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Our client’s bank would not let him take any money out, and nobody there would tell him why, or for how long. The answer to the second question turned out to be about eight weeks. The cause was an INTERPOL Blue Notice, which the Commission for the Control of INTERPOL’s Files (CCF) later deleted.
He lives in Monaco. At the time he was running substantial litigation in several jurisdictions against large companies and against individuals with the means to retaliate. One of them did. A public statement appeared saying that he was under criminal prosecution, that he had stolen money and that INTERPOL had issued a Blue Notice for him. Somewhere, a prosecutor had been persuaded to open a case.
A Blue Notice is a request to INTERPOL’s member countries to locate a person, or to supply information about him, in connection with a criminal investigation. It is governed by Article 88 of INTERPOL’s Rules on the Processing of Data. It is not a request for arrest, and there is no power of arrest behind one. That is part of why Blue Notices attract so little attention next to Red Notices.
None of that survives contact with a bank’s screening system. Screening matches customer names against notice data and adverse media, and in his case it returned his name alongside the word ‘stolen’ and the word ‘INTERPOL’. A compliance officer reading that output has one safe course open to him, and it is to freeze the account. His first bank froze, and the others followed.
The burden then moves to the customer. Over roughly eight weeks he established the source of funds he had held for years, account by account and transfer by transfer, to the satisfaction of institutions that had no particular reason to hurry. The accounts came back one at a time, while his standing orders failed and his bills went unpaid.
The CCF is the independent body that decides requests to access, correct or delete data held in INTERPOL’s files, and INTERPOL is bound by its decisions. The notice took longer than the accounts. We applied to the Commission, setting out the litigation the allegation had grown out of, the order in which the public statement and the prosecution had appeared, and the absence behind either of anything resembling an ordinary criminal investigation. The Commission deleted the data.
His banks froze the accounts before any court had examined the allegation against him. His money came back before INTERPOL had examined it either. The notice was deleted last of all, and by then the man who arranged it had already had most of what he wanted.
Our INTERPOL practice acts for people subject to Blue Notices, Red Notices and Diffusions, from first discovery of the data through access and deletion requests to the CCF. Where a notice, or a report that one exists, has reached a client’s banks, we advise on the CCF application and on what the banks will need to see before they release the accounts. We set out the arguments that work against Blue Notices in Acquitted but Still Wanted?
Rhys Davies and Ben Keith cover Blue Notices, and the way banks and borders respond to them, in INTERPOL Law and Practice (Sweet & Maxwell), published on 23 September 2026. Order from Sweet & Maxwell.
If your accounts have been frozen after a notice, or after a report that one exists, contact us in confidence.
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Ben Keith in The Times: Russia Is Still Abusing INTERPOL
