I-GRIP: Can an INTERPOL Message Lead to the Freezing of a Bank Account Without a Court Order?

In July 2026, INTERPOL announced the results of Operation First Light 2026, conducted from 15 January to 30 April with the participation of 97 countries and territories. According to INTERPOL, 31,014 bank accounts were blocked and assets worth almost USD 300 million were intercepted. One of the tools used during the operation was I-GRIP, INTERPOL's rapid payment intervention mechanism. The figures are striking, but from a legal perspective the more important question is what exactly gives an INTERPOL message the capacity to result in a bank account being frozen in another country.

The answer is somewhat counterintuitive: INTERPOL itself does not freeze bank accounts. Information transmitted through its systems may nevertheless lead, sometimes very quickly, to the suspension of a payment, the blocking of an account or the restriction of a virtual wallet. Understanding that distinction is essential to understanding both the legal nature of I-GRIP and the remedies that may be available when the information behind such action is disputed.

What is I-GRIP?

I-GRIP was officially launched by INTERPOL in November 2022 after the pilot use of its predecessor. A joint FATF, INTERPOL and Egmont Group report describes it as a global payment-stop mechanism through which countries may send and process requests to trace, intercept or provisionally freeze suspected criminal proceeds. In practice, I-GRIP facilitates rapid communication between INTERPOL National Central Bureaus (NCBs). A request is expected to contain enough information for the receiving side to act, such as the date and amount of a transaction, the currency, account details, the names of financial institutions and other identifying information.

The simplified sequence is therefore straightforward: the NCB of the requesting country sends information through INTERPOL's infrastructure to the NCB of the requested country; the receiving NCB then engages the competent domestic authorities, and any resulting action against the account is taken within that national system. I-GRIP should not be understood as a mechanism by which INTERPOL headquarters in Lyon sends a bank an order to freeze an account. INTERPOL has no such power.

Where does the power to freeze the money come from?

This is where one of the most important legal boundaries of the system appears. I-GRIP provides the international transmission of information and urgent coordination, but the legal authority to restrict a person's control over funds must come from the law of the country where the funds are held. INTERPOL itself puts the point cautiously: international coordination through I-GRIP allows authorities to take necessary action to the extent permitted by national law.

Two legally distinct acts must therefore be separated. The first is the transmission of information through INTERPOL channels, which is governed by INTERPOL's own legal framework. The second is the actual freezing or blocking of funds, which takes place under the domestic law of the country concerned. An I-GRIP message is not, in itself, an international seizure order.

Is an I-GRIP request binding on the receiving country?

No. A request transmitted through I-GRIP does not have mandatory supranational force and does not impose an unconditional duty on a national law-enforcement or other competent authority to freeze funds. Official materials describe I-GRIP as a mechanism for sending and processing requests for assistance. The receiving state must be legally able to act on the information provided, but the measures it may take depend on the powers of its own authorities and on its domestic law.

In practical terms, the requesting state gathers the relevant information and sends the I-GRIP request; INTERPOL provides the secure infrastructure for urgent international communication; and the requested state decides for itself whether the requested measure is legally available and, if so, what procedure must be followed. If one NCB informs another that funds in a particular account are believed to represent the proceeds of fraud, that communication does not become a court order of the receiving state, nor does it become a binding INTERPOL decision. The competent authority may consider the information sufficient for an urgent temporary measure under domestic law, but it may also require additional material, prosecutorial authorization, a judicial order or some other procedural basis. Receipt of an I-GRIP request does not remove those requirements.

This combination explains one of I-GRIP's most interesting characteristics: the mechanism may be extremely effective in practice even though the message itself is not legally binding on the recipient. Its effectiveness appears to rest on the speed of the information exchange, the level of trust between law-enforcement authorities, domestic anti-money-laundering mechanisms and the ability in many jurisdictions to pause a suspicious transaction before a full judicial or other formal decision is obtained. For the account holder, this means that it is not enough to establish that I-GRIP was used; the precise national legal basis on which the receiving country restricted access to the funds must also be identified.

How can this work in practice?

Consider a straightforward fraud scenario. A company in Country A becomes the victim of a fraud and several million euros are transferred to an account in Country B. Within hours, the victim reports the matter to the police. The authorities identify the receiving bank and the direction in which the funds are moving, and the NCB of Country A sends an urgent I-GRIP request to the NCB of Country B. What happens next is not the 'execution of an INTERPOL decision'. The receiving NCB acts within its own legal system, and depending on the jurisdiction the relevant decision may be taken by the police, a financial intelligence unit, a prosecutor, a court or, in some circumstances, the financial institution itself under anti-money-laundering rules.

Speed is crucial. A conventional request for mutual legal assistance may take weeks, during which the money may pass through several accounts, be converted into virtual assets, routed through mixers and disappear. I-GRIP is designed to operate within the much shorter window in which the funds can still be intercepted.

A real example: funds from Korea intercepted in Dubai

INTERPOL itself provides a useful illustration. During Operation HAECHI VI, a Korean company discovered that transport documents had been falsified after it transferred funds to an illicit bank account in Dubai. Korean police used I-GRIP, and rapid cooperation between Korean and UAE authorities enabled the full amount - KRW 6.6 billion, approximately USD 3.91 million - to be intercepted and later returned. From an operational perspective, the mechanism can therefore be remarkably effective. From a legal perspective, however, that same effectiveness raises a more difficult question: what happens if the information underlying the request is wrong or materially misleading?

What if the information is wrong?

Imagine a different case. Funds have genuinely been paid into the account of a company in Country B, but the account holder maintains that the transaction was lawful: there was a genuine contract, goods were delivered or services were performed, and the criminal case in Country A arose out of what was in substance a commercial dispute. Nevertheless, the money is described through I-GRIP as suspected criminal proceeds and the account is blocked. The practical consequences may be immediate and severe, leaving the owner unable to use a substantial amount of money. The obvious question is then who, before those consequences arose, tested the underlying allegation that the funds were criminal in origin.

Article 9 of INTERPOL's Rules on the Processing of Data

To address that question, it is necessary to turn to INTERPOL's Rules on the Processing of Data. Article 9 governs direct communications through the INTERPOL Information System, and this model differs significantly from the procedure used for the publication of certain INTERPOL notices. In direct NCB-to-NCB communication, primary responsibility for ensuring that the transmitted information complies with INTERPOL's rules rests with the NCB sending the message. It would therefore be misleading to assume that an I-GRIP communication necessarily receives the same kind of prior review that may occur in the notice context.

That does not mean that information transmitted through I-GRIP falls outside INTERPOL's legal framework. Where personal data are processed through the Organization's information system, the general requirements of the Rules on the Processing of Data continue to apply. The legal inquiry therefore does not end with the question whether the national authorities were entitled to block the account. There is a separate question as to whether the processing and transmission of the personal data through INTERPOL channels complied with INTERPOL's own rules.

Two levels of legality

This, in my view, is the central legal issue raised by I-GRIP. A bank-account restriction may engage two different legal orders at the same time. At the INTERPOL level, the issues include whether the data were processed for a lawful and proper purpose, whether the information met the applicable quality requirements, whether there was a sufficient connection with international police cooperation, and whether INTERPOL's channels were being used for purposes compatible with the Organization's Constitution and data-processing rules. At the national level, a different set of questions arises: which authority made the decision to restrict the assets, for how long, whether judicial authorization was required, whether there was a lawful basis for an urgent suspension, how the measure can be challenged, and whether it may continue after the initial emergency period.

Those questions are answered by the law of the country in which the funds were blocked, not by INTERPOL law. As a result, successfully challenging one level does not necessarily resolve the problem at the other. Effective defence may require both tracks to be examined in parallel.

Can the CCF help?

The Commission for the Control of INTERPOL's Files (CCF) independently reviews whether the processing of personal data through INTERPOL channels complies with the Organization's rules. It is not an international court, however, and it has no power to overturn decisions made by national banks, prosecutors or courts. The position is further complicated by the amendments to the CCF Statute approved by the INTERPOL General Assembly in 2025, which introduced specific rules concerning information exchanged directly between NCBs.

As a general rule, the Commission does not review information exchanged directly between NCBs. There is, however, an important exception where a serious violation of INTERPOL's rules is reported and brought to the Commission's attention in the manner contemplated by the amended Statute, including Articles 3, 19 and 28(1). For practitioners this matters, because it makes the simple answer that 'this was only an NCB-to-NCB message, so the CCF has nothing to do with it' too categorical. In appropriate circumstances, the lawfulness of the data processing underlying such a communication may fall within the Commission's scrutiny.

The relief sought before the CCF would nevertheless have to be framed correctly. The Commission cannot be asked to 'unfreeze the bank account'. The relevant question is whether the processing and transmission of the specific personal data through INTERPOL's system complied with the Organization's rules. Any challenge to the actual freezing measure must proceed separately under national law.

A practical example

Suppose a Russian national is living in Spain and his Spanish company receives a substantial payment under a commercial contract. A criminal investigation is pending against him in Russia, and the Russian authorities characterize the funds as criminal proceeds. Information is transmitted through INTERPOL channels and a Spanish bank then restricts transactions on the account. It would be legally imprecise simply to say that 'INTERPOL froze the account'. The defence would first need to establish what was transmitted through INTERPOL, who supplied the data, which mechanism was used, what was said about the origin of the funds, which domestic decision provided the immediate legal basis for the restriction, and whether that basis remains valid.

Only then can the correct strategy be identified. If the problem lies in the national asset-freezing decision, the principal challenge must be pursued in Spain. If, however, there are grounds to believe that inaccurate data, information inconsistent with the stated purpose, or other personal data seriously contrary to INTERPOL's rules were transmitted through the Organization's channels, a separate question arises as to whether the CCF may be engaged. In some cases, both avenues of defence may need to proceed at the same time.

Is I-GRIP a Red Notice for money?

The comparison is tempting, but legally inaccurate. A Red Notice is a specifically regulated instrument used in connection with the international location of a person, whereas I-GRIP is a mechanism for rapid international cooperation intended to prevent the further movement of suspected criminal proceeds. Their procedures, legal nature and consequences are different. What they have in common is that information transmitted through INTERPOL infrastructure can produce serious consequences for the person concerned, which is why the speed of international police cooperation cannot displace the requirement that data processing remain lawful.

Speed is both the strength and the legal challenge of I-GRIP

The practical value of I-GRIP in combating transnational fraud is difficult to dispute. Modern funds can move so quickly that traditional mutual legal assistance is often too slow to prevent dissipation. That is precisely the problem I-GRIP addresses. Yet the same speed that makes it effective also creates its most significant legal difficulty: very little time may pass between the transmission of information by one state and the effective loss of access to assets in another.

The restriction itself arises within a national legal system, while the informational trigger comes through an international police network. INTERPOL does not seize property, but its infrastructure can initiate a process that results in an actual freeze or seizure. The most difficult disputes are therefore likely to arise at the boundary between those two legal systems: national law on the one hand and INTERPOL's rules on the other.

Operation First Light 2026, in which tens of thousands of accounts were blocked, demonstrates that I-GRIP is already being used on a significant scale. For lawyers, the important practical question is no longer simply how the mechanism works, but what can be done when it is used against a client and the information on which it rests is inaccurate, outdated or was transmitted in serious breach of INTERPOL's rules. That issue is likely to become an increasingly important area of practice at the intersection of international criminal cooperation, banking law, domestic procedural law and CCF proceedings.

Sources

INTERPOL, Operation First Light 2026, 9 July 2026.

INTERPOL, Rules on the Processing of Data, in particular Article 9.

INTERPOL, About the CCF — amendments to the CCF Statute approved by the General Assembly in 2025 (Articles 3, 19 and 28(1)).

FATF / INTERPOL / Egmont Group, Illicit Financial Flows from Cyber-Enabled Fraud.

INTERPOL, Global Financial Fraud Assessment.