Greece sits at a significant crossroads for international extradition. It is an EU member state with treaty obligations stretching from the European Convention on Extradition to bilateral arrangements across multiple continents. It has an independent judiciary and a constitutional order that takes human rights seriously. And yet, in our practice, it is precisely in Greece that we see some of the most avoidable mistakes made – arrests handled without specialist input, first hearings attended without a proper assessment of the grounds, and Red Notices left unchallenged while detention drags on.
An extradition lawyer in Greece must work on two tracks simultaneously: the proceedings before the Greek courts and, where a Red Notice underpins the arrest, the parallel process before the Commission for the Control of INTERPOL's Files. Greece does not automatically extradite. Each request is examined on its merits under the extradition law of the requested state, and objections rooted in dual criminality, human rights and the political character of a prosecution are regularly raised and sometimes succeed. As of mid-2025, the volume of requests reaching Greece from CIS and MENA jurisdictions has grown, making early specialist engagement more consequential than ever.
This page sets out the structure of extradition proceedings in Greece, the grounds that carry real weight, the interaction with INTERPOL's notice system, and the points where the defence can be lost before it has properly begun.
How does extradition actually work in Greece?
Greek extradition proceedings are governed by the extradition law of the requested state – Greece – and by the applicable treaty or convention with the requesting country. The competent court is the Court of Appeal with jurisdiction over the location of detention. That court examines whether the formal conditions for extradition are met and whether any mandatory or discretionary bars apply.
Provisional arrest often precedes a formal request. A person arrested on the basis of a Red Notice or a diffusion can be held for a defined period while the requesting state transmits its formal extradition papers. In our experience, this window is shorter than most clients expect. The first hearing before the Court of Appeal is not a formality. It is the moment at which the court assesses whether detention is justified and whether the request discloses the minimum required by the applicable treaty.
What many people miss is that the hearing is also the first opportunity to lay down a record. Arguments not raised early can be harder to introduce later. A competent cross-border defence does not wait to see what the requesting state files; it arrives at the first hearing with a prepared legal position.
In a recent matter (a MENA-origin request, spring 2025), the arrest was made on a Friday evening and the first hearing was scheduled for the following Monday. Allied counsel in Greece and our CCF team were instructed over the weekend. By Monday, the dual-criminality gap in the underlying offence was identified and before the court. That sequence – rapid instruction, immediate legal analysis, early record – is not exceptional. It should be standard practice.
What grounds can defeat an extradition request in Greece?
Greek extradition law recognises several bases for refusal, and the applicable treaty or convention layers additional ones on top. The grounds that arise most frequently in our practice fall into four broad categories.
Dual criminality is the first and often the most reliable check. For extradition to proceed, the conduct alleged must constitute a criminal offence under Greek law as well as under the law of the requesting state. Where the requesting state has cast its charge broadly – or where the underlying conduct is lawful in Greece – the dual-criminality requirement is a genuine barrier. We examine the charging document against Greek criminal law carefully. A mismatch, even a partial one, can be decisive.
Political character is the second ground. INTERPOL's Constitution bars notices connected to offences of a political, military, religious or racial character under Article 3, and Greek extradition law contains an analogous protection. Where the prosecution originates in a commercial dispute that has been criminalised for political reasons – a pattern we see with some regularity from certain CIS jurisdictions – the political-character argument runs both before the CCF and before the Greek court. The two proceedings reinforce each other when they are properly aligned.
Human rights form the third ground. Under Article 2 of INTERPOL's Constitution, INTERPOL must respect human rights, in the spirit of the Universal Declaration of Human Rights. Greek courts also examine whether surrender would expose the person to a real risk of treatment prohibited by the European Convention on Human Rights. Where prison conditions in the requesting state, or the risk of unfair trial, are evidenced rather than merely asserted, the human-rights bar has real force.
Ne bis in idem – the rule against double jeopardy – is the fourth. Where the conduct in question has already been the subject of proceedings, acquittal or conviction in Greece or another EU state, extradition should be refused. This ground requires careful documentation of earlier proceedings and sometimes produces complex arguments about what "the same acts" means across different legal systems.
How does the Red Notice interact with the Greek extradition proceedings?
A Red Notice is a request to locate and provisionally detain a person with a view to extradition. It is not an international arrest warrant and not a judicial decision. Greece is not obliged to arrest solely because a notice exists; arrest and detention are governed by Greek law and the applicable treaty.
In practice, however, a live Red Notice significantly increases the risk of arrest at any Greek border point or during routine contact with law enforcement. It also affects banking, travel and contractual relationships in ways that accumulate quickly. We have seen accounts closed within days of a notice becoming visible to compliance teams – banks close accounts first and ask questions later, and the process of restoring those relationships is considerably more difficult once a file is already weak.
The relationship between the CCF process and the Greek court proceedings is one that practitioners frequently underestimate. They are parallel tracks, not sequential ones. A deletion request filed with the CCF does not stay the Greek extradition proceedings; conversely, a refusal of extradition by a Greek court does not automatically lead to deletion of the notice. Both need to be pursued, with the arguments co-ordinated so that evidence used in one forum supports rather than undermines the other.
The CCF's timeline matters here. A deletion request is, under the applicable rules, to be decided within nine months of the request being found admissible. An access request – to confirm whether data is held – should be answered within four months. There is no appeal against a CCF decision; where a first request fails, a review requires new elements. This is why the quality of the first CCF file is so consequential: a weak initial submission can close off a realistic second attempt.
In a recent CCF matter (a CIS-origin notice, autumn 2024), the first request had been filed without specialist legal input and refused. We were instructed at that point. A careful review of the political character of the underlying prosecution produced new elements sufficient to reopen the matter. The notice was subsequently deleted. The lesson is not that a poor first file is always recoverable – it is not always – but that the cost of getting it right the first time is low compared to the cost of rebuilding a file from a position of refusal.
What happens at the first extradition hearing in Greece?
The first hearing before the competent Court of Appeal is the procedural gateway to extradition. At this stage, the court examines whether the formal requirements under the applicable treaty are met, whether the arrest was lawful under Greek procedure, and whether there are any bars that are immediately apparent.
Critically, this is also the first opportunity to argue for release from provisional detention pending the full extradition hearing. The arguments for release overlap with, but are not identical to, the substantive extradition arguments. Risk of absconding, ties to Greece, personal circumstances and the strength of the substantive defence all feed into the detention assessment.
Counsel at the first hearing should already have reviewed the available treaty text, the arrest documents and, where possible, an outline of the charges. Walking in without those materials – which does happen when instruction is left too late – means the court record begins without a proper foundation. That is very difficult to remedy.
For clients who are not yet detained, the period before any arrest is the most valuable. It allows a full assessment of the underlying file, a pre-emptive CCF request where appropriate, and preparation of the extradition defence without the pressure of a detention clock running. The lost opportunity is not usually the first hearing itself; it is the days or weeks before it when nothing is done.
Is it possible to challenge the extradition at a later stage?
Yes, Greek extradition proceedings allow for substantive challenge at the full Court of Appeal hearing and, in certain circumstances, for further review thereafter. However, each stage of the proceedings is built on the record established at the stage before. A first hearing that produces no arguments, or a CCF file that has already been refused on grounds of poor quality, makes every later stage harder.
The appeal structure in extradition matters in Greece gives the defence genuine opportunities. Human-rights arguments, dual-criminality objections and political-character claims can all be developed at the full hearing with supporting evidence. Expert evidence on country conditions in the requesting state is regularly introduced before Greek courts. Allied counsel in Greece co-ordinate closely with us on the international legal elements – the CCF file, the notice history, the characterisation of the underlying charges – while managing the domestic procedural requirements.
One honest limitation: where the requesting state has produced a well-documented extradition request and the dual-criminality requirement is clearly satisfied, and where no human-rights or political-character argument is sustainable on the facts, the prognosis is difficult. We say so clearly. No honest practitioner guarantees a result in extradition proceedings, and any adviser who does should be viewed with caution. What we can offer is an honest assessment of the grounds before any commitment is made.
What are the most common mistakes in Greek extradition defence?
The first and most consequential mistake is delay. The window between becoming aware of a risk and the moment of arrest is the period of maximum opportunity. Instruction of specialist counsel, filing of a pre-emptive CCF access request, assembly of documentary evidence for the dual-criminality and political-character analysis – all of this is far more effective before arrest than after it.
The second mistake is treating the CCF filing and the Greek court proceedings as separate matters to be handled independently. They are not. The legal arguments must be aligned; the documentary evidence must be consistent across both fora; and the sequencing of filings must be considered strategically. We have seen cases where well-intentioned domestic counsel in Greece made submissions to the court that contradicted the CCF file, with damaging results.
The third mistake is a weak first CCF submission. A common misconception holds that a person can file with the CCF themselves and, if that does not work, can call in a lawyer to fix it. In our practice, the CCF submissions that succeed are built on detailed legal argument under the RPD's data-accuracy and processing conditions, the Constitution's human-rights requirements, and a carefully marshalled evidential file. A bare submission that simply says the charges are false rarely achieves anything and can harm a second attempt.
The fourth mistake is failing to address the banking and travel consequences while the legal proceedings run. A person who cannot access funds, cannot travel, and whose business relationships have frayed is in a worse position to fund and sustain a defence. Addressing the consequences in parallel – evidencing the position to affected institutions in a way that is consistent with the legal strategy – is a practical necessity, not an optional extra.
What is the cross-border picture: Greece versus the requesting state?
Greece's position as an EU member state, its geographic location, and its active international treaty network make it one of the more common venues in which CIS, MENA and Asian extradition requests arrive. The requesting state's motivation and the receiving state's domestic legal position often tell very different stories.
From a CIS requesting state, the extradition request is frequently the legal mechanism through which a commercial dispute, a regulatory disagreement, or a politically inconvenient individual is pursued. The criminal charge in the requesting state may be genuine, or it may be a repurposed instrument. The Greek court examines the dual-criminality question under Greek law, and Greek courts are experienced in assessing requests from jurisdictions where prosecutorial independence is in question.
From a MENA requesting state, different issues arise: fair-trial standards, the consistency of the underlying process with Greek constitutional requirements, and in some cases the nature of the offence itself. Conduct that is criminalised in a MENA jurisdiction may not constitute a criminal offence under Greek law at all – which returns us to dual criminality as the first line of analysis.
The cross-border defence is therefore not simply a defence conducted in Greece. It is a co-ordinated position that accounts for the requesting state's legal and political context, the applicable treaty, the CCF position and the domestic Greek proceedings. Lawyers who handle only one of those tracks without regard to the others produce results that are, at best, incomplete.
Related
- Extradition Defence Service – how we structure a cross-border extradition defence end to end
- Dual Criminality – when the conduct charged does not meet Greek criminal law requirements
- Red Notice Removal – filing with the CCF to delete the notice that underpins an arrest
The steps above describe the general structure. Your position turns on the specific file, the requesting state, the applicable treaty and the timing of instruction – which is precisely what an assessment is designed to clarify.
For a confidential first assessment of the grounds in your case, contact us at info@northlarkfirm.com or through our secure channel. We assess grounds honestly before we take a matter on, and we do not charge for the initial assessment.
Frequently asked questions
What happens at a first extradition hearing?
At a first extradition hearing in Greece, the competent Court of Appeal examines whether the arrest was procedurally lawful, whether the applicable treaty requirements are formally satisfied, and whether provisional detention should continue. It is also the moment at which the defence first puts its legal position before the court. Arguments established here form the foundation for every later stage, so specialist preparation before the hearing – not at it – is essential. The available window is often shorter than clients expect.
Can extradition be refused on human-rights grounds?
Yes. Greek courts assess whether surrender would expose the person to a real risk of treatment inconsistent with fundamental rights. Article 2 of INTERPOL's Constitution requires INTERPOL to respect human rights, and analogous protections operate in Greek extradition law and through Greece's obligations under the European Convention on Human Rights. Where prison conditions, fair-trial standards or the risk of persecution in the requesting state are evidenced in a detailed and credible way, the human-rights bar can succeed. Assertion alone rarely suffices; evidence does the work.
How does the Red Notice affect the request?
A Red Notice is a request to locate and provisionally detain a person with a view to extradition – it is not an arrest warrant and does not compel Greece to act. In practice, a live notice substantially increases arrest risk at borders and produces banking and travel consequences before any formal extradition request is received. A CCF deletion request and the Greek extradition proceedings are parallel tracks. A deletion request should be decided within nine months of admissibility; there is no appeal against a CCF decision, so the quality of the first submission matters greatly.
About NORTHLARK
NORTHLARK is an independent international boutique practising exclusively in INTERPOL Red Notice and diffusion defence and in cross-border extradition proceedings. We have no affiliation with any national network or parent firm. Our practice before the CCF and in extradition matters is our whole focus, not a supplementary service.
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 for challenge. If the grounds are not there, we say so at the assessment stage.
The first assessment is confidential. Our enquiry form does not require your real name, and you can reach us through a secure channel – Signal, WhatsApp or Telegram. To discuss your situation, write to us at info@northlarkfirm.com.
Facing an unjustified Red Notice?
Free initial assessment. Challenging Interpol Red Notices and extradition defence.
Request an assessment