Critical developments in INTERPOL’s Silver Notice

Introduction to the INTERPOL Silver Notice

In the landscape of international law enforcement cooperation, few developments in recent years have generated as much practitioner interest or as much quiet alarm in certain quarters, as the rapid emergence of INTERPOL’s Silver Notice.

Launched as a two-year pilot in January 2025, the Silver Notice represents a genuine paradigm shift in how INTERPOL and its 196 member states approach the challenge of tracing, identifying, and ultimately recovering the proceeds of serious crime across international borders.

For decades, INTERPOL’s colour-coded notice system was, in essence, a people-tracing architecture. Red Notices sought the provisional arrest of fugitives. Blue Notices gathered information on individuals. Yellow Notices located missing persons. The notices, diffusions, and related mechanisms that followed all operated on the same underlying logic: start with a person, and trace outwards. The Silver Notice inverts that logic entirely. It starts with the assets  and works backwards.

That conceptual shift matters enormously. The proceeds of serious crime, whether generated by organised crime syndicates, corrupt officials, fraudsters, or cybercriminals, do not sit still. They move across borders, are layered through nominee structures, converted into real estate or corporate interests, and, increasingly, transformed into cryptocurrency. Traditional mutual legal assistance mechanisms, reliant on bilateral treaty frameworks and notoriously slow to execute, have historically given criminals a structural advantage: by the time a formal asset-tracing request is processed, the assets are often gone. The Silver Notice is designed, at least in part, to close that gap.

Gherson has been closely monitoring the development of the Silver Notice since before its launch. As we noted in August 2024, the mechanism was already generating significant discussion in financial crime and international enforcement circles well before the first notice was ever published. Since then, the pace of developments has been striking: the first notice issued in January 2025, the UK and India deploying the mechanism within months, the first criminal charges flowing from a Silver Notice case by June 2025, and, by November 2025, a 127-0 vote at INTERPOL’s General Assembly to extend the pilot, with permanence increasingly looking like a question of when, not if.

This article provides a comprehensive overview of the Silver Notice: what it is, how it came into being, how many have been issued, who is using it, and what its growing application, including to cryptocurrency crime, means for practitioners and their clients.

What exactly is the INTERPOL Silver Notice?

The Silver Notice is INTERPOL’s newest notice type and it is first to focus on assets rather than individuals.  We have previously discussed this in an article:  How will INTERPOL Silver Notices assist in recovering laundered assets?

In summary, INTERPOL’s notice system has historically been built around people. The organisation itself has no powers of arrest, search, or seizure: it functions as a conduit for police cooperation and information-sharing among its member states. Notices are international requests, circulated to all 196 member countries, asking national law enforcement agencies to take specified steps, whether to arrest, locate, identify, or gather information. The colour coding reflects the nature of the request: Red (arrest with a view to extradition), Blue (gather information on a person), Green (warn of criminal activity), Yellow (locate missing persons), Orange (warn of threats), Purple (seek information on criminal methods), and Black (identify unknown bodies). Gherson has extensively explored these notices in a series of previous blogs: The various colour notices of INTERPOL.

The Silver Notice inserts an entirely new category into this architecture. Rather than seeking to locate or arrest a person, a Silver Notice is a formal international request, published to all 196 member states, or to a targeted subset via a Silver Diffusion, to locate, identify, obtain information about, and/or monitor assets that are believed to be linked to serious crime.

The four distinct purposes for which a Silver Notice may be issued are:

• To locate assets that are believed to be linked to a person and to be the proceeds, instrumentalities, or object of a crime;
• To identify assets that may not yet be precisely identified but are suspected to exist;
• To obtain information about assets, including their location, valuation, legal ownership structure, and encumbrances; and
• To monitor assets discreetly and/or continuously, an intelligence-gathering function that may occur over a sustained period.

Critically, the Silver Notice does not itself confer any coercive powers. It cannot freeze, seize, or confiscate assets. What it does is create a multilateral, institutionalised channel for the intelligence-gathering phase of asset recovery, the phase that, in many serious criminal cases, is the hardest and most time-sensitive part of the puzzle.

When a Silver Notice locates assets in a particular jurisdiction, the requesting state then pursues seizure or confiscation through its own national legal process, whether that is a criminal confiscation order, a civil recovery claim, or a formal mutual legal assistance request to the jurisdiction where the assets are held. In the UK context, this means the NCA can initiate proceedings under POCA 2002 on the basis of intelligence generated by a Silver Notice, without needing to await the conclusion of criminal proceedings, a significant procedural advantage.

The categories of asset explicitly contemplated are broad: real estate, corporate shareholdings, financial accounts, vehicles, businesses, cash, and notably — cryptocurrency wallets, Non-Fungible Tokens, and other digital assets. The framework also expressly covers transformed assets: where criminal proceeds have been converted into crypto-assets. This breadth is deliberate and reflects the contemporary reality of how serious criminal proceeds are held and moved.

The eligibility criteria are, however, cumulative and demanding:

• The request must relate to a natural person subject to an active criminal investigation;
• The offence must carry at least four years’ imprisonment;
• The requesting authority must hold sufficient judicial data, including a decision confirming assets are subject to criminal restraint or forfeiture; and — importantly,
• No prior conviction is required.

A Silver Notice can be issued during an ongoing investigation, before any charges or findings of guilt. That feature is both its greatest operational strength and its most significant due process risk.

When was the Silver Notice introduced?

The Silver Notice’s conceptual origins lie more than a decade before the first notice was published.

The idea was first formally raised at the 84th INTERPOL General Assembly in Kigali, Rwanda in 2015 — a recognition that INTERPOL’s notice architecture, powerful as it was for locating people, had a structural blind spot when it came to locating the proceeds of crime. At that stage it remained a proposal.

Progress accelerated following INTERPOL’s establishment of its Financial Crime and Anti-Corruption Centre (IFCACC) in 2022. In December 2023, an Expert Working Group formally recommended proceeding with a pilot. The recommendation went to the 91st General Assembly in Vienna, which passed Resolution GA-2023-91-RES-11 — authorising a two-year pilot of Silver Notices and Diffusions, with 52 countries and territories invited to participate.

The legal framework was published on 16 January 2025. Within days, on 10 January 2025 (pre-dating its formal publication), the world’s first Silver Notice had been issued — by Italy, targeting a high-ranking mafia figure whose money laundering scheme was valued at over half a billion euros. The result: over USD 1.7 million in illicit assets identified in Brazil.

Key milestones since:

• April 2025: UK issues its first Silver Notice (£8.5m property fraud);
• May 2025: India issues two Silver Notices, both involving crypto fraud;
• June 2025: 50+ notices published globally; first criminal charges flow from a Silver Notice case;
• September 2025: INTERPOL announces Singapore expansion and Asia-Pacific push;
• November 2025: 93rd General Assembly (Marrakech) — pilot extended, 127-0 vote;
• 2026 General Assembly (Hong Kong): Permanent institutionalisation expected.

As Gherson noted when the mechanism was first explained, the Silver Notice was already one of the most significant developments in international law enforcement cooperation for a generation. The speed of subsequent developments has exceeded initial expectations.

How many Silver Notices have been issued?

The pilot caps Silver Notices and Diffusions in aggregate at 500 across all 52 participating countries (~9-10 per jurisdiction). Within those constraints, the programme has grown substantially.

At the 93rd General Assembly (Marrakech, November 2025), the figures presented were:

• 133 Silver Notices published;
• 35 Silver Diffusions issued;
• 1,800+ responses received from member states;
• 39 countries had submitted requests, drawn from all geographic regions;
• Total financial harm linked to notified cases: more than EUR 30 billion;
• Resolution passed: *127 votes in favour, 0 against, 4 abstentions.

That EUR 30 billion figure is the programme’s most powerful statistic. Even if only a fraction of those assets are ultimately recovered, the mechanism will have demonstrated its value beyond doubt.

The pilot has consumed approximately one-third of its 500-notice cap. The pace of issuance will accelerate as awareness grows and more participating jurisdictions move from passive participation to active deployment.

Which jurisdictions have issued Silver Notices?

The 52 pilot participants span all regions: Algeria, Argentina, Australia, Belgium, Brazil, Burundi, China, Colombia, Congo, Ecuador, Estonia, France, Gabon, Georgia, Gibraltar, Guinea, Hungary, India, Iraq, Italy, Kazakhstan, Kenya, South Korea, Kuwait, Latvia, Malawi, Malta, Moldova, Mozambique, Namibia, Netherlands, New Zealand, Nigeria, North Macedonia, Pakistan, Paraguay, Poland, Portugal, Qatar, Russia, Singapore, Spain, Sweden, Trinidad and Tobago, Ukraine, UAE, United Kingdom, United States, Uruguay, Venezuela, Zambia, and Zimbabwe.

Of these, 39 had actively submitted requests by November 2025.

Some highlights:

• Italy was the first mover — January 2025, mafia money laundering, over USD 1.7m in assets identified in Brazil;
• The UK issued its first notice in April 2025, targeting a convicted property fraudster’s assets. The interaction with POCA 2002, the Economic Crime and Corporate Transparency Act 2023, and the UK’s civil recovery framework is significant and likely to generate substantial litigation as the mechanism matures;
• India entered the arena dramatically in May 2025, with two notices, both crypto-related, issued by the Enforcement Directorate. As [Gherson reported], this marked the mechanism’s first deployment in South Asia. By June 2025, eight individuals had been charged in the first case — [the first criminal proceedings to flow directly from a Silver Notice]. A milestone;
• Singapore is emerging as the Asia-Pacific hub. As [Gherson reported in September 2025], INTERPOL announced plans to strengthen its presence through the IGCI in Singapore, with a specific focus on expanding Silver Notice usage across the region;
• Russia, Venezuela, and Pakistan — participants that have attracted concern from practitioners given historical Red Notice abuse patterns. The absence of a conviction requirement creates structural vulnerability to politically motivated use. The CCF challenge mechanism exists but typically takes 6 months to 2 years, and specific Silver Notice challenge jurisprudence is still developing;
• The Silver Notice featured prominently at INTERPOL’s European Regional Conference in June 2025 — attended by 150+ senior police representatives, underlining that the days of this being a theoretical mechanism are firmly over.

Can a Silver Notice be used in connection with crypto-related crime?

Yes — and this may prove to be among its most consequential applications.

The legal framework explicitly includes cryptocurrency wallets, NFTs, and other digital assets in the categories of notifiable assets. It also covers transformed assets, where criminal proceeds have been converted into crypto-assets, meaning a Silver Notice can follow them through the blockchain.

The significance is substantial. Crypto presents unique challenges to traditional asset recovery: pseudonymity, borderless transferability, mixing services, and the speed at which assets can be moved means the intelligence-gathering phase is both critical and time-sensitive. By the time a traditional MLAT request is processed, crypto wallets can be emptied and the trail rendered unrecoverable.

The Silver Notice directly addresses this by enabling a rapid, multilateral intelligence request across all 196 member states simultaneously, requesting information about known or suspected wallets, exchange accounts, or on-chain activity.

India’s May 2025 cases provide the first concrete examples, as Gherson reported.

• Amit Lakhanpal — founder of fraudulent cryptocurrency scheme MTC, which raised approximately 113 crore rupees (~USD 13.5m) from defrauded investors without regulatory approval. Silver Notice sought to trace assets in undisclosed accounts, properties, and crypto-linked holdings. Eight individuals were subsequently charged — the first criminal proceedings directly from a Silver Notice.
• Shubham Shokeen — former French Embassy visa officer accused of bribery, with a Silver Notice targeting Dubai property valued at 15.7 crore rupees.

The UK’s legal framework is particularly well-suited to leveraging Silver Notice intelligence in crypto cases. The Economic Crime and Corporate Transparency Act 2023 strengthened NCA powers to seize crypto-assets on the basis of foreign intelligence including INTERPOL mechanisms. POCA 2002’s civil recovery framework can be engaged without a criminal conviction, meaning UK-held crypto-assets identified via a Silver Notice can be subjected to civil recovery proceedings even where prosecution is ongoing abroad.

As Gherson noted in March 2026, the Silver Notice “signals a broader shift toward financial enforcement and asset recovery — particularly relevant in crypto cases, where identifying and freezing funds may be more important than immediate arrest.” In cases where suspects are in jurisdictions from which extradition is unavailable, the traditional Red Notice route may be blocked, but the assets, including crypto-assets, remain accessible in financial centres across the globe.

Further dimensions for practitioners:

• Exchange cooperation: Centralised exchanges in INTERPOL member states (virtually all major exchanges) can be compelled to provide information by domestic authorities acting on Silver Notice intelligence. For clients using regulated exchanges, this is a significant practical risk;
• DeFi: Non-custodial wallets and decentralised protocols present greater challenges, there is no regulated intermediary. But Silver Notices can generate the multi-jurisdictional intelligence cooperation that makes blockchain forensics operationally viable at exchange touchpoints;
• NFTs: The explicit inclusion of NFTs reflects INTERPOL’s awareness of evolving asset landscapes. As institutional NFT ownership grows, this dimension will become more operationally relevant;
• Privacy coins and mixing: Where proceeds have been routed through Monero, Zcash, or mixing services, on-chain tracing is severely limited. Silver Notices in crypto cases will typically focus on exchange on/off-ramp touchpoints. This will drive greater regulatory pressure on privacy infrastructure globally.

Conclusion

The Silver Notice has, in little more than a year, moved from theoretical proposal to active and rapidly expanding mechanism. With 133 notices published, EUR 30 billion in linked financial harm identified, criminal charges flowing from the first cases, and a 127-0 General Assembly vote confirming political support, the direction is clear: permanence is a question of when, not if.

For practitioners and clients with cross-border asset exposures, this matters. The traditional comfort of geographical distance, slow MLAT processes, and bilateral treaty gaps is being systematically eroded. Assets in virtually any jurisdiction are now potentially subject to a multilateral intelligence mechanism that can be triggered without a conviction and without the subject necessarily knowing it has been invoked.

Silver Notices during the pilot are confidential, not published on INTERPOL’s public website. A subject may only become aware when domestic law enforcement in the relevant jurisdiction takes action on the intelligence generated.

The absence of a conviction requirement means notices will be issued in contested, politically motivated, or evidentially questionable cases. Participation by jurisdictions with weaker rule of law records is cause for genuine concern. Early advice and proactive CCF engagement will be essential for clients exposed to Silver Notice risk from less scrupulous requesting states.

Conversely, for clients who are victims of serious financial crime, the Silver Notice is a potentially powerful new tool. Engaging with national authorities capable of requesting a notice, and ensuring robust evidential documentation, could significantly accelerate the intelligence-gathering phase of a recovery case.

Gherson will continue to monitor developments. For advice on any aspect of the Silver Notice — whether you are concerned about risk, seeking to challenge a notice, or considering how the mechanism might assist in asset recovery, please contact our team.

How Gherson can help

Those who suspect that they may be subject to INTERPOL measures, including a Red (or Blue) Notice and diffusion, should take heed.

Gherson Solicitors continue to receive requests for expert advice and assistance from those who believe they may have outstanding financial issues. That advice tackles:

1. How best to approach a possible INTERPOL notice;
2. Preparing for potential criminal proceedings / an extradition request;
3. Preparing for a situation where a civil matter or commercial dispute could be used to initiate bogus criminal proceedings; and
4. Even exploring the possibility of instigating civil litigation proceedings to recover any misappropriated assets.

Gherson have previously written a series of blogs designed to assist those who suspect they may be subject to INTERPOL measures (including a Blue and a Red Notice):

• INTERPOL and Red Notice Challenges
• How to Remove an INTERPOL Red Notice
• INTERPOL Red Notices and Extradition
• How do I know if I am subject to an INTERPOL Red Notice?
• What is INTERPOL’s Silver Notice?
• INTERPOL UPDATE – India charges 8 people in first Interpol Silver Notice Case
• What is an INTERPOL Yellow Notice?
• What is an INTERPOL-United Nations Security Council Special Notice?
• What is an INTERPOL Purple Notice?
• What is an INTERPOL Green Notice and can it be challenged?
• What is an INTERPOL Orange Notice and can it be challenged?
• What is the purpose of an INTERPOL Blue Notice, and can it be challenged?
• What is an INTERPOL Blue Notice?

Gherson has over 37 years of experience in assisting with all aspects of INTERPOL, Red Notice challenges and extradition. If you would like to speak to us in respect of any of the issues raised in this blog or about your specific circumstances,  do not hesitate to contact us for advice, send us an e-mail, or alternatively, follow us on X, Facebook, or LinkedIn to stay-up-to-date.

The information in this blog is for general information purposes only and does not purport to be comprehensive or to provide legal advice.  Whilst every effort is made to ensure the information and law is current as of the date of publication it should be stressed that, due to the passage of time, this does not necessarily reflect the present legal position.  Gherson accepts no responsibility for loss which may arise from accessing or reliance on information contained in this blog.  For formal advice on the current law please do not hesitate to contact Gherson.  Legal advice is only provided pursuant to a written agreement, identified as such, and signed by the client and by or on behalf of Gherson.

©Gherson 2026