The Interpol silver notice: the pilot project in the fight against international money laundering

Andrea Puccio
Puccio Penalisti Associati, Milan and Brescia
puccio@pucciopenalisti.it

The Interpol alert system

In recent years, there has been a significant rise in crimes committed by individuals operating internationally. The increasing internalisation of offences makes it all the more necessary to establish effective and consistent mechanisms for cooperation and intervention at a global level.

In this context, Interpol plays a leading role among the international bodies charged with providing operational and informational support to countries around the world.

Interpol is an intergovernmental organisation comprising 196 members, known for the ways in which it operates on a global scale and for its ability to coordinate investigative operations internationally, making use of specific colour-coded alerts, known as ‘notices’. These tools enable its member states to share information and formulate requests for investigative assistance in a timely manner.

The system includes several types of notices, each with specific and well-defined objectives.

The most familiar is certainly the red notice, issued whenever there is a requirement to geolocate and, subsequently, arrest wanted individuals in order for them to stand trial or for them to serve a sentence.

In addition, there are several other types of alerts, such as:

• yellow notices, issued to help locate missing persons, often minors, or to facilitate the identification of persons who are unable to self-identify;
• blue notices, intended to gather information about a person’s identity, location or activities as part of a criminal investigation; and
• green notices, deployed to provide a warning about a person’s criminal activities, where that person is considered a possible threat to public safety.

Recently, however, attention has been focused on a new category of notice that is set to profoundly revolutionise the international investigative paradigm: the silver notice.

Silver notice: characteristics and regulatory framework

Starting from 2025, Interpol has a new innovative instrument for combatting transnational crime: the silver notice and its related dissemination system.

The initiative, currently being piloted through the use of a trial programme involving 52 countries and territories, is specifically designed to support authorities in the detection, identification and tracking of assets linked to criminal activity.

The silver notice forms part of Interpol’s colour-coded notice and diffusion system but incorporates an element of absolute novelty: for the first time, the investigative focus is not directly on the individual, but rather on the assets that can be linked to them and that are deemed to be of illicit origin. This paradigm shift reflects the evolution of modern criminal strategies, characterised by increasingly sophisticated techniques for concealing and laundering illicit gains.

The regulatory framework: guarantees and principles

The operational features of the silver notice are outlined in the document entitled ‘The legal framework governing the 2025 silver notice/silver diffusion pilot’,[1] published on Interpol’s official website.

The aforementioned document clarifies, at the outset, that the silver notice/silver diffusion must be employed in full compliance with the fundamental rules governing the organisation’s operation. Specifically, the use of a silver notice is contingent upon strict adherence to four essential pillars:

• the general principles of impartiality and protection of fundamental rights, which require Interpol to operate in accordance with international human rights standards and the prohibition of activities based on political, military, religious or racial grounds;[2]
• the rules governing personal data processing, which provide that any information transmitted through diffusion systems must be relevant, proportionate, up-to-date and processed within specified time limits and for specified purposes;[3]
• compliance with the regulations that specifically govern the issuance and circulation of silver notices/silver diffusions; and
• adherence to the rules governing the work of the Commission for the Control of Interpol’s Files (CCF), ie, Interpol’s Constitution and General Regulations, as previously applied with respect to other categories of notices and diffusions.

Requirements for issuance: when the Silver Notice is triggered

A mere suspicion is not sufficient to activate a silver notice. The legal framework governing the 2025 silver notice/silver diffusion pilot establishes precise and rigorous conditions, as follows:

• the existence of an ongoing criminal investigation against a natural person;
• the allegation of an offence punishable by at least four years’ imprisonment, in accordance with the provisions of the UN Convention Against Transnational Organized Crime; and
• the availability of adequate judicial elements, including a decision confirming that the assets are subject to seizure or confiscation, measures that need not necessarily be predicated upon a conviction.

Furthermore, it is paramount that the connection between the assets under scrutiny and the offence(s) for which the individual is under investigation is specified. More specifically, it is prescribed that silver notices/silver diffusions shall ‘establish the link between the criminal activities and the person and/or the asset(s) derived from the offence(s)’.[4]

Unlike traditional mutual legal assistance treaties (MLATs), silver notices/silver diffusions do not create binding legal obligations.

However, given Interpol’s authority and widespread recognition worldwide, such notices may produce significant practical and substantive impacts. Indeed, their issuance may trigger the freezing or the monitoring of targeted assets at the national level.

After all, this is precisely the reason for the introduction of this new instrument. As specified within the legal framework published by Interpol, a silver notice/silver diffusion may be issued with one of the following purposes:

• locating certain assets;
• identifying the assets with enhanced accuracy;
• acquiring relevant information regarding the assets; and
• monitoring the assets discreetly and constantly.

Early cases: from Italy to India, towards a new investigative paradigm

The inaugural silver notice originated from Italy. In January 2025, pursuant to a request submitted by national authorities, Interpol issued the first notice of this kind to acquire information regarding the existence of assets, both movable and immovable, mainly located in Asia and South America. The operation pertained to money laundering schemes of worldwide magnitude valued at over half a billion euros, marking a historic precedent in the concrete use of this new instrument.

In the following months, other countries participating in the pilot project, including the UK and India, followed the Italian example.

India, in particular, sought the issuance of two silver notices, issued by Interpol in May 2025, targeting the assets (of illicit origin) of two high-profile fugitives.

The first case involved a former French official stationed in New Delhi, charged with extensive fraud relating to the provision of Schengen visas in exchange for the payment of bribes by individual applicants. The illicit proceeds were allegedly invested in the acquisition of real estate in Dubai.

The second case pertained to an alleged fraudster who, claiming to be a Ministry of Finance representative, ostensibly established an unregulated cryptocurrency called MTC, thereby fraudulently gaining the trust of a significant number of investors. Upon obtaining considerable financial resources from the latter, instead of executing the promised investment strategies, he allegedly misappropriated the available funds to undisclosed destinations, bank accounts and properties.

This case underscores a troubling pattern: cryptocurrencies are emerging as a major instrument used for money laundering purposes, with estimates related to the value of illicit activities perpetrated throughout the 2023–2024 biennium involving crypto reaching multiple billions of dollars.

Moreover, the inherent characteristics of virtual currencies make them perfectly suited to criminal abuse.

Their decentralised structure allows for peer-to-peer financial transactions, without necessitating the use of any intermediaries or a centralised system. In these terms, public regulatory bodies and investigating authorities cannot rely on a significant institutional interlocutor with whom to establish and foster cooperative relationships for money laundering prevention and enforcement purposes.

Additionally, the fact that these assets represent ‘dematerialised currency’ enables the execution of transactions from any jurisdiction, with evident implications in terms of traceability.

Furthermore, individuals conducting such operations typically benefit from pseudonymous conditions, thereby preserving their anonymity.

It is consequently unsurprising that, within the EU framework, pursuant to the EU Anti-Money Laundering (AML) Package adopted during 2024, crypto-asset service providers (CASPs) were included in the scope of the newly conceived AML legislation, together with crowdfunding companies.

Future perspective: towards new frontiers in the fight against international money laundering

Given this scenario, the following question arises: will silver notices/silver diffusions genuinely constitute a breakthrough in the struggle against international money laundering?

As is widely recognised, Interpol represents the world’s foremost international police cooperation organisation, underpinned by an extensive and highly strategic global network. The operational mechanisms available to Interpol facilitate expeditious and efficient exchanges of information and coordination activities between member states and domestic police forces.

The introduction of this new category of notice, therefore, holds promises for enhanced success in targeting money laundering activities characterised by their transnational scope and employment of progressively more sophisticated techniques for concealing assets of illicit origin.

With specific regard to the world of cryptocurrencies, it is undisputable that the issuance of a silver notice/silver diffusion will facilitate enhanced intelligence gathering regarding the disposition of designated criminal proceeds, including instances where such assets have been transformed into ‘crypto-assets’.

Indeed, even those countries that, in recent years, have been characterised by the adoption of highly permissive and convenient fiscal regimes regarding digital finance, which are attractive destinations for those who have reinvested their criminal proceeds in cryptocurrencies, given their frequent disinclination to conclude international cooperation agreements, will be forced to provide information when requested.

Moreover, given this situation, it is reasonable to anticipate that the deployment of this innovative instrument will yield advantages for:

• local judicial authorities engaged in managing criminal proceedings constituting the legal basis for silver notices/silver diffusions themselves, if not yet concluded. In these instances, the possibility of getting detailed information on the targeted assets may facilitate the evidential reconstruction of the underlying criminal conduct and, particularly, the money laundering methodologies used by the subject under investigation, elements that will undoubtedly require substantiation at trial; and
• in terms of effectiveness, the other mechanisms presently at Interpol’s disposal. Indeed, it is unquestionable that identifying the country where the criminal proceeds are located will also facilitate the identification of the location where the individual controlling them resides. From this perspective, a beneficial synergy materialises with additional Interpol instruments, in particular with red notices, aimed at identifying and arresting the individual involved.

The expectation is that the first pilot phase will terminate in November 2025. This will be an opportunity for a concrete evaluation of the accomplished outcomes and determination of future trajectories for a new legal instrument that potentially constitutes a watershed moment in transnational crime suppression.

The silver notice stands as a cornerstone element in the evolutionary development of transnational crime countermeasures, holding promise to fill the investigative gaps that have so far constrained the effectiveness of cross-border enforcement actions.

Ultimately, this instrument represents an unprecedented professional challenge: indeed, it constitutes an opportunity for prosecuting authorities to develop more sophisticated and coordinated investigative strategies on a global scale. Moreover, it forces defence teams to deal with increasingly articulated and multilevel proceedings, wherein fundamental rights protection must be ensured within an investigative framework with a strong international dimension.