What a Silver Notice is for
INTERPOL introduced Silver Notices and Diffusions through a pilot framework for non-coercive international exchange of asset-related information. They may be used to locate or identify assets, obtain information about them, or monitor them for criminal forfeiture purposes.
The mechanism may concern real estate, vehicles, financial accounts, businesses and other assets across borders. It does not replace the separate national procedure required to freeze, seize or confiscate property.
Official reference: Legal Framework Governing the Silver Notice and Diffusion Pilot (PDF) ↗.
What the requesting country must establish
Under the pilot framework, a request must concern assets connected with a natural person who is the subject of a criminal investigation. The underlying conduct must meet the pilot’s seriousness threshold, and the request must provide sufficient facts linking the alleged criminal activity, the person and the assets sought.
The submission should identify the asset categories and explain the suspected criminal origin or use of the property. The mechanism cannot be used for a general enquiry into a person’s wealth.
Information may not be public
Extracts of Silver Notices are not published on INTERPOL’s public website under the pilot framework. A person may therefore be unaware that asset-related data are being exchanged through INTERPOL channels.
An access request to the CCF may ask whether personal data are processed and seek information that may be disclosed. Confirmation and disclosure remain subject to the applicable rules and consultation with the source.
What a legal review may examine
A review may examine whether a qualifying criminal investigation exists, whether the seriousness and evidential criteria are met, and whether there is a sufficiently specific link between the alleged offence, the person and the identified assets. Accuracy, relevance, proportionality, neutrality and fundamental-rights requirements may also be material.
Where a national authority has already imposed a restraint or forfeiture measure, that measure must usually be challenged in the country where it was made. CCF proceedings address INTERPOL data and do not replace domestic remedies concerning the property itself.
What I can do
I can analyse the underlying Russian investigation and the asserted asset trail, prepare an access, correction or deletion request to the CCF, and identify gaps in the alleged link between the client, the conduct and the property. I can also coordinate the INTERPOL submission with local counsel handling freezing, disclosure or forfeiture proceedings in the relevant jurisdiction.
Related guidance: CCF deletion requests and cross-border criminal advice.
A Silver Notice is not a judicial finding and does not itself authorise the freezing, seizure or confiscation of assets.