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INTERPOL’s Silver Notices and India’s Crypto Crackdown: Legal Implications for Cross Border Asset Recovery

In a development of growing significance to cross border legal practitioners and asset protection advisors, INTERPOL has introduced a new category of international alert: the Silver Notice. This tool, designed to trace and recover criminal assets globally, represents a material evolution in the architecture of international law enforcement. In May 2025, India issued its first ever Silver Notices, applying the mechanism in two high value crypto fraud cases. The move signals a more assertive posture by Indian authorities and underscores a broader trend of convergence between asset recovery, financial regulation, and cross border policing.

What Is An INTERPOL Silver Notice?

Launched in January 2025, the Silver Notice is INTERPOL‘s latest alert mechanism, joining its suite of colour coded notices such as the Red (wanted persons) and Blue (location of suspects). Uniquely, the Silver Notice is designed not to locate individuals, but to trace proceeds of crime, including real estate, corporate interests, financial accounts, and digital assets such as cryptocurrency wallets and NFTs.

The mechanism operates under INTERPOL Rules on the Processing of Data (RPD) and is primarily used to facilitate international cooperation in asset identification and restraint, often preceding mutual legal assistance requests or asset seizure applications in local courts.

India’s First Silver Notice: A Strategic Shift

As part of a pilot involving 51 participating countries, India has deployed its first ever Silver Notices in the following two matters:

Shubham Shokeen

A former visa officer at the French Embassy in Delhi, accused of issuing Schengen visas in exchange for bribes ranging from  ₹15 lakh to ₹45 lakh per applicant. The proceeds were allegedly used to purchase luxury property in Dubai valued at 15.7 crore. India had earlier issued a Blue Notice to locate Mr Shokeen; the Silver Notice now aims to trace and recover his Dubai assets.

Amit Lakhanpal

The founder of a fraudulent cryptocurrency scheme, MTC, which raised ₹113 crore from investors without regulatory approval. Lakhanpal is accused of impersonating a senior government official and misappropriating funds internationally. A Red Notice was previously issued against him; the new Silver Notice targets the recovery of assets generated by the scam.

The significance of these notices cannot be overstated. This is not only India’s first deployment of this enforcement tool, it is also one of the first globally, placing India at the forefront of INTERPOL’s new asset recovery regime.

Legal Analysis: Implications for the UK and Cross Border Practice

For clients and advisers with international exposure, particularly those operating in digital finance or holding property abroad, Silver Notices introduce a new category of legal risk. From a UK legal standpoint, several key frameworks come into focus:

1. Proceeds of Crime Act 2002 (POCA) and Civil Recovery. Under Part 5 of POCA, UK enforcement agencies such as NCA or HMRC can initiate civil recovery proceedings based on foreign intelligence, including INTERPOL notices. A Silver Notice involving assets in the UK could prompt an Account Freezing Order (AFO) or Property Freezing Order (PFO), even in the absence of domestic criminal proceedings.
2. Economic Crime and Corporate Transparency Act. Recent amendments under this legislation have strengthened the ability of UK agencies to seize and convert crypto assets linked to criminal activity. These powers can be exercised on the basis of intelligence from foreign jurisdictions, including INTERPOL alerts, if properly supported by evidence.
3. Mutual Legal Assistance and Bilateral Agreements. The UK India Mutual Legal Assistance Treaty (MLAT) and provisions under the Crime (International Co operation) Act 2003 permit cooperation in tracing and seizing assets, even where those assets are held by nominee structures, SPVs, or in anonymised digital wallets. A Silver Notice can serve as a basis for initiating such cooperation.
4. Due Process and Abuse Safeguards. Silver Notices do not currently undergo the same scrutiny as Red Notices, but clients subject to one may experience reputational harm, banking restrictions, or immigration complications. There remains the possibility of challenging such notices before INTERPOL’s Commission for the Control of Files (CCF) on grounds such as procedural fairness, abuse of process, or violation of due process norms.

Strategic Guidance for Clients and Institutions

The emergence of Silver Notices has direct implications for:

• Private clients with cross border wealth structures
• Crypto asset holders, including early investors and exchangers
• Family offices managing international portfolios
• Banks and fiduciaries with KYC and PEP screening obligations

At Quastels, we advise clients facing complex international scrutiny and enforcement risks, including INTERPOL alerts, crypto seizures, and asset protection matters. Our multi-disciplinary approach spans immigration, international protection, and cross border support.

Conclusion

The deployment of Silver Notices marks a pivotal shift in the global enforcement landscape, signalling that suspected financial crime, particularly involving digital assets, will increasingly be met with proactive, internationally coordinated responses. For individuals and institutions with cross border exposure, the focus is no longer solely on personal liability but on the traceability and recovery of assets, wherever they are held.

At Quastels, we are uniquely positioned to guide clients through this complex terrain, combining technical expertise in international protection, and immigration with a strategic understanding of international enforcement trends.

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Youth Is No Exception: The Importance Of Wills

The unexpected and tragic passing of Liam Payne in October 2024 has brought to light the critical importance of estate planning and wills. 

The former One Direction star died without leaving a valid will, leaving his £24.3 million estate to be managed under UK intestacy laws. This situation raises the potential complications and unintended consequences that can arise when individuals, regardless of their wealth, status or age, fail to put in place proper arrangements.

The Consequences of Dying Intestate

In the UK, when someone dies without a will, their estate is distributed according to the rules of intestacy. These rules prioritise spouses, civil partners, and direct descendants, but they do not account for cohabiting partners, stepchildren, or close friends. In Payne’s case, his entire estate is set to be inherited by his eight-year-old son, Bear. However, as a minor, Bear cannot manage the estate himself, leading to the appointment of his mother, Cheryl Tweedy, and a music lawyer as administrators to oversee the estate until Bear reaches the age of 18.

This arrangement, while legally sound, may not reflect Payne’s personal wishes. Without a will, there’s no formal record of how he intended his assets to be distributed, potentially leading to family disputes or legal challenges. In addition, the absence of a will means that specific bequests to friends, charities, or other individuals cannot be honoured, regardless of any verbal intentions or informal agreements.

Inheritance Tax Implications

One of the significant drawbacks of dying intestate is the potential for increased Inheritance Tax (IHT) liabilities. In the UK, estates exceeding the nil-rate band of £325,000 are subject to a 40% IHT on the amount above this threshold. While there are allowances, such as the residence nil-rate band, which can increase the threshold to £500,000 when passing the family home to direct descendants, these benefits may not be fully utilised without proper estate planning.

A well-drafted will can incorporate strategies to mitigate IHT.  For instance, leaving at least 10% of the estate to charity can reduce the IHT rate on the remaining estate from 40% to 36%. Without a will, these opportunities for tax efficiency are often missed, potentially reducing the value of the inheritance passed on to beneficiaries.

The Importance of a Will in Succession Planning

Beyond tax considerations, a will is a fundamental tool for succession planning. It allows individuals to:

• Appoint Executors: Designate trusted individuals to manage the estate, ensuring that assets are distributed according to the deceased’s wishes.
• Assign Guardians: Specify who will care for minor children, providing clarity and security for their future. 
• Detail Specific Bequests: Allocate particular assets or sums of money to friends, relatives, or charities, ensuring that personal relationships and philanthropic intentions are honoured.
• Establish Trusts: Create trusts to manage assets for beneficiaries who may not be ready or able to handle large inheritances, such as minors or individuals with disabilities.

In Payne’s situation, the lack of a will means that these critical decisions are left to the courts and administrators, which may not align with his personal preferences.

The Risks of Inheriting Too Young 

Whilst Bear is still a minor, his inheritance will be held on a statutory trust until he turns 18. At that age, Bear would gain full and unrestricted control over the entire estate, regardless of his financial maturity or readiness. This creates a considerable risk that the wealth could be mismanaged, lost, or attract unwanted influence. 

Proper estate planning could have mitigated these risks through the creation of a discretionary trust, allowing appointed trustees to manage and distribute funds according to Bear’s needs and maturity level over time, rather than handing over multi-millions at a legally but not necessarily developmentally appropriate age. This approach not only protects the estate but also supports the long-term well-being of the beneficiary. 

Potential Claims Under the 1975 Act

One further complication in cases of intestacy, especially among the wealthy and high-profile, is the increased likelihood of litigation. Under the Inheritance (Provision for Family and Dependants) Act 1975 (the 1975 Act), certain individuals can bring a claim against the estate if they believe that the distribution under intestacy (or even under a valid Will) does not make “reasonable financial provision” for them.

Eligible claimants include spouses, former spouses who have not remarried, cohabitees who lived with the deceased for at least two years, children, and individuals being maintained, wholly or partly, by the deceased immediately before their death. 

If Payne had individuals financially dependent on him who are not adequately provided for under intestacy, they may have grounds to bring a claim. 

While the 1975 Act can offer a safety net in certain circumstances, litigation is expensive, time-consuming, and emotionally fraught. It also places a public spotlight on the deceased’s personal affairs – something most would wish to avoid. A valid, well-drafted Will is the simplest way to reduce the risk of such disputes and ensure clarity for all involved.

Key Takeaways

Liam Payne’s intestacy serves as a poignant reminder of the importance of proactive estate planning. Regardless of age or wealth, creating a will ensures that your assets are distributed according to your wishes, minimises potential tax liabilities, and provides clarity and security for your loved ones. 

While the topic of wills and estate planning may seem premature, especially for young individuals, taking the time to address these matters is a responsible and caring act that can prevent unnecessary complications and provide peace of mind for both you and your family.

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Quastels’ India Desk Visits Mumbai for Exclusive Berkeley Group Event

Quastels is pleased to announce that our Partners and Heads of the India Desk, Jayesh Jethwa and Meera Malde, will be travelling to Mumbai to attend an exclusive event hosted by Source Investments and The Berkeley Group. The event will take place at the JW Marriott in Juhu, Mumbai, on 12th April.

This prestigious gathering will focus on the Oval Village development at the iconic Oval Cricket Ground, London. Jayesh and Meera will be leading discussions on the process of purchasing property in the UK and navigating the UK immigration system. The event aims to provide valuable insights to individuals considering investment opportunities in the UK, particularly in the thriving property market.

​Meet the event hosts

Source Investments is a distinguished UK property investment firm specialising in building high-performing buy-to-let portfolios with over £120 million in property investments across 25+ locations. They offer an end-to-end service encompassing sourcing, financing, and management. 

The Berkeley Group, one of the UK’s most renowned property developers, is known for creating exceptional homes and communities in London, Birmingham, and the South of England. Their commitment to quality and sustainability has established them as a leader in the property sector. The Oval Village development, situated at the Oval Cricket Ground, represents an exciting blend of luxury living and iconic location, making it a standout investment opportunity.

Quastels Involvement

Jayesh and Meera’s involvement at this event reflects Quastels’ commitment to fostering strong connections within the Indian business community and providing specialist advice on UK property transactions and immigration processes. As experts in these fields, they are well-placed to guide attendees through the legal complexities of acquiring UK real estate.

Quastels continues to strengthen its global outreach, and this event marks another step in building meaningful relationships between the UK and Indian business communities. We look forward to an engaging and insightful event and to meeting our clients and contacts in Mumbai.

Get in touch

For more information about the event or the services we offer, please get in touch with our India Desk team.

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