INTERPOL’s “Rules on the Processing of Data” (RPD) are second in importance only to its Constitution, as the RPD set out how INTERPOL interprets the requirements of its Constitution in practice. RPD violations are frequently utilized by targets of Red Notices and their attorneys to request the deletion of abusive or improper requests for cooperation. The RPD are also subject to frequent revision, having been amended four times (2014, 2016, 2019, and 2023) since their adoption in 2011.

                On September 17, 2024, the Swiss Financial Market Supervisory Authority released a statement that in enforcement proceedings it found that Mirabaud & Cie SA (Mirabaud), a Swiss bank, breached its anti-money laundering obligations and seriously violated Swiss financial services law.  FINMA forfeited CHF 12.7 million in unlawfully generated profits and ordered Mirabaud not to accept any new clients with increased money laundering risks until it has restored compliance.  FINMA has ordered additional prevention measures.[1]

             On September 13, 2024, the United States Department of Justice (DOJ) announced the indictment of film producer Nigel Sinclair and Australian accountant Anthony Stewart for their alleged participation in a multi-decade conspiracy to conceal Sinclair’s income and assets offshore.[1] The tax loss was said to be $5 million.[2]

              On September 5, 2024, the Council of Europe (CoE) opened for signature the Framework Convention on Artificial Intelligence and Human Rights, Democracy and the Rule of Law.[1] Given how hotly artificial intelligence (AI) has been discussed over the last several years, it should not come as a surprise that the CoE resolved to prepare a treaty on how AI should be compliant with its three principal areas of activity, namely human rights, democracy and the rule of law. After all, for many decades now CoE treaties have always been at the forefront of international legal developments (suffice to mention insider dealing, money laundering, financing of terrorism, and trafficking in human beings). The purpose of this short article is to offer an overview of the Convention, which in Article 2 defines AI systems as ‘a machine-based system that, for explicit or implicit objectives, infers, from the input it receives, how to generate outputs such as predictions, content, recommendations or decisions that may influence physical or virtual environments.’

              It is settled law that a refusal to extradite is not in itself a basis for the deletion of a Red Notice or diffusion from INTERPOL’s files.  In 1984, the INTERPOL General Assembly resolved: “[I]f certain countries refuse extradition, this is reported to the other NCBs in an addendum to the original notice.” [1]  The Commission for the Control of INTERPOL’s Files has been applying this rule while adjudicating individual cases, repeatedly reminding us that a refusal to extradite does not per se lead to the deletion of a government request from the Organization’s databases: “[the] mere fact that one of INTERPOL’s Member countries has denied the extradition of an individual subject to a Red Notice does not, in itself, directly affect the compliance of the corresponding data registered in INTERPOL’s files.”[2]  However, the role of a refusal to extradite is not always limited to a mere addendum to a government request that otherwise continues to linger in the Organization’s databases. 

                 On September 5, 2024, the U.S. Department unsealed two indictments charging Dimitri Simes, 76, and Anastasia Simes, 55, both of Huntly, Virginia, and Russia with two separate schemes to violate U.S. sanctions.[1]

                 On September 4, the Department of Justice (DOJ) filed an affidavit for the seizure of 32 internet domains allegedly used by the Russian government to interfere with U.S. and foreign elections. The election interference campaign, known as “Doppelganger,” includes various Russian companies working under the discretion of Russia’s Presidential Administration to spread Russian propaganda to sway voters in different countries, increase pro-Russia support, and minimize countries’ support for Ukraine.[1]

          Two Columbian soldiers, José Medina, and Alejandro Ante, who had allegedly fought for Ukraine, have been deported to Moscow by Venezuelan authorities.  Russia claims that the two men functioned as mercenaries for Ukraine over a span of eight-to-ten months, and the government recently aired a video of the two men being interrogated on its state television.

         On August 23, 2024, a U.K. court published a ruling in which a judge dismissed Michael Lomas’s attempt to delay his extradition to South Africa. This ruling was made despite Lomas’ attorneys' argument that Lomas had serious mental health concerns and suicidal tendencies.

        On August 27, 2024, Nordea Bank accepted a $35 million civil penalty from a top regulator in New York state for its role in the Panama Papers scandal.  The Finland-based bank was accused of improperly policing its accounts and aiding money laundering operations – among other criminal activities -- in the process.