Is the new INTERPOL Silver Notice a step in the right direction?

I welcome the introduction of INTERPOL’s newly-launched Silver Notice initiative, the latest addition to the organisation’s suite of colour-coded Notices and Diffusions.

Intended to frustrate those engaged in the concealment and movement of criminal assets, the new Silver Notice enables countries to share alerts and requests for information worldwide. It’s being launched as part of a pilot phase involving 52 countries and territories, and will run at least until November this year.

The Silver Notice seeks to address a long-standing gap in global asset recovery: the lack of a unified and efficient framework for sharing intelligence about illicit financial flows. This lack of conduits is not unique to law enforcement, but law enforcement seems to suffer more frequently from choke points, probably due to the red tape and diplomatic restrictions that blight international investigations.

By allowing countries to issue notices specific to criminal assets, INTERPOL has introduced a tool that could significantly enhance cross-border asset tracing and recovery efforts.

Public-private partnerships

Those who practice in the often complex and dynamic area of asset recovery know that success requires a holistic approach: meaning that law enforcement agencies, for example, can benefit from the insights and expertise of the private sector.

According to publicly available information, the experts who shaped the Silver Notice system seem to have overwhelmingly come from law enforcement backgrounds. 

While law enforcement agencies are undoubtedly central to the fight against financial crime, excluding private-sector expertise may inadvertently undermine any initiative’s potential effectiveness.

I do not know if INTERPOL has sought any input from the private sector, but I can only speak for myself when I say that I am confident that many of my friends and colleagues would give up their time for free if we were approached to share our knowledge and experience. 

I see this as two-way street: none of us have all the answers, and sharing knowledge and expertise across the public-private divide seems to make sense. Professionals in our field have spent decades navigating the complexities of asset recovery in civil, criminal and hybrid cases.

We are intimately familiar with the sophisticated methods employed by individuals and entities to hide assets, including the use of shell companies, offshore structures and via digital currencies.

Joined-up thinking

A siloed strategy when formulating major international policing initiatives risks perpetuating what can be a disparate approach to asset recovery. Especially given the increasingly complex and globalised nature of financial crime.

Asset recovery today demands more than traditional investigative techniques. It requires innovative thinking and interdisciplinary collaboration.

I believe that private-sector involvement to bear in the development of initiatives such as the new Silver Notice will not only bring fresh perspectives, but could also foster stronger partnerships between law enforcement and the broader asset recovery community (of which I am part).

These experts could assist in training law enforcement personnel, helping them approach cases slightly differently, imparting better understanding of the mechanisms and tools used in modern asset concealment.

Law enforcement can leverage the full spectrum of knowledge and experience available in the private sector, if it wished: we only need to be asked.