On June 25, 2026, the Parliamentary Assembly of the Council of Europe (PACE) did something that rarely happens in the field of international police cooperation: it named, with figures and without euphemisms, the misuse of INTERPOL's notice system as a tool for transnational repression.
Less than a month later, on July 22, 2026, INTERPOL published the list of twenty candidates who will compete, in November, for the seven seats of the Commission for the Control of INTERPOL's Files (CCF), the only body capable of canceling an abusive Red Notice.
It is not a minor coincidence. They are two aspects of the same problem: who abuses the system and who must correct it. For a business owner, a banker, or an executive with international exposure, understanding both fronts is no longer an academic exercise. It is information that can anticipate an arrest at an airport or prevent years of reputational wear and tear.
What Europe warned about in 2023 and repeated even more strongly in 2026
It is advisable to be precise with the dates, because in a written defense, chronological precision is as relevant as the argument itself. In June 2023, the Parliamentary Assembly of the Council of Europe had already adopted the Resolution 2509, based on a report by Sir Christopher Chope (United Kingdom), warning about the risk that transnational repression poses to the rule of law. That text did not centrally mention INTERPOL.
Three years later, the Committee on Legal Affairs and Human Rights of the Assembly approved a new report, based on the work of Cypriot member of parliament Constantinos Efstathiou, and the plenary of the Assembly debated and adopted it on June 25, 2026: the Resolution 2669, entitled «Fighting Back Against Transnational Repression». It is this Resolution 2669, and not Resolution 2509, that is directly relevant to anyone facing or fearing an INTERPOL notice.
According to the initial expert analyses following the debate, the vote concluded with 52 votes in favor, 5 against (the entire delegation of the Turkish ruling party), and 7 abstentions. We recommend, in any case, verifying this figure directly against the official record of results at pace.coe.int before citing it in a legal brief.
What is indeed consistent among the available sources is the content. The new 2026 text expressly condemns «the misuse of legitimate mechanisms of international legal cooperation, such as the INTERPOL notification system, extradition requests, mutual legal assistance frameworks, and measures against money laundering and the financing of terrorism.» The text relies on data from Freedom House: at least 1,375 documented incidents of transnational repression since 2014, attributed to 54 States with victims in 107 host countries.
Turkey and Russia are among the most criticized states. Russia, expelled from the Council of Europe in 2022, continues to generate concern due to the partial lifting of corrective measures that INTERPOL's Executive Committee had imposed on it.
The Assembly further recommends that member states reject the agreement currently under discussion to expand INTERPOL's legal immunities, and calls for the designation of national focal points against transnational repression.
This resolution does not arrive alone. It is preceded by the European Parliament one, passed on November 13, 2025 with 512 votes in favor, 76 against, and 52 abstentions, concerning the protection of human rights defenders against transnational repression. Two different European institutions, the Council of Europe and the European Union, have reached a converging conclusion in less than eight months.
It is also useful to be precise about the scope: none of these resolutions legally binds the CCF or orders the annulment of any notice. However, they constitute an institutional context of considerable weight. When a lawyer invokes Article 3 of INTERPOL's Constitution before the Commission (which prohibits any intervention in matters of a political, military, racial, or religious character), they are no longer arguing in a vacuum. They do so backed by two European parliaments that have documented, with figures, the pattern of abuse they are denouncing.
Seven seats, twenty candidates: the election that decides who controls your file
The seven current terms in office on the CCF expire, all at once, on March 11, 2027. This coincidence is explained by the fact that the seven current members were elected in the same cycle, in 2022; it is usual for renewals to be staggered, but this year will not be the case. The election will be held at the 94th INTERPOL General Assembly in Hong Kong, from November 30 to December 3, 2026.
The INTERPOL Executive Committee approved twenty candidacies from seventeen countries. Five of the seven outgoing members are seeking re-election: President Teresa McHenry (United States), Michel Forst (France), Hamza Es Said (Morocco), Mohamed Kamara (Lebanon), and Mohamed Elfadhel Miled (Tunisia). The other two current members, from Belgium and the United Kingdom, do not appear on the list of candidates. This guarantees two entirely new representation seats.
Among the fifteen candidates who are currently not members of the Commission are jurists and specialists from Georgia, Cameroon, Italy, Ukraine, Mexico, Namibia, India, Turkey, the Netherlands, and the United Kingdom, among other countries. A relevant fact for the region: Argentina provides the only Latin American candidate from the twenty, Ramiro Anzit Guerrero, criminal intelligence director of his country and former officer of the INTERPOL General Secretariat in Lyon.
Michel Forst, along with President McHenry, is one of the profiles with the highest international projection among those aspiring to a second term. Forst is a current member for France and was the United Nations Special Rapporteur on the situation of human rights defenders.
The selection is not based on nationality quotas: no country may have more than one national on the CCF. Instead, it is based on specialization categories required by the Statute: international police cooperation, international criminal law, human rights, data protection, electronic information processing, and high-level judicial or prosecutorial experience. Each category corresponds to one of the seven seats. The very breakdown of the candidacies reveals how uneven the competition is within each category: only two of the twenty candidates demonstrate specific experience in data protection, the specialty required for a single position, while as many as six candidates with a senior judicial or prosecutorial background are competing for the seat reserved for that profile.
There is one piece of data that is of direct interest to anyone who has submitted, or is considering submitting, an application to the CCF. The Commission's Statute sets five-year terms, renewable only once for an additional period of three years. In practice, this means that those elected for the first time in Hong Kong will remain in office until 2032, while those who are re-elected—predictably including Chairperson McHenry—will complete a second and final term of just three years, until 2029. The institutional architecture of the CCF thus prevents the indefinite tenure of its members, thereby reinforcing its independence from any country.
A vote of confidence and a pending task in the national link
The twenty candidates approved by the Executive Committee do not compete on equal terms with one another: each one demonstrates the specific profile required by their category: international police cooperation, international criminal law, human rights, data protection, electronic information processing, or senior judicial or prosecutorial experience. This requirement for specialization, seat by seat, is in itself a vote of confidence in the new Commission: whoever joins it as of March 2027 will arrive precisely accredited in the subject matter they will be responsible for judging.
But the CCF is, by design, the final control instance. The first line of defense against abuse is much further back: in the National Central Bureaus (NCBs) of each country, which are the ones that enter, or should reject, a request for a red notice or diffusion before it even reaches the General Secretariat. No CCF reform, no matter how sophisticated, replaces the rigor that must be exercised at that first filter.
Author's personal contribution
Speaking personally and after more than two decades litigating these cases, I venture to make a specific recommendation here. NCBs should have internal protocols, not just declarations of principle, so that an official subjected to undue political pressure, aimed at processing a request without prior judicial review, can report it through a protected internal channel without fear of reprisal. Furthermore, such a report should have real disciplinary consequences when the abuse is confirmed. The specialized and ethical training of those who decide which request leaves a country for INTERPOL is not an administrative luxury: in my view, it is the most cost-effective investment any State can make to prevent its own institutions from ultimately being held accountable before the Council of Europe.
At the same time, it is advisable to reinforce something we already documented in our analysis of the 2025 reforms: since then, the INTERPOL General Secretariat plays a more active role in the compliance review before a notice is published and becomes visible to 196 countries. That dual filter, national and central, is in theory the correct architecture. What the current moment demands is that both links, and not just the second one, operate with the same standard of rigor.
The silent reform: fewer missed deadlines, more agility in the simple things
While a decision is being made on the composition of the CCF, the Commission itself has begun to change the way it operates. Starting in 2026, it will replace its four annual five-day sessions with three longer sessions, each lasting approximately two weeks, scheduled for late January, June, and September–October. This is a pilot program in response to a concerning statistic: in 2024, up to 70% of access requests were not resolved within the statutory deadline.
The change with the greatest practical impact is the expansion of the delegation of powers to the rapporteur and the chairperson for «appropriately non-complex» cases, combined with greater use of remote reviews between plenary sessions. A simple, well-documented file can now be resolved without waiting for all seven members to meet in a plenary session. This is the case, for example, of a red notice manifestly contrary to Article 83 of INTERPOL's Rules on the Processing of Data, because it stems from an administrative, labor, or commercial dispute. Complex, politically sensitive cases, or those with indications of persecution, on the other hand, will remain reserved for the full deliberation of the Commission.
This reform adds to the one we already analyzed in our study of the 93rd General Assembly, held in Marrakech in November 2025: since 2024, CCF members have been granted up to 80 days of paid work per year (125 in the case of the presidency), compared to the previous 26 days. The practical conclusion is twofold. Well-constructed cases, backed by a solid technical dossier from the outset, now have a faster path toward a favorable resolution. Complex cases will still require patience, evidentiary rigor, and ongoing support before the Commission Secretariat.
A commission risking its own credibility
It wasn’t always this way. In the past, the integrity of the CCF was the subject of serious questions in specialized international forums. Under the chairmanship of Teresa McHenry, that chapter appears to be behind us: according to figures released by INTERPOL itself, in 2024, 40% of the data reviewed by the Commission were found to comply with the organization’s standards, reflecting a sustained improvement in the quality and speed of decisions. Furthermore, no country currently subject to corrective measures by INTERPOL’s Executive Committee is among the approved candidates for 2026.
At VENFORT, we have represented high-net-worth business leaders and former high-ranking government officials before the CCF who were targeted through fabricated notices following a shift in political power. It is the classic pattern of cross-border lawfare. That direct experience before the Commission, session after session, is what enables us to anticipate how a file will be read and what arguments truly drive a decision, long before the case reaches Hong Kong or any other venue of the General Assembly.
It is, in that sense, good news both for those seeking to renew their term and for those arriving for the first time. The five members running for re-election must be credited with something of no small importance: having maintained, for five years, a work standard that today serves as a benchmark for the entire organization. For the fifteen new candidates, it is an opportunity to bring fresh profiles to the Commission precisely at a time when two European parliaments have examined, with data and without ambiguity, the misuse of the mechanisms that the CCF is called upon to control. Accumulated experience and renewal do not compete with one another: both are, ultimately, what sustains the institutional trust that a client needs when their freedom of movement depends on the decision of seven people.
Three frequently asked questions about your case before the CCF
Is there an appeal against a CCF decision upholding a red notice?
No. The CCF Statute it does not provide for an appeal in the strict sense, but rather a review (Article 42) before the Commission itself, admissible only when a new fact appears that, had it been known at the time, could have changed the conclusion. The deadline to request it is six months from the discovery of that new fact, not from the date of the original decision. At VENFORT, we recommend initiating the review immediately when a genuinely new element arises within that period and, when there is none, calmly evaluating whether it is advisable to wait for the renewal of the Commission's composition, such as the one taking office in March 2027, before submitting a substantially identical request to the same seven members who already rejected it.
What happens to the applications already submitted while the composition of the CCF is being renewed?
They are neither paralyzed nor do they restart. The seven current members continue resolving cases until the end of their term on March 11, 2027; as of that date, pending files are transferred to the new composition without the change, in and of itself, making it mandatory to submit a new application. It is a different matter that, before a renewed Commission, it may be advisable to reinforce the file with additional arguments or elements, something that at VENFORT we evaluate on a case-by-case basis.
Is every red notice derived from a labor or commercial dispute automatically invalid?
Not automatically. Article 83 of INTERPOL's Rules on the Processing of Data prevents the use of the notification system to enforce obligations arising from private contracts, but the Commission requires that the civil, labor, or commercial nature of the matter be established on a case-by-case basis: it is not enough to merely allege it, it must be proven with the case file. This is precisely the type of «non-complex» case that, under the reform in effect since 2026, the rapporteur or the presidency can resolve without waiting for all seven members to meet in plenary session.
What does this mean to you
For a business owner, a banker, or a family with international exposure, these two developments (the European condemnation of the abuse of the INTERPOL system and the complete overhaul of the CCF) are not distant news. They are a sign that the environment in which reputation and freedom of movement are at stake is changing, and that those who act with anticipation and technical rigor will find, in the coming months, a more favorable window than in previous years.
Latin America is today the region where this pattern repeats most frequently: changes of government followed by fabricated charges against business owners, bankers, and former officials of the outgoing administration. From Caracas and Madrid, with a network of allied law firms in Colombia, Panama, the Dominican Republic, and the rest of the region, we coordinate the strategy before the CCF from the very first sign of risk, not from the moment of arrest at the airport. This same architecture now extends to other jurisdictions where asset exposure demands identical discretion, such as the Persian Gulf, and allows us to anticipate how a case file will be interpreted both by the INTERPOL General Secretariat and by the new composition of the Commission taking office in March 2027.
The composition of the CCF will change in Hong Kong. The standards it demands will not change. That is why the recommendation we make to our clients remains the same: act before the notification exists, not after.
By Dr. Alan Aldana · Managing Partner of VENFORT Abogados · Attorney admitted to the International Criminal Court · Director of the Venezuelan Committee of the World Compliance Association
Confidential consultationcontacto@venfort.com
VENFORT By Aldana & Abogados · Madrid · Caracas · Presence in 15 jurisdictions International criminal defense · Extraditions · INTERPOL · Sanctions · Corporate lawfare
Founding partner and Director of the International Criminal Law Department at VENFORT Lawyers. Lawyer accredited before the International Criminal Court, with over twenty years of practice in extraditions, INTERPOL proceedings, economic criminal law, and international sanctions, assists entrepreneurs, executives, institutions, and families with interests in Europe and the Americas.
