Authoritarian regimes, including states already under Western sanctions, exploit anti-money laundering rules, INTERPOL’s notice systems, and mutual legal assistance treaties to freeze accounts, access private data, and destroy the livelihoods of their critics in democratic countries. The system allows it because it was built on an assumption of good faith that no longer holds. On 4 July 2026, Lyudmyla Kozlovska, ODF’s president, chaired a panel at the OSCE Parliamentary Assembly in The Hague bringing together a former U.S. National Security Advisor, OSCE and Council of Europe parliamentarians, international lawyers, and civil society leaders to demand concrete reforms:
- a presumption of abuse for cooperation requests from perpetrator states,
- pre-freeze verification before accounts can be blocked,
- sanctions against states that weaponise INTERPOL,
- human rights safeguards in FATF rules,
- protection of donor privacy and encrypted communications, and
- a binding international convention to prevent and punish transnational financial repression.
On 4 July 2026, Italian MP Mauro Del Barba (Italian Delegation to the OSCE Parliamentary Assembly) hosted a panel discussion on transnational financial repression at the OSCE PA Annual Session in The Hague, in cooperation with the Open Dialogue Foundation and the Economic Inclusion Group. The side event brought together a former U.S. National Security Advisor, members of parliament from Italy, Sweden, and Latvia, international lawyers, policy researchers, technology entrepreneurs, and civil society leaders to address the systematic abuse of international cooperation mechanisms by authoritarian regimes to pursue, debank, and silence their critics abroad.
The hearing marked the first time the OSCE Parliamentary Assembly hosted a dedicated session on transnational financial repression, the deliberate misuse of anti-money laundering and counter-terrorism financing (AML/CFT) frameworks, INTERPOL notice systems, mutual legal assistance treaties, and cybersecurity conventions by foreign states to economically coerce individuals and organisations beyond their borders. Targets include human rights defenders, opposition politicians, diaspora leaders, journalists, scientists, entrepreneurs, donors, and increasingly, serving and former officials of EU and NATO member states.
The event generated a set of concrete reform proposals directed at OSCE participating states, INTERPOL, the Financial Action Task Force (FATF), and national regulators, centred on five priorities: identifying and penalising states that weaponise international cooperation frameworks; introducing human rights and financial inclusion safeguards into AML/CFT regulations; reforming INTERPOL’s notice and governance systems; protecting philanthropic freedom and donor privacy; and creating rapid-response channels for victims of transnational financial repression in strategic sectors.
Mutual trust as a vulnerability
Opening the session, Mauro Del Barba, Member of the Italian Chamber of Deputies and host of the event, framed the issue as a challenge not of choosing between security and fundamental rights, but of ensuring that international cooperation instruments remain resilient against abuse. He emphasised that mechanisms such as the AML/CFT framework and INTERPOL cooperation are indispensable within the OSCE, and that whenever they prove vulnerable to manipulation, they risk eroding the most valuable asset that participating states share: mutual trust.
Lyudmyla Kozlovska, President of the Open Dialogue Foundation, provided the institutional context. ODF has worked on the weaponisation of interstate mechanisms since 2013, initially focused on INTERPOL reform to protect refugees and civil society activists targeted by authoritarian regimes. She stressed that transnational financial repression is no longer only a human rights concern affecting activists and diaspora communities; it now targets members and officials of OSCE and NATO member states, including documented cases in the Baltic states, Poland, and the Czech Republic involving Russian-weaponised instruments.
What is transnational financial repression, and who is targeted?
Jorge Jraissati, President of the Economic Inclusion Group, delivered a detailed explanation of how transnational financial repression operates. He outlined how international cooperation frameworks, including AML/CFT, INTERPOL, cybersecurity conventions, and terrorist financing frameworks, were built on the assumption that states would act in good faith. That assumption, strengthened after 9/11, is now being heavily exploited by authoritarian actors worldwide.
Jraissati identified the specific mechanisms being weaponised: beyond INTERPOL red notices, he highlighted the purple notice (used to access private information of citizens and organisations in other jurisdictions) and the silver notice (a newer mechanism designed to freeze assets), both of which are vulnerable to abuse in the current geopolitical environment. He described how authoritarian states manufacture misinformation campaigns labelling targets as money launderers or terrorist financiers, leading to debanking and economic destruction in Western democracies.
He introduced two key analytical concepts. First, the absence of due process: a country can initiate legal requests in Europe or the United States without requiring a court decision in the target’s own jurisdiction. Second, asymmetric compliance, a term he credited to Daniel Rothschild: if a court in an authoritarian country issues a money laundering finding, Western banks and courts tend to act on it, but the reverse never applies. Authoritarian states refuse to comply with equivalent requests from democratic countries.
Jraissati concluded with a call for the OSCE to promote a framework identifying states and their proxies that weaponise cooperation agreements, to establish penalties and non-automatic approval of requests from abuser states, and to introduce human rights and financial inclusion safeguards into the FATF system, reforms he described as historically unprecedented and urgently needed.
Philanthropic freedom under threat
Lawson Bader, President and CEO of DonorsTrust and Donors Capital Fund, addressed the hearing from the United States to make the case that philanthropic freedom, the right to support charitable causes anonymously, is a fundamental liberty now directly threatened by transnational financial repression.
Bader drew on American legal history to illustrate the constitutional foundations of donor privacy, from 19th-century Supreme Court jurisprudence establishing that charitable gifts are not government property, to the landmark mid-20th century ruling that struck down compelled disclosure of a civil rights organisation’s supporters. He argued that these principles, while rooted in U.S. law, are universal.
He explained why donor privacy matters from four perspectives: its roots in religious traditions of humble charity; its protection of non-profit independence from donor influence; its defence of both wealthy and ordinary citizens from political intimidation; and its protection against real physical harm, citing his own experience of receiving threats serious enough to require police protection at his home and personal security at public events, solely because of lawful grants made through his organisation.
Bader warned that if international financial agreements compel disclosure of donor identities, charitable giving, including millions of dollars that U.S. donors send overseas, will decline significantly, not because generosity has disappeared, but because people will reasonably fear the consequences. He concluded with a principle he urged policymakers to adopt as a test for any regulation affecting philanthropy: transparency is the obligation of government, but privacy is the right of citizens.
INTERPOL: a system built on trust, exploited in bad faith
Cristian González Ruiz, Associate at International Human Rights Advisors (IHR Advisors) and former practitioner at the International Criminal Court, provided a technical analysis of how INTERPOL’s systems are abused for transnational financial repression.
He explained that INTERPOL functions primarily as a database and data-sharing organisation, not as an operational police force. With 196 member countries and approximately 22 million daily database searches, national police can register notices that are almost automatically entered into INTERPOL’s systems, with serious practical consequences: tracking, arrest, extradition, account freezing, and reputational damage.
González Ruiz identified Russia as a persistent abuser, providing a concrete example: a Nordic company that left the Russian market after the invasion of Ukraine was targeted through fabricated criminal charges, including complex financial crime accusations designed to be difficult to challenge technically.
He stressed a structural vulnerability that remains unaddressed: states and entities already under Western sanctions retain full access to INTERPOL’s notice and data-sharing systems. A state sanctioned for aggression or systematic human rights violations can still register red, purple, and silver notices, request private data, and trigger asset freezes against its targets in the very jurisdictions that imposed those sanctions. The system, as currently designed, does not distinguish between cooperation requests from democratic states acting in good faith and those from sanctioned regimes pursuing political opponents.
He acknowledged INTERPOL’s safeguard mechanism, the Commission for the Control of Files (CCF), but emphasised that it operates as a posterior control, meaning relief comes only after individuals have already suffered arrest, asset freezing, and personal harm. He called for a reformed system of prior review and sanctions against serial abusers, describing the approach as being a “critical friend” of INTERPOL, defending the system’s purpose while insisting it live up to its own human rights commitments.
Lived experience: a Latvian lawmaker’s perspective
Skaidrite Abrama, Member of the Latvian Delegation to the OSCE PA, offered a personal account of how reputational harm functions as a tool of retaliation. Drawing on 16 years of experience leading Latvia’s competition authority, she described how entities she had sanctioned for market abuse and cartel behaviour launched coordinated PR campaigns to discredit her, campaigns that continued even eight years after the relevant decisions, when she had entered parliament.
Her testimony illustrated a pattern relevant to the broader discussion: that individuals who make independent, lawful decisions, whether heads of regulatory agencies, judges, or parliamentarians, face sustained reputational attacks designed to discourage future enforcement. She emphasised that this form of retaliation leaves individuals isolated, with limited legal recourse, since courts in her jurisdiction have held that politicians must tolerate a higher threshold of public criticism.
Weaponisation of compliance architecture against strategic sectors
Pavlo Tanasyuk, Founder and CEO of Spacebit, presented his case as an example of transnational financial repression targeting the technology and defence sector. A Ukrainian-born British citizen working on lunar rover technology for NASA programmes, Tanasyuk described how he was targeted after reporting to authorities a network of individuals with deep Russian connections who were attempting to influence political decision-making in the United States and United Kingdom.
The retaliation pattern he described, including bad-faith legal threats, strategic litigation, manufactured defamation in media outlets, death threats, and deliberate interference with banking services and investment, illustrates a critical vulnerability: modern banking, investment, and procurement systems depend on semi-automated risk-assessment tools that can be manipulated by hostile actors manufacturing “reputational risk” signals through paid media and coordinated lawsuits.
Tanasyuk called for systems that can distinguish between genuine risk signals and coordinated retaliatory campaigns, reforms that require banks and due-diligence providers to assess the quality and origin of negative signals, and the creation of rapid-response channels for cases involving defence technology and critical infrastructure, sectors where delays in protection have strategic consequences for democratic cooperation.
The geopolitical dimension: transnational repression as hybrid warfare
Lt. Gen. H.R. McMaster (Ret.), 25th U.S. National Security Advisor and Senior Fellow at the Hoover Institution, Stanford University, placed transnational financial repression within the broader context of what he described as a sustained campaign of political subversion waged by an “axis of aggressors”, centred on China and Russia, and drawing in Iran, North Korea, and other authoritarian actors who share their form of government and seek to tear down the existing rules-based international order.
McMaster connected transnational financial repression to the wider spectrum of hybrid warfare operations targeting Europe: the cutting of undersea cables, drone incursions, destruction of warehouses and rail lines, and assassination contracts on defence industry executives. He argued that the purpose of transnational repression is to extinguish hope, to exert control over the life chances of those who oppose authoritarian regimes, expose corruption, or challenge their systems of rule.
He proposed five key actions for democratic countries: first, expose and map intimidation networks, including the cooperation between intelligence services such as Russia’s SVR and GRU and China’s MSS; second, educate domestic populations and diaspora communities about these campaigns; third, support victims through financial reforms, including requiring banks to explain account closures and providing quick legal remedies; fourth, counter and deter these operations by expelling undeclared intelligence operators and disrupting intimidation networks through legal means; and fifth, reform, replicate, or replace international organisations that are no longer fit for purpose, including, if necessary, forming new executive structures within INTERPOL composed exclusively of democratic states committed to the organisation’s original mission.
Asymmetric compliance and the new walls of repression
Daniel M. Rothschild, Director of the Center for Civics, Education and Opportunity at the Ronald Reagan Institute, delivered a historically grounded argument framing transnational financial repression as the 21st-century equivalent of the physical walls that once confined citizens of unfree states.
He argued that the AML/CFT and financial cooperation frameworks established between 1989 and 2001 rested on three assumptions that no longer hold: that the international system was unipolar and broadly cooperative; that the principal threat came from non-state actors; and that all state parties would comply in good faith. Today, he said, democratic countries find themselves in an era of asymmetric compliance, continuing to honour the spirit of these rules while adversaries weaponise them.
Rothschild noted that autocrats are no longer restricting their targets to current or former citizens of their own countries, but increasingly targeting parliamentarians, judges, journalists, and academics from other countries entirely. He pointed to the recent unanimous U.S. Supreme Court ruling that domestic regulators cannot coerce private entities under the guise of “reputational risk” warnings, and urged that the same standard be applied to autocrats abroad.
He concluded by calling on the OSCE community to develop a reinvigorated framework of freedom, updating policies that have inadvertently enabled transnational financial repression while recognising that standing on the side of freedom now means preventing autocrats from asymmetrically exploiting trust-based international systems.
A call for OSCE-wide action
Markus Wiechel, Member of the Swedish Riksdag, Chairman of the Swedish Delegation to PACE, and member of the OSCE PA, concluded the panel with a survey of how states already under Western sanctions, including Iran, Russia, Belarus, Cuba, and Venezuela, continue to weaponise interstate cooperation mechanisms, including INTERPOL, to engage in transnational repression through notice abuse, espionage, assassination attempts, and the pursuit of exiles across borders.
He described the Iranian regime’s refusal to recognise renounced citizenship and its systematic harassment of diaspora communities, including an assassination attempt against a close colleague in Sweden, as well as Russia’s and Belarus’s combination of red notice abuse, lawfare, and corporate raiding. He highlighted Venezuela’s pattern of issuing INTERPOL notices against journalists and opposition voices, and Cuba’s extension of domestic repression abroad despite European engagement.
Wiechel called for INTERPOL reform with stronger independent review, transparency, and automatic safeguards against notices from serial abusers; improved national screening of red notices; targeted sanctions and support for international justice; and strong OSCE PA resolutions translating recommendations into coordinated action by participating states.
Preserving international cooperation by protecting it from abuse
Closing the session, Mauro Del Barba emphasised that the panel had not questioned the value of international cooperation; on the contrary, it had discussed how to preserve it. The best way to defend shared instruments, he concluded, is to ensure they cannot be turned against the very values they were created to protect.
For more on ODF’s work combating transnational financial repression, visit the BTC Coalition & FreedomTech Embassy page.
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