GYH Team Published in International Enforcement Law Reporter (IERL) Vol. 42, Issue 2

INTERPOL Adopts Changes to CCF Statute and Rules on the Data Processing

In a recent analysis in the International Enforcement Law Reporter, Of Counsel Dr. Ted R. Bromund, Of Counsel Charlie Magri, Esq., and Managing Attorney Sandra Grossman examine the amendments adopted at INTERPOL’s November 24–27, 2025 General Assembly in Marrakech. The General Assembly approved changes to both the Rules on the Processing of Data (RPD) and the Statute of the Commission for the Control of INTERPOL’s Files (CCF). While the only RPD amendment—the deletion of Article 94 on Stolen Work of Art Notices—was largely administrative and reflects the creation of a public database, the revisions to the CCF Statute are far more significant.

The amendments to the CCF Statute reshape aspects of the Commission’s authority and procedures. Changes to Articles 3 and 23 clarify the scope of the CCF’s mandate and strengthen confidentiality obligations within the General Secretariat. However, revisions to Article 19 limit the CCF’s access to INTERPOL’s direct messaging system, effectively reducing oversight of millions of annual communications exchanged between member states. Additional changes to Articles 25 and 28 give the CCF expanded authority to address abusive or bad-faith conduct, but they also raise concerns regarding procedural fairness, unclear distinctions between unfounded and abusive requests, and the lack of clearly defined sanctions.

Most consequential are the revisions to Article 33, which formalize the General Secretariat’s role in the early stages of CCF proceedings and require the Commission to wait for the Secretariat’s compliance assessment before acting in certain cases. Although a new 45-day response deadline may help reduce delays, the sequencing requirement risks slowing urgent relief—particularly in detention or extradition cases—and may contribute to prolonged procedural uncertainty. As the authors note, while these reforms reflect INTERPOL’s ongoing institutional evolution, they also highlight continuing concerns about oversight, transparency, and the protection of individuals affected by INTERPOL notices.