Under the leadership of its current Chairman,  Vitalie Pirlog, the Commission for the Control of INTERPOL’s Files (“CCF”) has proven in this year’s decisions that it is serious about holding National Central Bureaus to their obligations under INTERPOL’s rules.

In his speech at this year’s General Assembly, Chairman Pirlog reminded INTERPOL’s membership that the CCF often seeks information from their National Central Bureaus (“NCBs”). These responses are essential to the CCF’s ability to make decisions about requests for removal of Red Notices from the requesting country. Mr. Pirlog reminded member countries that timely responses were particularly important, given the CCF’s new statute that generally requires a response to be issued within four to nine months.

INTERPOL has always provided the required assistance to its members’ NCBs, but historically, the NCBs have not always been strictly observant of their duties to provided requested information, or to provide it timely. The CCF has apparently had enough of that, and is holding the members countries’ NCB’s feet to the fire.

Based on the CCF’s decision letters that have been received by this practitioner, it is clear that:

• The CCF is generally adhering to the new time limitations for issuing decisions, with some decisions being issued even earlier than required;
• The CCF is demanding cooperation from National Central Bureaus, and when they do not respond in a timely fashion, the CCF is proceeding to make a decision based on the information it has, rather than waiting or continuing the matter until the NCB provides a full response; and
•  The decisions being issued by the CCF are generally accompanied by a reasoned explanation, detailing the Commission’s steps and considerations taken in reaching its decision.

These factors are critical to the CCF’s efforts at demonstrating transparency, and allow applicants to both appreciate the nature of the process, as well as to recognize that they were given a “fair shake” in INTERPOL’s processes. One would hope that the more lax NCBs recognize the shift in culture at the CCF, and become more compliant as a result. Whether they do or not, the CCF will benefit from the fact that it is protecting INTERPOL’s interests in transparency and the furtherance of human rights.

As always, thoughts and comments are welcomed.