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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:
- 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.
- 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.
- 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.
- 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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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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Quastels Publishes Strategic Report on India-UK Economic Outlook for 2025
Quastels is pleased to announce the release of India-UK Outlook 2025: A Strategic Report on Bilateral Trade, Investment & Economic Shifts, an in-depth publication authored by Partner and Co-Head of the India Desk, Jayesh Jethwa. The report is designed to guide Indian businesses, private clients, and institutions looking to engage with the UK in a pivotal year for bilateral economic relations.
As the UK recalibrates post-Brexit and India maintains its position as the fastest-growing major economy, this timely report explores how evolving trade agreements, cross-border investments, and regulatory reforms are reshaping opportunities across sectors. It highlights key developments, including the anticipated India-UK Free Trade Agreement (FTA), projected to unlock billions in trade and investment.
Covering macroeconomic trends, sector-specific insights, and strategic considerations, the report is a valuable resource for Indian corporates, UHNWIs, and family offices navigating real estate, fintech, infrastructure, and professional services across the corridor.
Clients are invited to download the full report on India-UK economic outlook, or contact our India Desk for tailored guidance on leveraging new opportunities in 2025 and beyond.
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