The 2025 INTERPOL General Assembly in Marrakesh adopted a series of resolutions substantially reforming the procedures before the Commission for the Control of INTERPOL's Files (CCF). In particular, they introduced new guidelines and regulatory amendments aimed at modernizing the processing of requests for review of notifications (including preventive“ requests” and requests for data deletion), strengthening procedural guarantees and the efficiency of the system. 

These reforms, compared to the rules in place in 2023 and 2024, mark an important evolution in the defense of individuals subject to Red Notices or international notices, especially those potentially politically motivated. Below, we discuss the key changes and their practical implications from the perspective of an INTERPOL defense lawyer.

Reforms Approved at the 2025 General Assembly

In November 2025, the 93rd INTERPOL General Assembly adopted Resolution No. 8, which amends both the INTERPOL Data Processing Rules and the CCF Constitution.[1]. Among the most relevant changes are:

• Amendments to the CCF BylawsArticles 3, 19, 23, 25, 25, 28 and 33 of the CCF Bylaws were revised.[1]. These amendments seek to ensure that the CCF's legal framework and procedures allow it to fully exercise its control and recourse functions, in line with the Article 36 of INTERPOL's Constitution. The General Assembly recognized “the important work carried out by the CCF”.” y “the need for its legal framework and procedures to enable it to fully exercise its functions”.”[2]. In other words, the CCF was given clearer and more effective regulatory tools to monitor data processing and resolve applicant complaints.
• Deletion of Article 94 of the Data Processing RegulationThe same resolution deleted Article 94 of INTERPOL's Rules on the Processing of Personal Data.[1], concerning stolen works of art notices. Although this deletion is of a technical nature and does not directly affect Red Notices or notices, it reflects an effort to update and simplify INTERPOL's rules.
• Balancing Confidentiality and TransparencyIn addition, the Assembly adopted Resolution No. 7, aimed at striking a better balance between the organization's tradition of confidentiality and transparency toward its member countries and the public. Various articles of the General Rules of Procedure and the rules of the General Assembly were amended to formalize the Organization's practices regarding access to governance information.[3]. Although this resolution does not specifically address the CCF, it does indicate a trend of greater openness and accountability, This could be translated into more dissemination of information on file control activities (e.g., publication of anonymized CCF decisions, as is already being done).[4]).

Changes in the Processing of Preventive Applications

What are “preventive applications”? Although the term does not appear in the CCF Bylaws, In practice, this refers to requests submitted by individuals asking INTERPOL to not to process certain data in the future, anticipating that a red notice or broadcast could be issued against him in an abusive manner.[5]. It is a proactive measure: the requesting party provides information to argue that any future diffusion or notice about him/her would violate INTERPOL's rules (e.g., as a case of political persecution). Until 2024, the CCF's policy with respect to such requests was clear and limited: the Commission only The information was forwarded to the INTERPOL General Secretariat, along with the information provided, to to be taken into account in the compliance checks that the General Secretariat carries out if a request for police cooperation is received in relation to that person.[6]. The CCF informed the applicant of this referral, without initiating a formal review of the data (as no data is yet recorded), unless the individual later submits a formal request for access, rectification or deletion after a notice has been issued.[6].

What changed in 2025?

The new guidelines formalize and reinforce this preventive procedure. With the reform of the CCF Statute, the Commission's power to take “appropriate action” when an application is admissible but not admissible has been explicitly recognized. there are no records of the requesting party in INTERPOL's files. (typical situation of the preventive application). In such a case, the CCF may transmit the information received to the General Secretariat to be taken into account in the eventual verification of future notifications, thus fulfilling its function as a preventive guarantee.[6]. This practice, which until 2024 was only an internal policy, is now supported by rules approved by the General Assembly, giving greater official weight to preventive applications.

From the defense perspective, the change implies that a attorney in fact who submits a preventive application on behalf of his or her client can expect a formal response from the CCF confirming the referral to the General Secretariat. While the INTERPOL General Secretariat retains discretion as to how to act (e.g., it could refuse to issue a future Red Notice if it considers allegations of political abuse proven), at least there is now a institutional constancy of the preventive alert. It should be noted that the CCF will not reach a decision on the merits in this preventive phase (it does not “decide” anything yet, since there are no data to be suppressed), but the practical value of this mechanism is early warning to INTERPOL about possible irregularities. In 2023, the CCF itself highlighted the usefulness of these alerts and improved transparency by publishing a detailed explanation of its policy on preventive requests on its website.[4]. Also during 2023, the company worked on the development of guidelines and training modules for National Central Bureaus (NCBs) and the applicants themselves and their attorneys, in order to improve the ability to detect and prevent abuse in international notifications[4].

Comparison 2023-2024In previous years, defense attorneys were already using pretrial motions as part of a strategy of proactive defense. For example, businessmen and opposition figures who feared being the target of politically motivated red notices submitted such requests to the CCF to demonstrate the bad faith of the requesting country. The difference now is that, with the regulatory backing of 2025, these requests take on greater relevance: the General Secretariat should take formal note of the information submitted by the CCF. Although there is no explicit obligation to respond to the requester, the fact that the General Assembly asks to ensure that “data processing remains effective, easily applicable and up to date with the latest developments.”[7] suggests that INTERPOL is seeking to improve its compliance filters. In practice, we expect the General Secretariat to be more rigorous in conducting spot checks where there is a early warning transmitted by the CCF, minimizing the risk of a successful notice against the rules (e.g., in violation of Article 3 of the INTERPOL Constitution, which prohibits politically motivated interventions).[8]).

Changes in the Processing of Data Deletion Requests (Red Notices)

Requests for deletion or correction of data are at the heart of the CCF's contentious function: typically, they are requests from individuals to cancel a Red Notice, a diffusion or any record in INTERPOL's databases that they consider unfair or unlawful. Until 2024, the procedure was clearly defined in the CCF's Constitution and Operating Rules: once a request for cancellation has been made, the CCF will be able to cancel the notice. application was declared admissible, The Application Chamber examined whether data on the requesting party existed in the INTERPOL Information System and, if so, evaluated the compliance of these data with INTERPOL standards[9]. The CCF could request additional information from the applicant, the source country (NCB) and even the General Secretariat during its analysis.[9]. After gathering sufficient elements, the Commission made a reasoned decision. This decision was final and binding for both INTERPOL and the requesting party (no appeal within INTERPOL, except for the extraordinary review by the CCF itself)[10][11]. The role of the Secretary General in this previous scheme was mainly executiveThe CCF communicated the decision to the applicant for implementation, and then notified the applicant and the source NCB in writing of the outcome, indicating that the decision had been made. has been applied by INTERPOL[12]. In other words, the Secretary General (through the General Secretariat) proceeded to delete or correct the data in the files, in compliance with the CCF's decision.

What changes did 2025 introduce?

Although the General Assembly Resolution does not publicly detail the exact wording of each amendment, In addition, it is known that there was an important discussion about the role of the Secretary General in the litigation process. The initial project envisaged strengthening the intervention of the Secretary General formerly of the CCF's decision, granting it the power to make a preliminary “conformity decision” on the contested data.[13][14]. Specifically, it was proposed that the CCF only consider one deletion request. once that the General Secretariat had communicated its final decision on the conformity of such data[13]. In addition, the idea of prohibiting the CCF from ordering provisional measures (e.g., temporary suspension of a red notice) prior to such a prior decision by the Secretary-General[13][15]. These ideas generated concern in the human rights community, given that they postponed the independent intervention of the CCF and could further delay the resolution of urgent cases.[16][17].

Following the consultation process (in which specialized organizations submitted critical comments), the version finally adopted in Marrakech appears to have been more balanced. Article 33 of the CCF's bylaws was amended to clarify the sequence The new system will ensure the collaboration of the Secretary General without undermining the autonomy of the CCF. Although the details have not been disclosed line by line, all indications are that the Chamber of Applications may rely on the assessment of the General Secretariat about the case, but without relinquishing its final decision-making authority or the ability to act quickly and efficiently. in urgent cases. In fact, the amendments to Article 37 relating to provisional measures no The CCF retains the power to issue an urgent suspension of the red notice if circumstances require it, without waiting for a prior pronouncement from the Secretary General (a victory for the effective protection of applicants at immediate risk of detention)[18][19].

In practice, the role of the Secretary General is reinforced in the sense that now will be more actively involved in the initial phaseWhen someone contests a notice, the General Secretariat will have the opportunity to conduct an additional compliance review. This could mean that, in some cases, INTERPOL will voluntarily withdraw or correct a contested notification before the CCF issues its final decision, thus speeding up the settlement. In fact, it was already customary that, upon receipt of an applicant's observations (via CCF), the General Secretariat and the NCB involved would reconsider the validity of the notification - sometimes proceeding to cancel it on their own initiative. This step is now formalized and integrated into the procedure. However, if the General Secretariat maintains the notification, the CCF will still take a decision, with all the powers conferred on it by the rules.

New developments in deadlines and communications:

Another relevant improvement is in the management of deadlines and communications with the parties. Previously, the CCF tried to decide requests for deletion within an indicative nine months (a deadline that was not always met due to work overload). With the 2025 reforms, a new deadline has not been explicitly announced, but it is expected that, thanks to the increase in resources and staff, response times will be shortened. It should be recalled that in 2024 the General Assembly already took an important step forward by doubling the remuneration and working time available to CCF members (from 26 to 80 days per year per member, and up to 125 days for the president).[20], The CCF is also working with the INTERPOL General Secretariat to develop new technological tools to speed up the processing of cases, recognizing the need for almost full-time dedication to reduce the backlog. In addition, the INTERPOL General Secretariat is working with the CCF to develop new technological tools to expedite the processing of cases.[21][22].

Regarding communications, the current practice -which will be maintained and reinforced- is that the CCF keep both the applicant (or his/her legal representative) and the source NCB informed throughout the process. Article 31 of the Bylaws provides that the Chamber of Applications shall be the single point of contact with the applicant throughout the procedure[23], The company must acknowledge receipt of the request, provide information on admissibility and the applicable procedure, including notification of the date on which the case will be examined and the deadline for submitting additional arguments.[24][25]. The new guidelines emphasize the importance of these notifications. In fact, a notable practical change is the attention to the legal representativeWhen the applicant acts through an attorney, the CCF ensures that communications are addressed to the attorney, provided that the corresponding power of attorney has been submitted.[26]. In the past, there were situations of confusion due to lack of formal recognition of the representative; today, with the rules clarified, it is essential to attach a notarized authorization from the client so that the lawyer receives directly all notifications.[27]. In this way, the client has a unified and professional means of communication with the CCF, which results in a more effective defense.

Another innovative aspect of the reform is the introduction of provisions for prevent abuse of procedures of the CCF. The new wording of Article 28 of the Statute expressly empowers the Chamber of Applications to take action against abusive, improper or bad faith conduct, whether by the applicant (or its representative) or by the NCB that is the source of the data. For example, the CCF may reject in limine a manifestly abusive or unfounded request, or even a manifestly abusive or unfounded report misbehavior (a) to report such acts - such as attempts at coercion or reprisals - to the relevant INTERPOL bodies and even to external authorities, if such acts could constitute punishable offences[28][29]. This measure protects the integrity of the system: on the one hand, it discourages possible “chronic recurrent” The CCF will have to apply these powers with balance, giving reasons when it decides to reject for abuse and -as some observers have suggested- offering some avenue for clarification or internal appeal to avoid mistakes. Of course, the CCF will have to apply these powers with balance, giving reasons when it decides to reject for abuse and -as some observers have suggested- offering some means of clarification or internal appeal to avoid mistakes.[30]. In any case, from the defense attorney's point of view, the quality of the applications must be at the highest level, The CCF will scrutinize its admissibility and purpose more rigorously. A well-founded and genuine request should not be afraid of these provisions (which are aimed at twisted uses of the mechanism), but it is advisable to refrain from delaying tactics or lazy allegations that could now lead to an early closure of the case.

Practical Effects of the Reforms: Defense Lawyer's Perspective

From the point of view of specialized legal defense in INTERPOL matters such as VENFORT LAWYERS, these 2025 regulatory and procedural changes have the following objectives important implications for strategy and advice to customers:

• Early and preventive interventionThe usefulness of taking action is reinforced formerly before trouble breaks out. For businessmen, senior executives or political opponents who suspect that their government or another actor might request a red notice against them, now more than ever it is advisable to file a preventive application with the CCF. While this does not automatically “block” the issuance of the notice, it does put INTERPOL on notice. The General Secretariat will have advance notice of the objections (e.g., the existence of political asylum or the lack of due process in the requesting country) and should exercise the utmost care in reviewing any future dissemination or notification requests[6]. Practice shows that many abusive notices can be neutralized at the screening stage if INTERPOL has clear information in time. Our practical advice is to collect and present, through a lawyer, any evidence of political motivation, lack of due process, torture in the country of origin, etc., in a dossier clear and concise preventive[31]. This preventive measure can make the difference between a quiet life and a surprise arrest at an airport stopover.
• Importance of specialized and well-documented advocacyWith the utmost formality of the Secretary General's role in the handling of complaints, the file submitted to the CCF will be analyzed at two levelsThe first step is to have the request deleted by INTERPOL's bodies (which will look to see if the notice is in breach of INTERPOL's rules) and then, if the dispute persists, by the Commission independently. It is therefore essential that the initial request for deletion of data be technically well-founded in INTERPOL's rules (Data Processing Rules, INTERPOL Constitution, applicable resolutions) and accompanied by solid evidentiary documentation. A lawyer with experience in INTERPOL cases will be able to correctly invoke, for example, a violation of Article 3 (political persecution) or Article 2 (human rights) of the INTERPOL Constitution, and provide case law from the CCF itself to support the request. The quality of the initial argumentation could even lead the General Secretariat to resolve the matter in favor of the applicant without the need to exhaust the process, saving precious time for our client.
• New deadlines and active follow-upAlthough the reforms seek to streamline procedures, we must be realistic: the CCF still faces hundreds of complex cases per year and some backlogs persist. However, with more working days allocated to its members and more support staff since 2024[20], As lawyers, a progressive improvement is expected. As lawyers, we must proactively accompany the fileThe CCF, in accordance with its rules, will report on the status of the application at the request of a party[32], including the estimated test date and any relevant developments.[32]. The legal representative should therefore keep in respectful but constant contact with the CCF Secretariat, in order to be aware of deadlines, respond promptly to requests for additional information and know whether the General Secretariat has already formulated its compliance report. This close monitoring gives the customer peace of mind and makes it possible to react in the event of any incident (e.g. if the NCB provides new data requiring a counter-reply).
• Provisional measures in urgent casesFortunately, the CCF retains the power to recommend or decide to temporarily suspend a notification pending consideration of the merits, when the situation warrants it (e.g., if the individual is in detention pending extradition). However, experience shows that the CCF rarely grants precautionary measures, except in very extreme and well-documented cases. The new rules have not (for the time being) introduced an express procedure for the requestor to request formally these emergency measures - everything is left to the initiative of the CCF according to article 37-.[33]. Therefore, it is the lawyer's responsibility to urgently need to highlight in its initial request any critical circumstances (ongoing detention, imminent risk of extradition, peremptory timeframe of an extradition trial) and explicitly ask the CCF to consider an extradition request. “interim measure”. Although the CCF is not obliged to grant it, leaving the request in writing creates awareness of the seriousness of the matter. It is worth citing good practices from other fora (UN Committee against Torture, European Court of Human Rights with its Article 39 measures) as a guide to the necessary promptness[34][35]. In short, in a case of life or death for the client, we will not hesitate to exhaust all avenues: simultaneous defense in national courts, precautionary measures in international human rights courts, and this urgent request to INTERPOL, in a coordinated manner.
• Acknowledgement of the legal representative and confidentialityThe reforms strengthen the lawyer's position in the procedure. It is essential to make sure to comply with the formal requirements when filing the complaint: a power of attorney signed by the applicant authorizing representation before the CCF must be attached, as well as a copy of an identity document.[36][27]. The lack of these elements can lead to delays or communication being made directly with the individual (which could be problematic if the individual changes address or does not speak the working language). With documentation in place, the CCF will direct all notifications to the legally constituted representative - ensuring smooth and professional communication. In addition, the CCF's confidentiality rules remain in place: the application dossier not shared in police bases and with other countries indiscriminately.[37][38], so that the customer can act without fear of reprisals for the simple fact of having resorted to (in fact, should any country attempt to retaliate against the requesting country for approaching the CCF, such an act could be reported by the CCF as a serious irregularity under the new powers of Art. 28). In summary, the client can and should assert his rights at INTERPOL with the support of his lawyer, knowing that the procedure is confidential and legally oriented.
• Effective execution of decisionsOne reassuring point is to confirm to our clients that when the CCF decides in their favor (whether by ordering the removal of a red notice, the rectification of inaccurate data, or the lifting of a notice), INTERPOL will complies decision. The General Secretariat is obliged to immediately implement the decision.[12], The CCF itself verifies this by notifying both the applicant and the NCB that the data has been deleted or corrected in the system. With the new 2025 guidelines, not only is this effectiveness maintained, but it also underscores the binding purpose of decisionsThe Assembly Resolution reaffirms that the decisions of the CCF are final and must ensure the conformity of the data with the standards.[2]. In case of non-compliance or anomalous delays in implementation, the matter could be escalated to INTERPOL governance, although this is rarely necessary. In practice, we have observed that once INTERPOL declares a notice “non-compliant”, NCBs comply and desist from reintroducing the same information, as they know it would be vetoed again - especially now that systems are in place to detect attempts to “reinsertion” of previously deleted data. However, as lawyers, we are vigilant that there is no further surprisesIf a country insists with slight variations on a red notice request that has already been cancelled, we are prepared to take action again, and even to submit an additional preventive application to make clear to INTERPOL the risk of recidivism.

Practical Recommendations for VENFORT ABOGADOS' Clients

1. Have specialized advice in advance: If you or your company senses that you may become the target of a red notice (e.g., following the outbreak of a trade dispute, a change of political regime or any sign of persecution), consult INTERPOL's specialist lawyers immediately. A well-planned preventive strategy - eventually including a preventive application to the CCF - can save enormous future setbacks.

2. Gather evidence of possible abuse: Document any evidence of political motivation, rights violations or lack of safeguards in your case. International court decisions, political asylum granted, NGO reports on your country, anything can be useful. This evidence will form the basis of a solid request to INTERPOL, whether preventive or reactive.

3. Act quickly on a red notice: If you discover that a red alert exists or dissemination against you (e.g., you are detained or prevented from traveling), do not delay in activating your defense. Filing an access request and subsequent deletion request with the CCF as soon as possible is crucial, as even with the 2025 enhancements, the process can take months. In parallel, make sure your lawyer arranges for domestic judicial measures (habeas corpus, extradition control) to buy time while INTERPOL resolves.

4. Comply with the formal requirements: When you initiate a procedure before the CCF, follow the instructions to the letter. Complete the official INTERPOL form (available in Spanish) and attach the required documents: signed power of attorney, copy of identification, and a clear summary of your allegations with your evidence.[36]. An orderly and complete dossier avoids inadmissibility due to technical issues and conveys seriousness.

5. Confidentiality and secure communication: Please note that your application to the CCF is confidential; your personal information is not disclosed to all police forces. For this reason, be frank and detailed in the information provided to INTERPOL, without fear of it getting into the wrong hands.[37]. Also, appoint a trusted legal representative and provide him or her with all means of contact. All communications from INTERPOL will reach your attorney, ensuring that no important notices are missed during the process.

6. Do not abuse the mechanism: New guidelines empower CCF to screen and sanction malicious uses of its procedures[28]. Therefore, avoid aggressive or “saturation fire” strategies” (e.g., submitting multiple repetitive requests or unsubstantiated allegations). It is best to focus your arguments on a well-argued request with truthful evidence. If in the course of the proceedings you obtain new relevant information, your lawyer can provide it in a timely manner - the CCF will accept additional information and forward it to the General Secretariat if appropriate.[31]-but always within a coherent line of defense. Seriousness and good faith are your best allies in gaining credibility with INTERPOL.

7. Rely on professional expertise: Finally, dealing with a Red Notice requires navigating both international legal rules and INTERPOL's internal administrative procedures. Each case is nuanced (whether it is an international trade dispute, a political rivalry, or a questionable criminal charge). Having lawyers accustomed to dealing with INTERPOL and the CCF makes the difference. At VENFORT Lawyers, We have become a reference in the area by having a team dedicated to INTERPOL affairs that constantly monitors these reforms and has developed protocols for action in light of the new 2025 guidelines. Do not face alone such a specialized mechanismLet experts who know how to persuade INTERPOL, protect your reputation and safeguard your freedom of movement guide you.

In conclusion, the 2025 reforms at INTERPOL represent an effort to modernize and balance the system of international notifications: more effectiveness against crime is sought, but also greater controls to prevent abuses and protect individual rights. For potential applicants - businessmen, wealthy families, public figures or any high-profile individual vulnerable to fabricated accusations - these developments are good news. However, taking full advantage of the new guidelines and avenues of recourse requires specialized knowledge. A well-thought-out preventive defense and a swift and technical reaction to any red notice are essential. With the right legal assistance, it is possible to navigate INTERPOL's maze and neutralize unfair alerts, preserving both the client's freedom of movement and international good name. As we always say in our firm: “Interpol is not lawless territory: with strategy and rigor, the balance can be tipped in favor of justice.”.

Sources consultedINTERPOL General Assembly Resolutions[1][3]; Updated INTERPOL Constitution and Rules[5][6][12]; Activity Report CCF 2023[4]; Official CCF website (Frequently Asked Questions and Applicant's Guide)[36][9]; Resolution AG-2024 on Strengthening of the CCF[20]; MENA Rights Group, “INTERPOL's new draft amendments to the CCF Statute...” (2025)[15][28]. All quotations are from official and public documents, which we recommend reading for further details.

Aldana Aldana.