INTERPOL - Silver Notice

June 2025

Author: KW KRUK AND PARTNERS LAW FIRM

At the beginning of 2025, the International Criminal Police Organization (INTERPOL) launched a pilot initiative known as the “Silver Notice.” Initially scheduled to run until November of the current year, the program has already been extended through the end of 2026 due to its promising results and anticipated future developments. The pilot involves 52 of INTERPOL’s 196 member countries, with additional states expressing interest in joining the initiative.

INTERPOL - Silver Notice

The “Silver Notice,” established by INTERPOL, is designed to enhance the identification, tracing, and recovery of assets derived from criminal activity. It may also be used effectively for the discreet and continuous monitoring of such assets. These objectives are pursued through the increased exchange of information and the development of new legal and operational instruments. The information thus obtained facilitates the submission of bilateral requests for the freezing, confiscation, or restitution of assets located within the territories of other member states. Participants in the pilot phase may request the issuance of up to 500 Silver Notices; however, this quota is not distributed equally among states. Only countries participating in the pilot phase are authorized to initiate asset verification inquiries. Nevertheless, all INTERPOL member states are obliged to carry out appropriate verification actions upon receipt of a request.

The concept of the Silver Notice was first introduced in 2015 during INTERPOL’s 84th General Assembly. At that time, it was estimated that only 3–5% of global illicit financial flows were effectively intercepted. This highlighted an urgent need for the development of a new mechanism aimed at facilitating the tracking and recovery of assets derived from criminal conduct. The project was temporarily suspended until 2022, at which time INTERPOL established a dedicated expert group tasked with formulating optimal solutions for the exchange of financial intelligence and for the tracing and recovery of criminal assets. A breakthrough occurred between November and December 2023, during the 91st session of the INTERPOL General Assembly held in Vienna, where, by virtue of Resolution GA-2023-91-RES-11, the implementation of the Silver Notice was formally approved.

In May 2024, INTERPOL, together with the Financial Action Task Force (FATF), issued a joint statement underscoring the imperative for member states to intensify efforts to combat the substantial illicit profits generated by transnational organized crime.

The first documented application of a Silver Notice took place on 10 January 2025, upon the request of the Italian Financial Police (Guardia di Finanza) in relation to a high-ranking member of an Italian mafia organization suspected of hiding in France. Another widely reported instance involved a request submitted by the United Kingdom to determine the location and enable the recovery of assets belonging to the convicted offender Anopkumar Maudhoo. The individual had pleaded guilty to 76 criminal offences, including fraud, money laundering, and possession of false identity documents. The value of the unlawfully obtained proceeds was estimated at GBP 8.5 million.

The Republic of Poland was among the first 52 states to engage in the pilot program for the implementation of the Silver Notice.

To date, Poland has issued four Silver Notices, all related to fraud schemes based on a financial pyramid model. In the largest case, the value of the transferred assets is estimated at approximately PLN 900 million, with over 40,000 individuals identified as victims.

Concurrently, Poland received 17 Silver Notices. These primarily concerned property-related fraud, value-added tax (VAT) fraud, smuggling of gold and narcotics, as well as the laundering of proceeds derived from criminal activity. Requests in these matters were submitted by countries including Italy, Brazil, Belgium, and Sweden.

According to the current framework, each state participating in the training component of the program may nominate up to ten cases in which the identification of assets belonging to individuals suspected or accused of criminal offences is deemed necessary. Within the structure of the Polish Police, the authority to utilize Silver Notices is vested in specific units, notably the Central Bureau for Combating Cybercrime, the Central Bureau of Investigation, and Provincial Police Commanders. Equivalent authority is also held by the Central Anti-Corruption Bureau and the Internal Security Agency.