Extradition from Greece to Russia: defending against a Red Notice

A Russian extradition request transmitted through Greece can feel like two walls closing in at once. The notice is live. Provisional arrest is a real possibility. And ordinary life – travel, banking, contracts – has already narrowed or stopped entirely. The instinct is to wait and see. That instinct is almost always wrong.

Extradition from Greece to Russia is governed by a bilateral extradition treaty between the two states, Greek extradition law, and the European Convention on Human Rights as incorporated into the Greek legal order. A Red Notice issued at Russia's request is not an arrest warrant and not a judicial decision; it is a request to locate and provisionally detain with a view to extradition. The CCF (Commission for the Control of INTERPOL's Files) can order its deletion where INTERPOL's own Constitution or the RPD's data-accuracy requirements are breached. Both the Greek extradition proceedings and the CCF file must be addressed in parallel – each affects the other.

As of mid-2025, this corridor remains one of the more litigated in our extradition practice. What follows is an honest account of how the process works, the grounds that carry real weight, and where the genuine risks lie.

How does the Greece-to-Russia extradition corridor actually work?

Greece and Russia operate under a bilateral extradition treaty – a branch of international criminal co-operation law that imposes mutual obligations on both states. Under that treaty, Greece is formally obliged to examine a Russian request, but the treaty itself does not require surrender. It sets the conditions under which surrender may occur and, critically, the conditions under which it must be refused.

In practice, a Russian request typically reaches Greece via two routes. First, through a formal diplomatic channel following the issue of an INTERPOL Red Notice. Second, through a direct request from the Russian Prosecutor General's office to the Greek Ministry of Justice. These routes are not mutually exclusive. A Red Notice and a formal extradition request often run simultaneously, which is why acting early matters.

Once the Greek authorities receive a formal extradition request, the file goes before a Greek court of appeal. That court examines the request on the merits – not merely whether the paperwork is complete, but whether the conditions for surrender are legally met. Provisional arrest can precede that hearing, triggered by the Red Notice or by the formal request, and the timeline from arrest to first hearing is governed by Greek extradition law. Speed at that first hearing shapes everything that follows.

In our extradition practice, we have seen cases where the Russian file looked superficially sound but fell apart on closer reading – the underlying offence did not satisfy dual criminality, or the material accompanying the request omitted facts central to any fair assessment. The court does not search for those defects on its own. Counsel must put them before it, clearly and early.

What are the strongest grounds to resist surrender to Russia?

Several distinct grounds can resist or delay surrender, and they are not mutually exclusive. The file that works hardest typically runs more than one.

Human rights under the ECHR. Greece is a party to the European Convention on Human Rights. Its courts are bound to refuse surrender where there is a real risk of a flagrant breach of the right to a fair trial, of ill-treatment, or of persecution on political grounds. Russia's removal from the Council of Europe in 2022 is a relevant contextual fact, though it does not itself determine the outcome. What matters is the specific individual's situation, the nature of the charges, and the conditions they would face. In our practice, the human-rights ground has produced the most durable results in this corridor, provided the evidence is assembled properly.

Dual criminality. Greek extradition law, following the treaty, requires that the conduct alleged by Russia also constitutes a criminal offence under Greek law. This is a technical but often decisive ground. Russian prosecutions frequently frame conduct – commercial disputes, regulatory non-compliance, tax allegations – in terms that have no direct equivalent in the Greek criminal code. Where the alleged conduct, stripped of its Russian characterisation, is not criminal under Greek law, the court should refuse surrender. We examine the underlying factual allegations, not merely the label attached to them.

Political character of the offence. Article 3 of INTERPOL's Constitution bars the processing of data connected to offences of a political, military, religious or racial character. The same principle applies in Greek extradition law and under the bilateral treaty: politically motivated prosecutions are a ground for refusal. Establishing political character before the Greek court requires evidence, not assertion – documentation of the prosecutorial context, the complainant's identity and interests, and the pattern of the proceedings in Russia.

Article 2 of INTERPOL's Constitution requires INTERPOL's activity to respect human rights in the spirit of the Universal Declaration of Human Rights. Where a Red Notice was issued to support a prosecution that violates this requirement, the CCF can be asked to delete the notice independently of the Greek extradition proceedings.

Refugee status and non-refoulement. Where the individual has been granted refugee or subsidiary protection status in Greece or another EU state, surrender to the prosecuting state is generally incompatible with the non-refoulement principle. Greek courts take this ground seriously, and it can operate as an absolute bar.

Ne bis in idem. If the underlying conduct has already been tried and disposed of in Greece or in another jurisdiction, the double-jeopardy principle – ne bis in idem – may block a fresh surrender. This ground requires precise documentation of the earlier proceedings and their outcome.

How does the Red Notice interact with extradition proceedings in Greece?

The Red Notice and the extradition request are separate instruments, but they reinforce each other in dangerous ways if both are left unaddressed. The notice keeps the individual on law-enforcement databases across all INTERPOL member countries. Provisional arrest in Greece – or in any country the person transits through – becomes a live risk so long as the notice stands. The extradition request then converts that provisional arrest into a formal surrender hearing.

Challenging the Red Notice before the CCF does not automatically stop extradition proceedings in Greece, and challenging the Greek extradition does not automatically remove the notice. The two tracks must be co-ordinated. A CCF deletion request filed with no awareness of the Greek proceedings – or vice versa – can produce contradictions that undermine both.

Under the RPD's data-accuracy requirements, the CCF examines whether the data INTERPOL processes about an individual is accurate, adequate and not excessive. A Russian extradition request based on a prosecution that a Greek court subsequently finds to be politically motivated, or one that fails dual criminality, provides strong supporting material for a CCF submission. The two files should tell a consistent story.

The CCF deletion process has its own timeline. A deletion request, once found admissible, is to be decided within nine months. An access request – to establish what data INTERPOL holds – is to be answered within four months. There is no appeal against a CCF decision; a further request requires new elements. A weak first CCF file, filed without awareness of the extradition proceedings, narrows the room for a second attempt.

In a recent matter (a CIS-origin notice, winter 2024), we obtained deletion before the formal extradition request arrived, which removed the provisional arrest risk and materially changed the dynamic of the subsequent proceedings. In a second matter (a MENA-connected file with a European nexus, spring 2025), the extradition request was refused by the court on human-rights and dual-criminality grounds simultaneously, and the CCF file was then resolved on the basis of the court's findings. Sequencing matters.

Can the rule of specialty or other procedural protections help?

The rule of specialty is a standard feature of extradition treaties and Greek extradition law. It provides that a person surrendered to a requesting state may only be prosecuted for the offences named in the extradition request. Russia may not use a surrender for a commercial fraud allegation to then try the same individual for a separate tax offence, for example. In our experience, specialty arguments are most useful at an early stage, to frame the scope of what Russia is actually requesting and to test whether the request is genuine or opportunistic.

Procedural defects in the Russian request itself can also found an objection. Greek courts examine whether the request meets the formal requirements of the treaty: adequate description of the alleged acts, supporting evidence, assurances concerning the conditions of detention and the fairness of the proceedings. Where Russia's file is incomplete or internally inconsistent, those defects should be put squarely before the court.

One honest limitation: Greek proceedings can be slow. The formal hearing timelines under Greek extradition law do not always move at the pace a client under provisional arrest would wish. Managing that reality – including bail applications and applications to have provisional arrest lifted – requires early engagement before the first hearing, not after it.

What should you not do after a Russian Red Notice or extradition request?

Several responses we see are either neutral at best or actively harmful.

Ignoring the notice in the hope it will expire is the most common and most damaging. Red Notices do not lapse automatically in any timeframe that offers practical comfort. They circulate to every INTERPOL member country and can result in provisional arrest at any border crossing.

Filing a CCF request without a parallel extradition strategy is the second error. A CCF submission that argues political character, while the Greek extradition file says nothing about it, creates contradictions that a well-resourced requesting state will exploit. Consistency across both files is not optional.

Attempting a self-represented CCF submission is the third. The verified position is clear on this point: a person may formally apply to the CCF without a lawyer, but the outcome depends heavily on the quality of the legal argument. A weak first file lowers the odds on any review, and there is no appeal. The CCF is not a form-filling exercise. It is a legal submission that must identify the precise ground, cite the applicable branch of the RPD or the Constitution, and support the argument with evidence that the CCF can weigh.

Finally: do not assume that the Greek proceedings and the CCF process will resolve each other automatically. They will not. Each requires a separate, properly constructed file. Where they can be made to reinforce each other, they should be.

What is the realistic prospect of success in this corridor?

No honest practitioner guarantees a result in extradition proceedings, and anyone who does is not being straight with you. What we can say, honestly, is this.

The Greece-to-Russia corridor is litigated. Greek courts have refused Russian extradition requests on human-rights grounds. The ECHR framework, the dual-criminality requirement, and the political-offence exception are all live and functional in this corridor. Where the underlying prosecution is politically motivated, commercially driven, or based on conduct that simply does not satisfy dual criminality, there are real grounds to work with.

The difficulty is evidential. A ground exists in the abstract but must be established in the specific file. A Russian prosecution that looks political from the inside does not automatically read that way to a Greek court or to the CCF without careful, targeted evidence. The strength of the submission – its factual specificity, its consistency with what INTERPOL's own records show, and its alignment with how Greek courts have approached this corridor – is the variable that matters most.

The steps above are the general picture. Your situation turns on the specific file, the requesting state's actual conduct and the timing – which is exactly what an assessment examines. For a confidential assessment of the grounds in your case, contact us at info@northlarkfirm.com or reach us through our secure channel.

Common myths about extradition from Greece to Russia

One persistent myth is that filing to the CCF yourself – once you have confirmed a notice is live – will be enough to stop extradition. The CCF and the Greek extradition court are separate institutions with separate mandates. A CCF deletion, valuable as it is, does not bind a Greek court and does not automatically terminate extradition proceedings. Conversely, a Greek court refusal does not automatically prompt the CCF to act. Both tracks need to be run.

A second myth is that EU membership protects Greece's residents from Russian extradition requests. Greece is an EU member and an ECHR contracting state, both of which create real legal protections. But neither membership automatically bars a Russian request. They provide the grounds on which surrender can be refused, not a blanket immunity. The grounds must be argued, evidenced and put before the court.

A third myth is that a previously refused extradition from another country makes the Greek proceedings straightforward. A refusal elsewhere is relevant evidence and can carry weight, particularly on human-rights grounds. It is not, however, binding on a Greek court, and Russia may reframe or supplement the earlier request in ways that require fresh analysis.

If a first CCF request or an earlier extradition defence produced a refusal, a second reading can identify what was missed and whether there are new grounds – remembering there is no appeal, so a review must be built carefully. Write to us at info@northlarkfirm.com to discuss whether new elements exist.

Related

• Extradition proceedings in Greece – how Greek courts examine formal extradition requests
• Red Notices issued by Russia – the pattern of Russian requests and how to challenge them
• Article 2: human rights as a ground for deletion – INTERPOL's Constitution and the human-rights standard

Frequently asked questions

Can I be released or bailed during proceedings?

Bail or provisional release during Greek extradition proceedings is possible but not automatic. Greek extradition law gives the court discretion to order release, with or without conditions, pending the formal hearing. The decision turns on the flight risk assessment, the seriousness of the underlying allegations, and the strength of any preliminary defence raised. Early engagement before the first hearing – rather than after remand is ordered – gives the best realistic prospect of securing release.

Does dual criminality apply to my case?

Dual criminality is a standard requirement under both Greek extradition law and the bilateral treaty with Russia. The conduct alleged must constitute a criminal offence under Greek law, not merely under Russian law. Where the underlying allegation is a commercial dispute, a regulatory matter or a tax claim framed as fraud, the dual-criminality analysis often reveals a gap. The court examines the actual conduct alleged, not the Russian legal label attached to it – which is why the factual detail of the Russian file matters greatly.

What is the rule of specialty and does it help me?

The rule of specialty means that if Greece surrenders you to Russia, Russia may only prosecute you for the specific offences named in the extradition request. It cannot use the surrender to pursue separate, undisclosed charges. In practice, specialty arguments are most useful early: they define the precise scope of Russia's request and can expose whether the stated charges are the real purpose of the request or a pretext for broader prosecution. Where Russia has a history of expanding charges after surrender, specialty evidence should go before the court.

About NORTHLARK

NORTHLARK is an independent international boutique focused on defending individuals against unjustified INTERPOL Red Notices, diffusions and related extradition proceedings. We act before the CCF and in extradition proceedings across multiple jurisdictions, coordinating with allied counsel in the country of detention where parallel proceedings require it. We are fully independent, with no affiliation to any regional network, and that independence is a deliberate protective feature for clients whose exposure originates in Russia or the CIS.

We act only on lawful mandates. We do not help anyone evade legitimate justice, and we take on a matter only where we see genuine grounds. We assess those grounds honestly before any engagement – including in this corridor, where the stakes are high and the legal position is rarely simple.

The first assessment is confidential. Our enquiry form does not require your real name, and you can reach us through a secure channel – Signal, Telegram or WhatsApp. Write to us at info@northlarkfirm.com or contact us through your preferred secure channel to discuss your situation.