West Science Law and Human Rights Vol. No. October 2025, pp. Legal Analysis of Red Notices in the Handling of Wanted Persons (DPO) Cases in Indonesia: A Study Based on Law No. 1 of 1979 on Extradition (Articles 2, 3, 4, . , and Police Regulation No. 1 of 2020 on the Functions of the NCB -Interpol Indonesia, with the Case of Fugitive Former Investree CEO Adrian Gunadi as the Focus Nabain Idrus1. Ilham Akbar Bunyamin2. Paramita Andiani3 Universitas Teknologi Mataram and nabainidrus@gmail. 2 Universitas Nusa Putra and ilhamakb14@gmail. 3 Universitas Nusa Putra and paramita. andiani_mn20@nusaputra. Article Info ABSTRACT Article history: This study examines the legal framework and implementation of Red Notices in handling fugitive cases (Daftar Pencarian Orang Ae DPO) in Indonesia, with a particular focus on the case of the former CEO of Investree. Adrian Gunadi. Using a normative legal analysis, the research explores the application of Law Number 1 of 1979 concerning Extradition (Articles 2, 3, 4, and . and Police Regulation Number 1 of 2020 concerning the Functions of the NCBAeInterpol Indonesia. The findings reveal that the Red Notice serves as a crucial tool for international law enforcement cooperation but lacks the status of a binding arrest warrant under Indonesian law. Its execution depends on the harmonization between national legal sovereignty and international obligations. The study also identifies legal and institutional challenges, such as procedural inconsistencies, limited inter-agency coordination, and inadequate bilateral extradition treaties, which hinder effective implementation. The case of Adrian Gunadi highlights these weaknesses, demonstrating the need for stronger regulatory mechanisms, enhanced cooperation between NCBAeInterpol Indonesia and foreign counterparts, and policy reforms to ensure due process and accountability. Overall, this research underscores the importance of integrating Red Notice practices into IndonesiaAos legal framework to improve the pursuit and extradition of fugitives within the boundaries of both domestic and international law. Received October, 2025 Revised October, 2025 Accepted October, 2025 Keywords: Red Notice Extradition NCBAeInterpol Indonesia Fugitive Normative Legal Analysis This is an open access article under the CC BY-SA license. Corresponding Author: Name: Nabain Idrus Institution: Universitas Teknologi Mataram e-mail: nabainidrus@gmail. INTRODUCTION The development of international law enforcement cooperation has become transnational crimes and pursuing fugitives who cross national borders. One of the key mechanisms that facilitate this cooperation is the Red Notice, issued by Interpol (International Criminal Police Organizatio. Journal homepage: https://wsj. westscience-press. com/index. php/wslhr West Science Law and Human Rights which serves as an international alert requesting the location and provisional arrest of a wanted person pending extradition. Indonesia, the Red Notice plays a crucial role in supporting domestic law enforcement agencies, especially in cases involving fugitives (Daftar Pencarian Orang or DPO) who have fled abroad to avoid prosecution. This mechanism acts as a pivotal tool in international law enforcement cooperation, enabling the pursuit of fugitives who have fled abroad and supporting domestic law transnational crimes. The importance of such cooperation is underscored by the increasing complexity and global nature of crime, necessitating sophisticated and coordinated policing efforts across borders. Interpol plays a crucial role in international police cooperation by facilitating the exchange of information and coordinating efforts to combat transnational crime, including organized crime, terrorism, and human trafficking . , . The Red Notice is a key tool used by Interpol to alert member countries about fugitives, enabling their location and provisional arrest pending extradition . Indonesia, the Red Notice supports domestic agencies in tracking and apprehending fugitives (DPO) who have fled the country to evade prosecution . This mechanism enhances the ability of Indonesian authorities to collaborate with international counterparts, ensuring that fugitives cannot easily find abroad . However, while multilateral cooperation through Interpol offers transparency and accountability, it can be hindered by bureaucratic challenges . Bilateral agreements, although more agile, may face issues of trust and accountability, highlighting the need for a balanced approach . The legal foundation for IndonesiaAos participation in Red Notice mechanisms is primarily based on two key instruments: Law Number 1 of 1979 concerning Extradition and Police Regulation Number 1 of 2020 concerning the Functions of the National Central Bureau (NCB)AeInterpol Indonesia. Law Number 1 of 1979 regulates the procedures and principles for requesting and A granting extradition between Indonesia and other states, defining essential aspects such as obligations, conditions, and grounds for refusal, as well as the reciprocity principle that underpins cross-border law enforcement cooperation . Meanwhile. Police Regulation Number 1 of 2020 outlines the operational role of Interpol Indonesia in coordinating international police cooperation, including the issuance and handling of Red Notices as instruments to track and apprehend fugitives across borders . Together, these legal IndonesiaAos commitment to global law enforcement collaboration by providing both procedural and operational mechanisms for effective participation in international policing. However, challenges remain in harmonizing IndonesiaAos extradition and Red Notice frameworks with international law, as the integration of Pancasila valuesAiparticularly those emphasizing social justice and humanityAican sometimes create friction with global obligations . Additionally, considerations, such as those in IndonesiaAos extradition cooperation with countries like Australia, implementation of extradition processes due to legal and diplomatic hurdles . The effectiveness of Red Notices remains a topic of debate in both legal and practical contexts, particularly within IndonesiaAos legal framework. While Red Notices are vital tools for international cooperation, they do not constitute arrest warrants and must be implemented in accordance with domestic laws. In Indonesia, this means that their issuance and enforcement must align with both national legislation and international obligations to ensure adherence to due process, human rights, and the principles of sovereignty. This dual requirement often generates difficulties in harmonizing domestic legal systems with international law enforcement mechanisms. The extradition treaty between Indonesia and Singapore, ratified under Indonesian Law No. 5 of 2023, was designed to facilitate the prosecution of fugitives, particularly those involved in corruption . However, the Vol. No. October 2025: pp. West Science Law and Human Rights effectiveness of Red Notices remains constrained by the lack of judicial authority and the diversity of legal systems across countries, which can limit the capacity for cohesive international cooperation . Extradition treaties and alternatives like mutual legal assistance have thus become essential in bridging these gaps, providing avenues for the recovery of fugitives and supporting the broader pursuit of justice . A contemporary example illustrating these complexities is the case of Adrian Gunadi, the former CEO of Investree, who became a fugitive following allegations of financial misconduct. His case drew significant public and legal attention to the challenges faced by Indonesian authorities, especially the NCBAeInterpol Indonesia, in utilizing the Red Notice mechanism effectively to track and apprehend fugitives It also exposed ongoing questions regarding the legal weight and enforceability of Red Notices within IndonesiaAos jurisdiction and the extent to which national and international law enforcement agencies coordinate during extradition processes. While INTERPOL cooperation through its National Central Bureaus, its effectiveness depends heavily on national responsiveness and regulatory harmonization . Moreover. INTERPOLAos legal framework allows for police cooperation even in the absence of formal extradition treaties, which can be advantageous in situations where extradition is not feasible . Nonetheless, cases like Adrian GunadiAos underscore the need to strengthen IndonesiaAos institutional capacity and legal mechanisms to ensure that Red Notices serve not only as symbolic alerts but as actionable instruments in global justice. This paper adopts a normative legal approach to analyze the legal basis, procedures, and implications of Red Notices within IndonesiaAos fugitive handling system. By examining Law Number 1 of 1979 concerning Extradition and Police Regulation Number 1 of 2020 concerning the Functions of the National Central Bureau (NCB)AeInterpol Indonesia, the study aims to elucidate how Red Notices function within IndonesiaAos legal framework and to identify potential gaps or inconsistencies in their implementation. Focusing on the case of Adrian Gunadi, the former CEO of Investree, this research illustrates the practical challenges of applying legal norms to real-world situations involving fugitives and international cooperation. The objectives of the study are to analyze the legal basis and governing principles of Red Notices in Indonesia, evaluate their effectiveness as tools for pursuing fugitives in accordance with extradition law, and assess their implementation and implications through the case study of Adrian Gunadi. Ultimately, this research contributes to the broader discourse on the intersection between international police cooperation and domestic legal sovereignty, emphasizing the necessity for Indonesia to strengthen its legal instruments, enhance institutional coordination, and align national policies with international standards to ensure that the Red Notice mechanism operates effectively, transparently, and in accordance with the rule of law within the framework of extradition and criminal justice. LITERATURE REVIEW Concept of Red Notice in International Law Interpol's Red Notices serve as a crucial tool in international law enforcement, facilitating cooperation across borders to locate and provisionally arrest individuals pending extradition or similar legal actions. While not legally binding arrest warrants. Red Notices act as alerts to member countries about fugitives wanted for prosecution or sentencing. The legal status and implementation of Red Notices vary significantly across countries treating them as binding directives and others. Indonesia, domestic legal review. Interpol emphasizes the importance of respecting human rights and due process, with the Interpol Rules Vol. No. October 2025: pp. West Science Law and Human Rights on the Processing of Data (RPD) ensuring that Red Notices are not politically motivated or in violation of international law. This highlights the need to cooperation with domestic legal Red Notices are not arrest warrants but serve as international alerts for law enforcement cooperation . , . The legal status of Red Notices varies, with some countries treating them as binding, while others require domestic legal compliance . Interpol's RPD sets limitations to prevent politically motivated notices and ensure compliance with international law . Red Notices can be challenged, and Interpol provides mechanisms for their review and deletion . The necessity of balancing international cooperation with respect for national sovereignty and human rights is emphasized . Interpol's structure and databases are central to its role in combating transnational crime . Interpol's international police cooperation is vital for addressing organized crime that transcends borders . , and the organization must balance law enforcement needs ensuring due diligence in policing . 2 Legal Framework of Extradition in Indonesia Indonesia's extradition law, primarily governed by Law Number 1 of 1979, establishes a framework for international cooperation in criminal matters, playing a crucial role in addressing transnational crimes by allowing Indonesia to engage in extradition based on treaties or reciprocity. This law also sets A forth key principles such as exceptions for political offenses and cases where individuals may Indonesia's . , . However, application of these laws faces absence of bilateral treaties and differences in legal systems, which can hinder effective Additionally, the exclusion of military offenses and crimes against Indonesia's national sovereignty . The need for modernization of Indonesia's emphasized to better address contemporary crime patterns, as the lack of formal treaties with many countries complicates . Moreover, bureaucratic complexities and variations in legal systems between Indonesia and other countries can further delay or obstruct the extradition process . 3 The Role of NCBAeInterpol Indonesia The National Central Bureau (NCB)AeInterpol Indonesia plays a crucial role in facilitating international law transnational crimes such as cybercrime, financial crimes, and Its effectiveness is largely dependent on robust institutional coordination and information-sharing The NCB acts as a bridge between Indonesian law Vol. No. October 2025: pp. West Science Law and Human Rights Interpol compliance with both domestic standards, which is vital for tracing fugitives and managing extradition requests, especially in complex cases like cybercrime and international fraud. The NCB serves as a facilitator and transnational crimes, such as cyberterrorism, by exchanging critical information with other Interpol member states . , . It is responsible for managing publication, verification, and withdrawal of Red Notices, essential tools for tracking and fugitives . The bureau also Indonesian ministries and the Attorney GeneralAos Office to ensure effective extradition and mutual legal assistance, which is crucial for tackling crimes that transcend national boundaries . Furthermore, the NCB monitors the implementation of InterpolAos standards, ensuring that both domestic and global legal norms are adhered to, particularly in the context of cybercrime and corporate crime . , . 4 Relationship Between Red Notices and Extradition The issuance of a Red Notice extradition process. Once a Red Notice is issued, the country where the fugitive is located can individual while awaiting a However, as pointed out by Shaw . Red Notices have A no direct coercive power unless recognized by domestic law. This means that member countries retain full discretion over whether to act upon them. In the Indonesian context, the implementation of Red Notices must align with Law Number 1 of 1979. This ensures that arrests or detentions based on Red Notices are legally justified and respect due process. The case of Djoko Tjandra, for example, highlighted gaps in law enforcement coordination when a Red Notice was previously deleted and later reactivated due to administrative issues. Such incidents underline the need for stronger legal clarity and transparency in handling Red Notices. 5 The Case of Adrian Gunadi and Its Legal Relevance The case of Adrian Gunadi highlights the complexities and challenges faced by Indonesia in utilizing Red Notices and mechanisms to pursue fugitives. The procedural steps for issuing Red Notice coordination between national law enforcement and Interpol, requiring adherence to both domestic and international legal This underscores the importance of extradition treaties and mutual (MLA) agreements in ensuring effective cross-border law enforcement. The absence of such treaties with significantly hinder the pursuit of justice, as seen in Indonesia's efforts to combat transnational crimes like corruption. The issuance of a Red Notice requires a formal request from the National Central Bureau (NCB) Vol. No. October 2025: pp. West Science Law and Human Rights of Interpol in the requesting country, supported by a valid arrest warrant and evidence of the crime . The process involves legal scrutiny to ensure compliance with both national and international laws, including human rights considerations . Effective coordination between Indonesian law enforcement and Interpol member states is crucial for the successful application of Red Notices . This through existing extradition treaties and MLA agreements, framework for cooperation . However, the absence of extradition treaties with certain countries poses a significant challenge, limiting the ability to . Indonesia's recent extradition Singapore exemplifies efforts to overcome such limitations and enhance international cooperation . 6 Theoretical Framework: Normative Legal Analysis This study employs a statutory interpretation, legal consistency, and principle-based Normative legal research, as described by Soerjono Soekanto involves examining written laws, legal doctrines, and judicial interpretations to evaluate how effectively legal norms address specific problems. In this context, the normative approach helps to contextual interpretation of Law Number 1 of 1979 and Police Regulation Number 1 of 2020, examine how Red Notices fit within IndonesiaAos extradition A discrepancies between law and practice in fugitive handling. applying this framework, the study situates the discussion of Red Notices within the broader legal and institutional structures of Indonesia, ensuring that conclusions are grounded in both doctrinal understanding and real-world applicability. RESEARCH METHODS This research employs a normative juridical . method, which focuses on studying law as a set of written norms contained in legislation, international conventions, and institutional regulations. According to Soerjono Soekanto . , normative juridical research aims to examine legal principles, doctrines, and regulations systematically to determine their consistency, application, and effectiveness. In this study, the normative juridical method is used to analyze the legal foundation and practical implementation of Red Notices within the Indonesian legal framework, particularly in relation to Law Number 1 of 1979 concerning Extradition, specifically Articles 2, 3, 4, and 5. Police Regulation Number 1 of 2020 concerning the Functions of NCBAeInterpol Indonesia. and the Interpol Constitution and the Interpol Rules on the Processing of Data (RPD), as international legal sources that guide the issuance and handling of Red Notices. This approach allows the research to focus on how Indonesian law aligns with international cooperation mechanisms and to identify legal challenges in applying Red Notices to specific cases such as that of Adrian Gunadi, the fugitive former CEO of Investree. The complementary approaches to provide a comprehensive legal analysis: . Statutory Approach (Pendekatan Perundangundanga. , which examines relevant laws and regulations forming the legal framework for extradition and international cooperation in criminal matters, including Law Number 1 of 1979 and Police Regulation Number 1 of Vol. No. October 2025: pp. West Science Law and Human Rights 2020, as well as international conventions such as the Interpol Constitution and general principles of international law. Conceptual Approach (Pendekatan Konseptua. , used to clarify theoretical concepts such as extradition. Red Notice, sovereignty, and international cooperation, which allows the study to explore legal doctrines and scholarly opinions explaining how these concepts interact within the Indonesian context. Case Approach (Pendekatan Kasu. , which examines the Adrian Gunadi case as an example of how Red Notices are implemented in practice, assessing procedural compliance, challenges, and lessons learned based on available reports, media releases, and statements from the Indonesian National Police and Interpol Indonesia. These three approaches together ensure that the research not only studies written laws but also connects them with their conceptual and practical implications. Legal materials in normative juridical research are divided into primary, secondary, and tertiary sources. Primary legal materials consist of authoritative legal texts and official documents, including Law Number 1 of 1979 concerning Extradition . articularly Articles 2Ae. Police Regulation Number 1 of 2020. Interpol Constitution and RPD, the 1945 Constitution of the Republic of Indonesia, and international treaties related to extradition and mutual legal assistance. Secondary legal textbooks, legal journals, previous research, and expert opinions related to extradition law. InterpolAos legal authority. Examples include works by Bassiouni . Boister . Shaw . , and Indonesian legal scholars such as Hiariej . and Siregar . Tertiary sources are supporting materials that provide clarification or additional context, such as legal dictionaries, encyclopedias, and official publications from Interpol or the Indonesian National Police. The combination of these sources enables a comprehensive understanding of both the normative and operational aspects of Red Notices in Indonesia. Data collection relies on documentary research and literature review. A including library research, document analysis, and comparative review. The data analysis employs qualitative and prescriptive interpretation, comparative interpretation, case evaluation, and prescriptive analysis to formulate recommendations to enhance IndonesiaAos mechanisms for handling fugitives through Red Notices and extradition cooperation. This ensures that the study remains doctrinally focused and consistent with the objectives of normative legal analysis. RESULTS AND DISCUSSION 1 Overview of Red Notice Implementation in Indonesia A Red Notice is an international alert mechanism used by Interpol to assist member countries in locating and provisionally arresting fugitives pending extradition. Indonesia, the issuance and enforcement of Red Notices are handled by the National Central Bureau (NCB)AeInterpol Indonesia, which operates under the Indonesian National Police (POLRI). Based on Police Regulation Number 1 of 2020. NCBAeInterpol Indonesia functions as the national liaison with Interpol Headquarters in Lyon. France, and other member countries. The bureau is responsible for managing requests for Red Notices from Indonesian law enforcement institutions, such as the Attorney GeneralAos Office. Corruption Eradication Commission, or the National Police, coordinating communication with foreign law enforcement bodies to locate fugitives, and ensuring that the request for a Red Notice aligns with national laws and international obligations. However, under IndonesiaAos legal system, a Red Notice does not have the status of an arrest warrant. Its function is limited to alerting other states about a wanted person and requesting cooperation in locating or detaining the suspect. The actual arrest or extradition must still follow domestic legal procedures and be supported by Law Number 1 of 1979. This creates a legal distinction between international police cooperation, facilitated through the Red Vol. No. October 2025: pp. West Science Law and Human Rights Notice, and formal extradition processes, which are regulated by national law. While the Red Notice accelerates information exchange, it cannot override IndonesiaAos legal sovereignty or the due process requirements stipulated by domestic regulations. 2 Legal Foundation of Red Notice under Law Number 1 of 1979 Indonesia's Extradition Law (Law Number 1 of 1. provides a comprehensive framework for international cooperation in criminal matters, particularly through Articles 2, 3, 4, and 5. These articles collectively shape Indonesia's approach to extradition and its interaction with Red Notices. Article 2 facilitates extradition based on treaties or reciprocity, allowing Indonesia to cooperate with countries even in the absence of formal treaties, which is crucial for handling Red Notice cases. Article 3 ensures that extradition requests comply with human rights protections by outlining grounds for refusal, such as political offenses or potential Article 4 introduces the double criminality principle, requiring that offenses be recognized as crimes in both Indonesia and the requesting country. Article 5 excludes non-extraditable offenses like military or political crimes, maintaining a balance between international cooperation and national sovereignty. The extradition treaty between Indonesia and South Korea exemplifies how formal agreements enhance cooperation in law enforcement and crime eradication . Reciprocity allows Indonesia to engage in extradition with countries lacking formal treaties, which is essential for processing Red Notices . Article 3's provisions align with international standards to protect individuals from extradition in cases of political offenses or potential persecution. , ensuring that Red Notice requests are scrutinized for compliance with human rights protections . The double criminality principle ensures that only offenses recognized as crimes in both jurisdictions are subject to extradition . Article 5's exclusion of military and political commitment to national sovereignty and A international norms . Collectively, these provisions establish the legal boundaries within which Indonesia can act on a Red Notice, cooperation is consistent with constitutional guarantees, human rights norms, and domestic legal principles. 3 The Role of NCBAeInterpol Indonesia in Red Notice Operations The NCBAeInterpol Indonesia, as outlined in Police Regulation Number 1 of 2020, plays a central operational role in processing Red Notices. Its duties include verification and authentication, ensuring that requests from Indonesian law enforcement agencies meet InterpolAos standards and national legal requirements. This involves a thorough review process to authenticate the legitimacy of the requests . , . The dissemination with relevant domestic institutions such as the Ministry of Law and Human Rights, the Ministry of Foreign Affairs, and the Attorney GeneralAos Office, ensuring that national efforts align with . , . Additionally. NCBAeInterpol Indonesia acts as the country's representative in facilitating communication with other Interpol member states, vital for addressing transnational crimes like cybercrime and drug trafficking . , . Furthermore, it tracks the status of Red Notices to ensure their proper use, preventing political misuse or violations of individual rights, thus maintaining the integrity of international law enforcement cooperation . , . However, challenges often arise in the coordination process between NCBAeInterpol Indonesia and other national institutions. Issues such as delays in data verification, lack of interagency synchronization, and limited access to international databases can reduce the timeliness and effectiveness of Red Notices. Additionally. InterpolAos neutrality principle, as stated in Article 3 of its Constitution, prohibits the organization from engaging in political, military, religious, or racial matters. Consequently, any Red Notice Vol. No. October 2025: pp. West Science Law and Human Rights request must undergo a thorough review to ensure compliance with these standards, which may further delay the process. 4 Analysis of the Adrian Gunadi Case The case of Adrian Gunadi, the former CEO of Investree, serves as a contemporary example of how Indonesia implements the Red Notice mechanism in handling fugitives. After being accused of financial irregularities and investor fraud. Gunadi reportedly left Indonesia, prompting law enforcement authorities to consider international cooperation measures through Interpol. From a legal standpoint, the issuance of a Red Notice for GunadiAos arrest would need to comply with both Law Number 1 of 1979 and Police Regulation Number 1 of 2020. The process involves several steps: the investigating agency . , the National Police or Attorney GeneralAos Offic. submits a request to NCBAeInterpol Indonesia, which verifies the case details to ensure the offense qualifies under extradition principles. Interpol publishes the Red Notice, allowing member countries to locate the Upon locating the fugitive, a formal extradition request is submitted through diplomatic channels based on reciprocity or existing treaties. In practice, the Adrian Gunadi case highlights several systemic issues, such as the absence of bilateral extradition treaties with certain countries where fugitives may seek refuge, bureaucratic delays in coordinating between law enforcement and diplomatic institutions, and the limited binding authority of Red Notices under Indonesian law, which prevents automatic arrest or detention. These challenges underscore the complexity of balancing international cooperation with domestic legal sovereignty. Although the Red Notice system facilitates communication and tracking, actual enforcement remains subject to the recipient countryAos legal framework and willingness to cooperate. 5 Challenges in Implementing Red Notices in Indonesia Based on the analysis, several key challenges are identified in IndonesiaAos handling of Red Notices. First, the legal status and enforcement limitations of a Red Notice in Indonesia are significant, as it does not equate to an arrest warrant, meaning law enforcement must still follow national legal procedures to request detention or extradition, leading to procedural delays. Second, effective Red Notice implementation requires seamless coordination among multiple agencies, including the National Police, the Ministry of Law and Human Rights, the Attorney GeneralAos Office, and the Ministry of Foreign Affairs. overlapping jurisdiction and communication gaps often hinder swift action. Third. Indonesia's lack of comprehensive extradition treaties with many countries complicates the enforcement of Red Notices, especially when non-treaty Additionally, administrative and technical constraints, such as limited access to real-time international databases and differences in case management systems, can impede the monitoring of fugitives. Finally, human rights and political considerations come into play, as InterpolAos strict compliance with neutrality and human rights standards requires that each Red Notice be carefully vetted, particularly when the alleged offenses may have political implications. 6 Discussion: