challenge the legitimacy of Interpol notices. While this could indicate greater awareness of the legal mechanism to control Interpol’s actions, partially due to the massification of the use of Internet, it also suggests that Interpol’s notice system is being exploited more frequently.

Second, the CCF has revealed which countries’ notices are most frequently challenged. While the CCF is inconsistent in disclosing this data—perhaps due to its sensitivity—it has done so for the periods 2005–2009, 2012–2013, and 2015–2017. Although the CCF states in its reports that the listing of countries does not necessarily indicate a pattern of non-compliant notices, the repeated appearance of certain nations—such as Russia, the United Arab Emirates, China, Moldova, Venezuela, and Turkey—statistically confirms the need for stricter oversight as these countries have consistently used Interpol’s notices to target political opponents and businessmen involved in disputes with the state among others.

The third, and perhaps most alarming, statistic is the high percentage of Interpol-registered data that the CCF finds to be non-compliant with the organization’s rules. The CCF has been publishing this data since 2012, revealing concerning trends. In 2012, 42% of reviewed notices were found non-compliant; in 2013, the figure rose to 47%; in 2014, 38%; in 2015, 37%; in 2016, 54%; in 2017, 65%; in 2018, 48%; in 2019–2020, 57%; in 2021, 61%; in 2022, 57%; and in 2023, 53%.

Thus, an average of 50.8% of the complaints submitted before the CCF about an Interpol’s notice are likely to be found as non-compliant. The average failure rate of over 50%, the data suggests that Interpol’s internal safeguards are not working as they should. If more than half of the reviewed notices are deemed to violate Interpol’s own rules, it implies that a significant number of individuals are being wrongfully targeted. The high rate of non-compliance underscores the need for more stringent oversight before notices are issued, rather than relying on a flawed review system after the damage has already been done.

Ultimately, these statistics point to a deeper accountability issue within Interpol. While the CCF plays a crucial role in addressing wrongful notices, its limited budget and human resources make it difficult to assess the full extent of the problem. If Interpol is serious about preventing abuse, it must strengthen oversight mechanisms, increase funding for the CCF, and enforce stricter rules to ensure that its notices are not weaponized for persecution. Without meaningful reforms, Interpol risks losing credibility as a neutral and reliable international law enforcement body.

The alarming rate of non-compliant notices highlights a serious flaw in Interpol’s system, one that disproportionately affects individuals who lack the knowledge or financial resources to challenge wrongful listings. While those with legal expertise and financial backing may navigate the complex process of contesting a notice, many others remain defenceless, often unaware of their predicament until they face arrest, travel restrictions, or frozen assets. The fact that over half of reviewed notices violate Interpol’s own rules suggests that countless individuals are being unfairly targeted, with little recourse available to them. This is a matter of fundamental justice. If authoritarian regimes can manipulate its mechanisms to silence dissidents and settle personal or political scores, the organization risks being seen as a tool for repression rather than justice. Strengthening oversight, increasing transparency, and making legal remedies more accessible are urgent steps Interpol must take to prevent further abuse.

The Committee on the Processing of Data (CPD), the Interpol body responsible for reviewing and making recommendations on the organization’s processing of data, has recently launched a process to review the legal framework governing the work of the CCF. The CPD sought contributions from civil society concerning the procedure for the examination of new requests to the CCF and concerning the misuse of CCF proceedings. Red Notice Monitor editors, Ben Keith and Rhys Davies, made submissions suggesting practical approaches to strengthen the proposed amendments, facilitate implementation, and curtail abuse. We will publish the submissions in our next blog.

Image: via Unsplash by Nicholas Cappello

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Thanks to Cristian González Ruiz for assisting in the research and drafting of this blog.

Cristian is a Colombian-qualified lawyer and International Consultant with experience in strategic litigation before national and international tribunals. He was awarded Pro-Bono Lawyer of the year in 2021. Cristian holds an Advanced LL.M. in Public International Law (Cum Laude) from Leiden University, LL.M in International Law, BA in Political Science and J.D. (eq.) in Law by Universidad de Los Andes (Colombia).