INTERPOL's Website and Published Red Notices

more+
less-

I was recently contacted by a representative of a financial watch list compliance organization. He had an interesting question: How valuable is the information in INTERPOL's website? His goal was to determine whether the information on the website was valuable enough to provide to the subscribers to his watch list.

Of course, the determination of the value of information always depends on the intended use of the information. With that in mind, it is important to acknowledge a few facts:

The website does not list all active Red Notices. Only a very small percentage of Red Notices in circulation are actually published on the INTERPOL website. Each country has the discretion to either publish a Notice on the website or to keep the Notice confined to INTERPOL'S databases so that only member country law enforcement officials can view it. The vast majority of the time, the countries choose not to have the Notices published. This point is illustrated in INTERPOL's 2011 Annual report, which showed that 7,678 Red Notices had been issued during 2011. The website, however, listed Red Notices in the hundreds, not thousands, for that year.

Some listed Red Notices are no longer valid. The 2011 Annual Report of the Commission for the Control of INTERPOL's Files ("CCF") contained disturbing information regarding member countries' efforts to provide INTERPOL with updated information regarding active Red Notices. The CCF reported that, in certain situations, National Central Bureaus ("NCBs") generally only rarely informed the General Secretariat when a wanted person had been apprehended and had served his or her sentence. This failure to update INTERPOL results in invalid information remaining active in INTERPOL's databases.

Red Notices sometimes contain inaccurate charge information. Because of the fact that member countries can now upload Red Notices directly into INTERPOL's databases without a quality check being conducted by INTERPOL first, some information is entered invalidly. For example, a person wanted for a traffic-related charge may be listed as being wanted for a fraud charge. This information would naturally, and inaccurately, lead a financial institution to miscalculate the financial risk posed by such a person.

So, back to the question at hand: is the Red Notice subject information on INTERPOL's website of value? The answer is a typical lawyer answer: it depends. If up-to-date, complete, and positively accurate information is needed, then the answer is no. However, if the idea is to provide clients with information that gives them a starting point from which to evaluate the desirability of a given potential customer, with the understanding that clarification and correction may be necessary, then some value may exist.